Bp Products North America, Inc. | Occupational Safety and Health Administration osha.gov

Violation Detail

Standard Cited: 19100119 E03 IV Process safety management of highly hazardous chemicals.

Inspection Nr: 1623687.015

Citation: 01004

Citation Type: Serious

Abatement Date: 04/26/2023

Initial Penalty: $15,625.00

Current Penalty: $15,625.00

Issuance Date: 03/13/2023

Nr Instances: 2

Nr Exposed: 100

Related Event Code (REC): A

Gravity: 10

Report ID: 0524700

Contest Date: 04/04/2023

Final Order:

Emphasis:

**Penalty and Failure to Abate Event History**
Type	Latest Event	Event Date	Penalty	Abatement Due Date	Citation Type	Failure to Abate Inspection
Penalty	C: Contested	04/05/2023	$15,625.00	04/26/2023	Serious
Penalty	Z: Issued	03/13/2023	$15,625.00	04/26/2023	Serious

Text For Citation: 01 Item/Group: 004 Hazard:

29 CFR 1910.119(e)(3)(iv):The process hazard analysis did not address the consequences of the failure of engineering and administrative controls: a) BP Products North America, Inc. - Oregon, Ohio: On or about September 20, 2022, the employer failed to ensure that the PHA addressed the consequences of failure of administrative controls by not following the South/Coker Gas Plant: Bypassing and Returning to Service Coker Gas Plant Procedure (CGP 02.004). The procedure required closing FV-3816 while the Coker Gas Plant was in bypass mode. During the incident, FV-3816 was opened causing the Absorber Stripper Tower (PR-550025) and the downstream equipment including the TIU Fuel Gas Mix Drum (PR-510253) to overfill with liquid naphtha. This led to a direct path of liquid naphtha, causing an uncontrollable high level in the TIU Fuel Gas Mix Drum, exposing employees to fire, explosion hazards, and toxic gases from potential releases of fuel gas, flammable liquids, and hydrogen sulfide. b) BP Products North America, Inc. - Oregon, Ohio: On or about September 20, 2022, the employer failed to ensure that the PHA addressed the consequences of failure of administrative controls by not following Coker Gas Plant and NHT Feed Surge Drum Safe Operating and Design Limits which required steps to avoid an overfill scenario of the Absorber Stripper Tower (PR-550025) to include verifying that the Absorber Stripper Tower bottom valve (XV-3821) was open. Keeping this valve closed led to overfilling of the Absorber Stripper Tower (PR-550025) and the downstream equipment including the TIU Fuel Gas Mix Drum (PR-510253). This led to a direct path of liquid naphtha, causing an uncontrollable high level in the TIU Fuel Gas Mix Drum, exposing employees to fire, explosion hazards, and toxic gases from potential releases of fuel gas, flammable liquids, and hydrogen sulfide. c) BP Products North America, Inc. - Oregon, Ohio: On or about September 20, 2022, the employer failed to ensure that the PHA addressed the consequences of failure of engineering controls when the high-level switch (LSH-805) was not available to detect high level of flammables in the TIU Fuel Gas Mix Drum during an overfill scenario of the Absorber Stripper Tower (PR-550025) and downstream vessels. Failure to evaluate loss of engineering controls resulted in an uncontrollable high level in the TIU Fuel Gas Mix Drum, exposing employees to fire, explosion hazards, and toxic gases from potential releases of fuel gas, flammable liquids, and hydrogen sulfide.

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