Text For Citation: 01 Item/Group: 019 Hazard: CHEMICAL

29 CFR 1910.119(m)(1): The employer did not investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace: (a)Suncor Energy (U.S.A.), Inc., 5801 Brighton Blvd., Commerce City, Colorado: On or about December 16, 2008, and at times prior thereto, the employer did not investigate incidents including but not limited to pump cavitation in the vacuum distillation W-36 bottoms unit which could lead to loss of containment. Employees are exposed to the hazards of hydrogen sulfide, and fire and explosion hazards due to loss of containment. (b)On or about September 17, 2008, and at times prior thereto, some reported PSM incidents were not investigated. The employer scheduled repair work without investigating the cause of the incident, including but not limited to piping failures in the D-37, X-159, D-319 circuit which occurred within approximately 14 months prior to our inspection, were not investigated to determine causal factors until the fourth incident as follows; 7/16/2007, Incident number 100000027212; 1/21/2008, Incident number 100000037788; 1/27/2008, Incident number 100000038120, and 8/20/2008, Incident number 100000047494. Loss of containment due to piping failure could lead to fire or explosion. Employees are exposed to the hazards of hydrogen sulfide, and fire and explosion hazards due to loss of containment. (c)On or about December 16, 2008, and at times prior thereto, failure of the W-36 Bottoms level indicator, 13L98, was not investigated although it was known to malfunction for several months and was the replacement for 13L96 which was listed as a Critical Alarm System. Multiple failures of this equipment (i.e., level indicators in the W-36 Bottoms), were not investigated despite numerous work notifications being submitted. Employees are exposed to the hazards of hydrogen sulfide, and fire and explosion hazards due to loss of containment. (d)On or about December 16, 2008, and at times prior thereto, pressurization of the West Plant flare line to 37 psi (which was identified as a factor in the overflow of D- 73 and loss of control of the FCC) was not investigated as a PSM incident. The overpressurization of the flare line could release explosively and cause a flash fire due to the large amounts of flammable and combustible liquids which can be present. Operators and other employees in the West Plant are exposed to the hazards of hydrogen sulfide, and fire and explosion hazards due to loss of containment. Abatement Note: Abatement certification and documentation are required for this item (see enclosed "Sample Abatement-Certification Letter").