Text For Citation: 02 Item/Group: 031B Hazard: REFINERY

29 CFR 1910.119(e)(3)(i): The process hazard analysis does not address the hazar ds of the process: BP-Husky Refining, LLC - Oregon, Ohio: The employer does not address in the process hazard analyses, the existence of permanent connections b etween the plant fire water system and process systems that could lead to the co ntamination of fire water supply with hydrocarbons or other process fluids, in t hat, a. In the Isocracker 2 Unit, there is a cross connection at the 6" supply w ater to the cooler box on the east side of the unit; b. In the Hydrogen Unit the re are two cross connection instances on the blowdown drum; c. In the Sulfur Rec overy Unit, there are two filter backwash cross connections; d. In the Reformer 2 regeneration system, there is a cross connection between th e quench and cooling water; e. There are cross connections on the discharge side s of the fire water booster pumps in the FCC Unit. Pursuant to 29 CFR 1903.19, w ithin the (10) calendar days of the abatement date, the employer must submit doc umentation that it has abated the hazard. In addition, udner 29 CFR 1903.19(e), the employer, must submit an abatement plan describing the actions it is taking to ensure that it is in compliance with the standard. The abatement plan shall e stablish dates during the next three months to determine when applicable PHA's w ill be updated to address the hazards of cross contamination of fire water with process water. Once the plan has been fully implemented, the employer must submi t certification of its full compliance with the standard.e