Text For Citation: 01 Item/Group: 008B Hazard: FALLING

29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices (REGAGEP): a) 2PF - The employer failed to protect employees inside the operator shelter which was potentially exposed to overpressure hazards of up to 3 psi as a result of a vapor cloud explosion. The 2004 facility siting analysis did not identify the building as exceeding the occupancy criteria and no further action was taken. However, the employer failed to conduct an in depth occupancy load analysis at the unit instead relying solely on a study performed at their Trainer, PA refinery. Employees working within the structure were not protected through mitigation measures to include strengthening doorways, reinforcing walls, relocating personnel or rearranging room functions within the building. Condition noted on or about 01/18/08. Abatement Note OSHA does not accept occupancy criteria evaluations (see API 752, Section 2.5.2) as the basis for an employer's determination that adequate protection has been provided for employees in occupied structures which employer's have identified as being potentially subject to explosions, fires, ingress of toxic materials or high energy releases. b) PPBW - The employer did not comply with API 753 Section 3 when it failed to protect employees inside a wooden trailer being used as an operator shelter that was placed within the 1 psi overpressure zone. Condition noted on or about 01/22/08. c) 2PF - The employer did not comply with ASME Boiler and Pressure Vessel Code, Division 1 (BPVC), Section VIII, UG-135(d) when it failed to provide adequate controls to ensure that the block valve for safety valve 2992 on T109 remained in the open position. Condition noted on or about 03/07/08. d) 2PF - The employer did not comply with NFPA 496 Section 7.4.1 in that the air curtain on the West 1 door was measured at negative 342 feet per minute (FPM). A minimum reading of 60 FPM must be maintained through all openings. In addition, although exceeding a minimum outward velocity in excess of 60 FPM the air curtains on doors North 2 and 3 were disabled and not functioning. Condition noted on or about 03/06/08. e) ABW - Illumination of means of egress as required by NFPA 101 Section 7.8.1 was not adequately maintained throughout the unit. Employees were exposed to slip, trip and fall hazards while climbing stairs and ladders during the course of work operations. Condition noted on or about 02/12/08. f) ABW - The process sewer to include the catch basin and lateral piping under the Isobutane Receiving Drum (D18) were damaged. In the case of a release, isobutane would pool in the area and not be effectively transported via the process sewer exposing workers to fire hazards. Condition noted on or about 03/06/07.