Violation Detail
Standard Cited: 19100119 F03 Process safety management of highly hazardous chemicals.
Inspection Nr: 908161.015
Citation: 02002
Citation Type: Serious
Abatement Date: 12/11/2013 2
Initial Penalty: $70,000.00
Current Penalty: $35,000.00
Issuance Date: 11/21/2013
Nr Instances: 5
Nr Exposed: 18
Related Event Code (REC):
Gravity: 10
Report ID: 0626300
Contest Date: 12/10/2013
Final Order: 07/23/2014
Emphasis:
Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
---|---|---|---|---|---|---|
Penalty | C: Contested | 03/16/2015 | $70,000.00 | 12/11/2013 | Repeat | |
Penalty | F: Formal Settlement | 07/23/2014 | $35,000.00 | 12/11/2013 | Serious | |
Penalty | Z: Issued | 11/21/2013 | $70,000.00 | 12/11/2013 | Repeat |
Text For Citation: 02 Item/Group: 002 Hazard:
29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer did not annually certify that operating procedures were current and accurate: The employer does not ensure that operating procedures are current and accurate. This violation occurred on or about May 23, 2013 and at times prior thereto in the Naphtha Hydrotreater (NHT) and Saturated Gas (Sat-Gas) where employees were exposed to inhalation, fire, and explosion hazards from potential releases of hazardous materials without ensure operating procedures were current and accurate for the following instances. a. In the Naphtha Hydrotreater/Saturated Gas/ Unit Operating Limit List of Equipment, Procedure number 30.8.1 Bates: #00376: . The "Sat Gas Vessel List" is incorrect. It should be listed as Naphtha Hydrotreater Vessel List. . The high temperature separator is listed as 30-V-2 that is incorrect. It should be listed as 30-V-1. . Temperature is controlled with TIC-3002& is incorrect. It should be listed as temperature is controlled with TC-021. . The low temperature separator is listed as 30-V-3 that is incorrect. It should be listed as 30-V-2. Bates #00378: The "Naphtha Hydrotreater Vessel List" is incorrect. It should be listed as Saturated Gas Vessel List. Bates #00379: In the Debutanizer, 60-V-3A, it states "Bottom product from the Debutanizer is charge to the Splitter Tower (60-V-6)". This is incorrect. The Splitter Tower (60-V-6) was out of service. Bates #00380: Splitter Tower (60-V-6) and its process safety information (PSI) are listed in the Sat-Gas Vessel list. This tower should be removed because it was out of the service. The new splitter (60-20-V) and its PSI should be added into this procedure. b. In the "Emergency Procedure /Loss of Utilities", Procedure Number 30.2.7, Bates #00120. In Step #5, it states"The 300-psig steam to the Splitter reboiler, 60-E-18, will stop". This is incorrect because the reboiler, 60-E-18, was out of service. c. In the "Normal Start-Up Procedure/Naphtha Hydrotreater/Establishing Naphtha Circulation", Procedure Number 30.3.4, Bates #00155, in the step #7, it states"If Naphtha from the Crude Unit is not available, the Contact Accumulator (60-V-11) and the Stripper (60-V-10) can be established by lining Naphtha to the Splitter Bottoms Pumps (60-P-8A/B)."This is incorrect because Splitter Bottom Pumps (60-P-8A/B) were out of service. d. The "Special Procedures/Naphtha Hydrotreater Chloride Scrubber (30-V-8) Adsorbent Change out Shutdown Procedure", Procedure Number 30.5.10, Bates #00211-#00217 was listed in the operating procedures. This procedure should be removed because the Booster Gas Chloride Scrubber (30-V-8) was out of service. e. In the "Start-Up Procedures/Naphtha Hydrotreater /Isolation-Purging-Evacuation in Preparation for Start-Up", Procedure Number 30.3.1, Bates #00165, in step #18, it states "Line up chloride scrubber (30-V-8) for service". This step should be removed because the Booster Gas Chloride Scrubber (30-V-8) was out of service.