Text For Citation: 01 Item/Group: 010 Hazard: REFINERY

29 CFR 1910.119(e)(5): The employer failed to establish a system to promptly address the process hazard analysis team's findings and recommendations and to assure that the recommendations were resolved in a timely manner: Category II (medium) and Category III (significant) risks were not resolved in a timely manner with Category II recommendations completed within 5 years and Category III findings resolved within 3 years. This time frame developed by the employer did not meet OSHA and industry standards. In addition, some PHA recommendations were not completed within their assigned completion dates. PHA recommendations that remained open at the time of the inspection included but were not limited to: a) Flare Grid PHA, Action Item 78050, Cat III, Audit Date 02/08/05, Finding - Potential for sulfur buildup and back pressure in flare grid. Action - Install rupture disks per Process Specification 2007-13. Condition noted on or about 04/16/08. b) ABW PHA, Action Item 70565, Cat II, Audit Date 06/02/04, Findings - The P-36 appears to have difficulty in pumping light hydrocarbons. A procedure exists to bypass D-36 to use nitrogen pressure to help pump the material, but it takes time to make the lineup. Action - Consider whether modification/replacement of P-36 is required to enable pumping of light hydrocarbon from the ABW flare KO drum D-36. Condition noted on or about 02/28/08. c) ABW PHA, Action Item 70629, Cat II, Audit Date 06/02/04, Findings - Since the D-3 EIV is greater than 8-inch size, a power operated EIV is recommended per API 553. The D-3 EIV is located at a distance greater than 25 feet from the P-3 seal, therefore a Type CE EIV is adequate. Action - Consider motorizing the existing 12- inch EIV under D-3 to a Type C. Condition noted on or about 03/07/08. d) 2PF PHA, Action Item 66914, Cat II, Audit Date 09/25/06, Finding - No Flow- Outlet valve of E-122 Stabilizer Reflux Condenser closed. Action - Consider car- sealing open inlet and outlet valves of E-122 Stabilizer Reflux Condenser. Condition noted on or about 02/27/08. e) 2PF PHA, Action Item 66754, Cat III, Audit Date 09/25/06, Finding - PL56 open more than required. Potential decreased level in D-114 Powerformate Splitter Feed Surge Drum potential cavitation of P-123A/B Powerformate Splitter Feed Pumps. Action - Consider providing independent high and low level alarms on D-114 Powerformate Splitter Feed Surge Drum. Condition noted on or about 04/16/08. f) FCAT PHA, Action Item 70038, Cat II, Audit Date 09/08/03, Finding - The distance to the isolation valve is less than 25 feet from the pumps/compressors and the inventory in the drum is greater than 2,000 gallons of light ends. Recommendation - Consider upgrading the D-1 Suction Drum and D-301 Suction Drum isolating bottom valves from type A to type D. Condition noted on or about 12/11/07.