Violation Detail
Standard Cited: 19100119 E05 Process safety management of highly hazardous chemicals.
Inspection Nr: 313029233
Citation: 02001
Citation Type: Repeat
Abatement Status: X
Initial Penalty: $35,000.00
Current Penalty: $35,000.00
Issuance Date: 08/19/2010
Nr Instances: 2
Nr Exposed: 7
Abatement Date: 09/07/2010
Gravity: 10
Report ID: 0625700
Contest Date: 09/10/2010
Final Order:
Related Event Code (REC):
Emphasis:
Text For Citation: 02 Item/Group: 001 Hazard: REFINERY
29 CFR 1910.119(e)(5): The employer did not establish a system to promptly addre ss the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a writte n schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the pr ocess and who may be affected by the recommendations or actions. A.The employer does not consistently ensure that recommendations and/or corrective actions from PHAs are resolved. This violation was observed on or about March 3, 2010. It was observed that the response to the recommendation from Node 5 Quest ion 15 of the initial PHA stated that relief valves PSV 1911 and PSV 1912 in the Platformer Unit were removed during the 1995 turnaround. PSV 1911 appears on P& ID 19-E-54-3000 and PSV 1912 appears on P&ID 19-E-54-4000. Both P&IDs were field validated in March 17, 2009. PSV 1911 is still in service, but PSV 1912 has bee n removed. A failure to effectively document resolutions can result in fire and explosion hazards to employees. CALUMET lUBRICANTS WAS PREVIOUSLY CITED FOR A VI OLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD WHICH WAS CONTAINED IN I NSPECTION 310249941, CITATION NUMBER 01, ITEM NUMBER 3 AND 4, ISSUED ON SEPTEMBE R 24, 2007, WITH RESPECT TO A WORKSITE LOCATED AT 3333 MIDWAY AVE., SHREVEPORT, LA 71109. THIS CASE BECAME A FINAL ORDER ON MAY 28, 2008. Pursuant to 29 C. F. R . 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation that it is in compliance w ith the standard, including describing the steps it is taking to ensure PHA reco mmendations and/or corrective actions are completed in a timely manner. One meth od of abatement among others is to have someone other than the person responsibl e for the recommendation/correction verify the corrective actions. B.The employe r does not ensure that findings, related to facility siting from the results of process hazard analyses, effectively control fire and explosion hazards that emp loyees are exposed to who occupy structures located near hazardous processes. Th is violation was observed on or about February 24, 2010 where the employer faile d to ensure that recommendations for findings of Process Hazard revalidations fr om the Hazop 39, PDA Revalidation 2003, MEK 2K &7K area Revalidation 2004, and M EK 1000, 3000, 4000, 5000, & 6000 Revalidation, Date 1/9/08, for facility siting we re documented. Recommendations from a September, 2009 facility siting study are not resolved and documented for the following locations: 1.The Central Control R oom where employees control refinery process units. 2.The South Wing Office and Laboratory building where employees manage the refinery programs and conduct ana lytical testing for the refinery processes. Pursuant to 29 C. F. R. 1903.19, wit hin ten (10) calendar days of the date of this citation, the employer must submi t documentation that it is in compliance with the standard, including describing the steps it is taking to ensure employees are protected by either modifying th e buildings or removing the occupants from potentially hazardous zones that can be damaged during an explosion.
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