Violation Detail
Standard Cited: 19100119 L04 Process safety management of highly hazardous chemicals.
Inspection Nr: 312380512
Citation: 01010B
Citation Type: Serious
Abatement Date: 08/17/2009 X
Initial Penalty:
Current Penalty:
Issuance Date: 08/04/2009
Nr Instances: 5
Nr Exposed: 200
Related Event Code (REC):
Gravity: 10
Report ID: 0627700
Contest Date: 08/24/2009
Final Order:
Emphasis:
Text For Citation: 01 Item/Group: 010B Hazard: REFINERY
29 CFR 1910.119(l)(4): A change covered by 29 CFR 1910.119 (l) resulted in a change in the process safety information required by 29 CFR 1910.119(d) and the process safety information was not updated: The employer does not ensure process safety information (PSI) is updated as required by paragraph (d) of the PSM standard when the process is modified/changed. This violation was most recently discovered on or about February 4, 2009, and at times prior thereto and thereafter, when the employer did not update FCCU process flow diagrams (PFDs) or piping and instrument diagrams (P&IDs). The employer is deficient on PSI, such as, but not limited to, the following: a) PFD drawing 13326-D, Rev. A, current on February, 4, 2009; "7J-15A, 15C, 50" are depicted on the flow diagram as the wet gas compressors in service in the FCCU; 7J-15A and C are not in service. b) PFD drawing 13326-D, Rev. A, current on February, 4, 2009; equipment information on the PFD lists 7J-15A, 15C, 7J-42 and 7J-42M as wet gas compressors in service in the FCCU; wet gas compressors 7J-15A, 7J-15C, 7J-42 and 7J-42M are not in service. c) PFD drawing 13326-D, Rev. A., current on February, 4, 2009: a compressor dry drum, 7F-8, is depicted on the flow diagram upstream of the wet gas compressors in service in the FCCU; the compressor dry drum, 7F-8 is not in service. d) PFD drawing 13326-D, Rev. 0., updated on February, 19, 2009: equipment information on the PFD lists 7F-8 as the compressor dry drum in service in the FCCU; the compressor dry drum, 7F-8 is not in service. e) P&ID 11947-O-D, Rev. 3: P&ID depicts 7G-4, a catalyst removal cyclone, which was removed from the Unit, and does not depict the Donaldson Torit Baghouse added to the Unit after the cyclone was removed from service. f) The Plot Plan in the FCCU Operating Procedures Manual shows the locations of the J- 15A, J-15C, and J-42; this equipment is no longer on the Unit. g) The Plot Plan in the FCCU Operating Procedures Manual does not show the location of J- 50. h) In the FCCU Operating Procedures Manual, Section 307, the equipment description for catalyst recovery equipment in the FCCU Operating Manual has information on 7G-4, the Catalyst Disposal Cyclone, which was taken out of service in 2008. There is no description of the Baghouse that was installed on the Unit when the cyclone was taken out of service. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit an documentation showing that it is in compliance with the standard; in addition, an abatement plan must be submitted describing the steps it is taking to ensure all PFDs and P&IDs are accurate, up-to-date and depict all equipment existing in the field, as well as steps it is taking to ensure that PSI remains up-to-date and accurate. Every 30 days thereafter, the employer shall submit a progress report stating how many PFDs and P&IDs have been updated, how many still need to be updated, whether it is meeting the schedule set forth in its abatement plan, and if not why not; and whether it is maintaining the PFDs and P&IDs that have been updated.