Text For Citation: 01 Item/Group: 025 Hazard: UNAPOPPROC

29 CFR 1910.120(q)(2)(iv): The emergency response plan did not address, to the extent not addressed elsewhere, safe distances and places of refuge: (a)Suncor Energy (U.S.A.), Inc., 5801 Brighton Blvd., Commerce City, Colorado: On or about November 13, 2008, and at times prior thereto, The employer's emergency response plan did not include procedures for occupying safe havens. Operators are required to shelter in place in the control room during emergency evacuations. Other buildings such as the Maintenance Shop are listed as shelter in place refuges in the employer's emergency response plan. (b)On or about November 13, 2008, and at times prior thereto, the assembly areas in the employer's emergency response plan, the 4 Plex and the Warehouse, were not located at a safe distance. The 1998 Building Siting Evaluation indicated that a release from the Fuel Gas Contactor Knockout Drum would result in H2S levels above 300 ppm (IDLH is 100 ppm) up to 0.6 miles for a 1 in diameter release and up to 2 miles for a 3 inch diameter release. The assembly areas are within these radii. The employer's emergency response plan did not include evacuation contingency plans if an H2S release occurred from the Fuel Gas Contactor Knockout Drum. Abatement Note: Abatement certification and documentation are required for this item (see enclosed "Sample Abatement-Certification Letter").