Violation Detail
Standard Cited: 19100119 D03 I D Process safety management of highly hazardous chemicals.
Inspection Nr: 1521774.015
Citation: 01003
Citation Type: Serious
Abatement Date: 08/03/2022 4
Initial Penalty: $13,653.00
Current Penalty: $13,653.00
Issuance Date: 11/08/2021
Nr Instances: 11
Nr Exposed: 34
Related Event Code (REC):
Gravity: 10
Report ID: 0215300
Contest Date: 12/01/2021
Final Order: 08/15/2022
Emphasis:
Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
---|---|---|---|---|---|---|
Penalty | F: Formal Settlement | 08/15/2022 | $13,653.00 | 08/03/2022 | Serious | |
Penalty | C: Contested | 12/06/2021 | $13,653.00 | 08/03/2022 | Serious | |
Penalty | Z: Issued | 11/08/2021 | $13,653.00 | 08/03/2022 | Serious |
Text For Citation: 01 Item/Group: 003 Hazard:
29 CFR 1910.119(d)(3)(i)(D): Relief system design and design basis pertaining to the equipment in the process were not compiled before conducting any process safety analysis required by this standard. (a) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - the employer's relief system design basis and calculations did not include complete and accurate information such as all applicable overpressure scenarios and relief load calculations, Pressure Relief Device (PRD) documentation (PRD make/model, and materials of construction), and installation documentation (Relief piping isometrics), inlet and outlet pressure drop calculations including PRV stability (engineering analysis), and piping stress and reaction force analysis. (b) On or about May 12, 2021 at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - the employer failed to update relief system design basis and calculations after the crude composition changed. (c) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - the employer's relief system design basis and calculations did not include relief system design basis for the Blowdown Tower (T-8512). (d) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - the employer's relief system design basis failed to reevaluate overpressure scenario and sizing calculations for the Blowdown Tower (T-8512), Blowdown Drum Overhead Accumulator (D-8513) and Coke Fractionation Tower (T-8501), when the capacity of Coke Drum relief devices was increased. (e) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - the employer's relief system design basis and calculations did not include an evaluation of overpressure scenarios involving automatic control valve failure. In particular, the Coke Drum D-8504's relief system design basis shows that the vapor blocked outlet is the controlling scenario but the scenario analyses stated that there is "no relief" due to automatic control valve failure. (f) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - the employer's relief system design basis and calculations failed to include an evaluation of overpressure scenarios associated with water entering hot oil inside Coke Drum during quenching operation. (g) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - the employer's relief system design basis and calculations did not include or evaluate two phase flow as a Coke Drum relieving scenario during abnormal quenching. (h) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - the employer's relief system design basis and calculations did not take into account viscosity of process streams in Coker Unit relief system design basis. (i) On or about May 12, 2021, at Limetree Bay Refining, LLC., Flare No. 8 Complex - the employer's relief system design basis and calculations failed to evaluate all applicable overpressure scenarios when sizing Flare No. 8 header and the associated Flare knockout drums (D-7941 and D-8702). (j) On or about May 12, 2021, at Limetree Bay Refining, LLC., Flare No. 8 Complex - the employer's relief system design basis failed to compile complete accurate information for the East Flare header. (k) On or about May 12, 2021, at Limetree Bay Refining, LLC., Flare No. 8 Complex - the employer's relief system design basis and calculations did not include sizing calculations for the FCC Flare Knockout Drum (D-7941) and Coker Flare Knockout Drum (D-8702).