Text For Citation: 03 Item/Group: 009C Hazard: REFINERY

29 CFR 1910.119(e)(3)(iii) The process hazard analysis shall address: Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.) A. The employer did not ensure that the process hazard analysis (PHA) addressed specific engineering or administrative controls applicable to the identified hazards for Crude Heater FUR-20250, specifically low or no flow. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. During review of the 2005 #2 Crude Unit PHA, Item 5.9 (MDDW 1-UOSH27 0217) did not identify the specific engineering or administrative controls applicable to the identified hazards for Crude Heater FUR-20250. The employer did not identify periodic flame inspection as a safeguard and as an action item for the deviation of "high fuel pressure". By not addressing engineering and administrative controls applicable to the hazards, critical safeguards may not be present or used to ensure safe operation. Such oversight can lead to employees being exposed to hazardous situations that can cause serious injury or death. This may be a system-wide occurrence that requires evaluation of all process hazard analysis' (PHA's) throughout the facility. B. The employer did not ensure that the process hazard analysis (PHA) addressed specific engineering or administrative controls applicable to the identified hazards for Crude Heater FUR-20250, specifically no flow monitoring stations downstream. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. In the 2005 #2 Crude Unit PHA, Item 5.14 (MDDW 1-UOSH27 0218) the employer incorrectly identified the safeguard of "automatic furnace shutdown" as having the ability to mitigate the consequence of a "tube leak or rupture" in the crude heater. In order to do this there would have to be a crude flow monitoring station downstream of Crude Heater FUR-20250 with a signal to the fuel gas control valve TCV 28201. Per P&ID 02-PR-PID-0004 (MDDW 1- UOSH21 0030), there are no flow monitoring stations downstream of the crude heater and there are no flow related inputs to the fuel gas control valve for Crude Heater FUR-20250. By not addressing engineering and administrative controls applicable to the hazards, critical safeguards may not be present or used to ensure safe operation. Such oversight can lead to employees being exposed to hazardous situations that can cause serious injury or death. This may be a system-wide occurrence that requires evaluation of all process hazard analysis' (PHA's) throughout the facility. C. The employer did not ensure that the process hazard analysis (PHA) addressed specific engineering or administrative controls applicable to the identified hazards for Crude Heater FUR-20250, specifically related to safety equipment installed in the field. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. In the 2005 #2 Crude Unit PHA, Item 5.14 (MDDW 1-UOSH27 0218) the employer identified a "pilot flame scanner" and a "stack oxygen analyzer" as existing safeguards to offset the deviation of loss of pilot/ignition. During a UOSH field survey on March 15, 2009, and as stated byManagement, neither of these safeguards exist on the crude heater FUR-20250. By not addressing engineering and administrative controls applicable to the hazards, critical safeguards may not be present or used to ensure safe operation. Such oversight can lead to employees being exposed to hazardous situations that can cause serious injury or death. This may be a system-wide occurrence that requires evaluation of all process hazard analysis' (PHA's) throughout the facility. D. The employer did not ensure that the process hazard analysis (PHA) addressed specific engineering or administrative controls applicable to the identified hazards for Crude Heater FUR-20250, specifically the basic deviation of loss-of flame in the main burner. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. In the 2005 #2 Crude Unit PHA, Item 5.14 (MDDW 1-UOSH27 0218) the employer identified 34 deviations for crude heater FUR-20250. The employer did not identify the basic deviation of loss-of flame in the main burner. If this deviation had been identified, then flame-monitoring (e.g., fire-eyes, flame scanner, etc) devices would have been identified as the main potential safeguard for this deviation. During a UOSH field survey on March 15, 2009, and as stated by Management, no flame monitoring device has been installed on the crude heater FUR- 20250. By not addressing engineering and administrative controls applicable to the hazards, critical safeguards may not be present or used to ensure safe operation. Such oversight can lead to employees being exposed to hazardous situations that can cause serious injury or death. This may be a system-wide occurrence that requires evaluation of all process hazard analysis' (PHA's) throughout the facility.