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Occupational Safety and Health Administration OSHA

Citation 314767104/01013

InspectionReporting IDOpen DateSICEstablishment Name
314767104 0625700 09/15/2010 2911Calumet Lubricants Co., L.P.

CitationIssuance DateHazard Category
01013 03/14/2011 Refinery

29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address engineer ing and administrative controls applicable to the hazards and their interrelatio nships such as appropriate application of detection methodologies to provide ear ly warning of releases: a)The employer does not conduct a process hazard analysi s which addresses engineering and administrative controls (process monitoring an d control instrumentation with alarms and detection hardware such as hydrocarbon sensors) applicable to the hazards and their interrelationships with appropriat e application of detection methodologies; and is also appropriate for the comple xity of the process. Items such as alarms, pressure relief devices, flares, hydrocarbon sensors, emergency procedures, emer gency operating procedures, fire monitors were not addressed for many nodes in t he process hazard analysis. There are almost always consequences of interest for a change in a process parameter. For example: more flow into a vessel will usua lly generate more pressure in the vessel, more level in the vessel, or more flow out of the vessel. Also, reverse flow will usually be problem. Yet items such a s these were addressed in the Hazop as "No consequences of interest." This viola tion was documented on or about December 9, 2010 when it was noted that the 2007 What-if PHA for the 1100 Unit listed the consequences of the fire box being too hot as "Overheating the tubes with possible equipment damage, whereas the HAZOP PHA listed the consequence of the fire box being too hot as "No Consequences of interest." The HAZOP contained 14 nodes. One of them, Heater H11 01, was reanalyzed as a What-if. The other 13 nodes did not benefit from this ex panded approach. For them, most items are addressed as "No consequences of inter est." Examples: Node 3.3, Feed Line Out, had "No Consequences of Interest for al l items except leak/rupture. Node 5.2, Line in and Out Including Shell Side,, ha d "No Consequences of Interest for all items except leak/rupture. Node 9.2, Wate r Draw Line Out, had "No Consequences of Interest for all items except leak/rupt ure. b)The employer failed to ensure that the process safety information concern ing the technology of the process included a written evaluation of the consequen ces of deviations, including those affecting the safety and health of employees. A writ ten evaluation of the consequences of deviation is not available for pressure ve ssel E-403 A/B/C, 2.1 Line in Shell Side . The consequences of deviation lists " no consequence of interest" for would include circumstances which could result i n conditions such asmore flow, less flow, more pressure, and less pressure, the potential hazards of these consequences (equipment failure, release of hydrocarb ons, fire, explosion), and a list of the safeguards (e.g., alarms, operating pro cedures, training, pressure safety valves, flare system, blast-resistant buildin gs, etc.) available which protect employee safety and health. This may be a syst em-wide occurrence that requires the development and evaluation of all consequen ces of deviation throughout the facility. Pursuant to 29 CFR 1903.19, within ten (10)calendar days of the abatement date, the employer must submit an abatement plan describing the actions it is taking to ensure that the abovementioned possibilities are considered in all future Process Hazard Analyse s to protect employees.

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