Text For Citation: 01 Item/Group: 005 Hazard: REFINERY

29 CFR 1910.119(e)(3)(iii) The process hazard analysis was not appropriate to the complexity of the process. It did not 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. The employer violated this standard on or about June 6, 2011. In its Pipestill (PSLA-7) 2011 Delta and Transient Operation Hazop, the employer recommended that the three gate valves on the pipe line connecting the fire water system to the main quench (river) water supply pipe line be carsealed open to ensure adequate quench water flow to Blowdown Drum D-7. However, there are two block valves and a control valve on the river water line downstream of the point where the fire water line merges with it. These three valves must also be kept open for quench water to reach the blowdown. However, the PHA made no recommendation to carseal those valves open, and a field audit verified the valves are not carsealed open. Since the valves on the river water line are downstream of the point where the fire water merges with the river water line, closure of any one of these three valves will eliminate the flow of quench water to the blowdown. Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an abatement plan describing the actions it is taking to ensure that every future Process Hazard Analysis is sufficient to cover all process hazards. The violation must be abated no later than 10 days from the receipt of this citation.