Sunoco, Inc. (R&M) Marcus Hook Refinery - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RELEASE POLICIES At the Sunoco, Inc. (R&M) Marcus Hook Refinery, hereafter referred to as the Marcus Hook Refinery, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We are committed to promoting the health and safety of our employees, contractors, the facility and the community in which we operate. We are proactive in the use of a combination of accidental release prevention and emergency response planning programs to help ensure that our safety and environmental goals are met. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * Supplemental information on our RMP data elements * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * A five-year accident his tory for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our accidental release prevention programs * An overview of our emergency response program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment STATIONARY SOURCE AND REGULATED SUBSTANCE DESCRIPTION The Marcus Hook Refinery, located in Marcus Hook Pennsylvania, is a quality producer of refined products such as gasoline, jet fuel, kerosene, heating oil, propane, butane, and petrochemicals such as benzene, toluene, cyclohexane, propylene, ethylene, and ethylene oxide, using a variety of chemicals and processing operations. The Marcus Hook Refinery has been in business at the same location since 1901. The refinery can process sweet crude oil obtained primarily from the North Sea and West Africa. Other functions on the 781-acre site are research and development and a lubes service center. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics Ethylene Oxide is the only toxic in the Marcus Hook Refinery that meets the threshhold quantity specified by the RMP regulation. Flammables The Marcus Hook Refinery has a number of flammables which are in threshhold quantities that are specified by the RMP regulation: Hydrogen, Methane, Ethane, Ethyl Mercaptan, Propane, Propylene, Isobutane, Butane, Butene, Isobutene, 1-Butene, 2-Butene-cis, 2-Butene-trans, 1,3-Butadiene, Isopentane, Pentane and Pentene. The Refinery covered processes are included in the RMP program level three criteria. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. SUPPLEMENTAL INFORM ATION ON OUR RMP DATA ELEMENTS The following information would not fit into the appropriate fields in RMP*Submit and is therefore included in this executive summary: Section 1.12.c CAA Title V Air Operating Permit ID. Since the Marcus Hook Refinery is located in two States, Delaware and Pennsylvania, we have two Air Operating Permit IDs. For the State of Delaware, our ID is AQM-003/00021. For the State of Pennsylvania, our ID is pending. Section 9.7.a-b Local agency with which facility's ER plan or response activities are coordinated. We coordinate with three agencies: the Borough of Marcus Hook (610-485-1341), the Delaware County LEPC (610-565-8700), and Lower Chichester Township (610-485-1472). KEY OFFSITE CONSEQUENCE ANALYSES EPA's RMP rule requires that we provide information about the worst-case release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to lim it the exposure distances for each scenario: Worst-case Release Scenario (WCS) --- Regulated Toxic Chemical The single toxic worst case scenario as identified in the RMP is Ethylene Oxide contained in a storage vessel containing 220,000 pounds of the chemical. The entire quantity is released for a ten minute period with no allowance for any passive mitigation or administrative controls. The weather conditions used are 78 degrees F, 50% humidity, windspeed of 3.36 miles per hour and F stability. Alternate Release Scenario (ARS) --- Regulated Toxic Chemical The alternate release scenario for Ethylene Oxide is identified as a failure of a flexible railcar loading hose releasing 910 pounds per minute of material for a ten minute period for a total of 9100 pounds. Weather conditions used are 60 degrees F, 68% humidity, windspeed of 7 miles per hour and D stability. Worst-case Release Scenario (WCS) --- Regulated Flammable Chemicals The worst case scenario for flammables is determined to be Pentane contained in a storage vessel containing 9,000,000 pounds of material released, vaporized and ignited per RMP definition. No allowance was made for passive mitigation or administrative controls. The weather conditions used are 78 degrees F, 50% humidity, windspeed of 3.36 miles per hour and F stability. Alternate Release Scenario (ARS) --- Regulated Flammable Chemical The alternate release scenario for flammables is identified as a 2 inch piping failure on the above ground cavern equipment releasing 2540 pounds per minute of Butanes for 13 minutes for a total of 33,000 pounds and leads to a pool fire. Weather conditions used are 60 degrees F, 68% humidity, windspeed of 7 miles per hour and D stability. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. FIVE YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occ ur at our facility. All of the events were examined for RMP eligibility and there were no RMP incidents meeting the requirements defined by the RMP regulation. GENERAL ACCIDENT RELEASE PREVENTION PROGRAM (PSM) We maintain a number of programs to help prevent accidental releases and ensure safe operation. The elements in place are the 14 elements outlined in the OSHA Process Safety Management regulation 1910.119. Details of each of the PSM elements are outlined here in this executive summary. Individual elements of our prevention program work in unison to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 1. Employee Participation In accordance with Section 68.83 of the RMP rule, our employee participation plan helps ensure that all employees ha ve appropriate involvement in developing and implementing RMP. We have a written employee participation program that meets PSM requirements. In this document, we describe in detail the many different ways that employees participate in each element of the PSM regulations. This document has been made available to all employees for review, comment and use. We considered all comments and, where appropriate, revised the draft. We periodically update this document as changes occur. Employee participation is based on the principle that employee involvement in various areas of PSM is key to maintaining a Process Safety System that has input from all levels of employees. Employee participation is encouraged through the traditional forums of employee/supervisor dialogue, engineering, environmental and safety. The key ingredients to employee participation and consultation is involving employees knowledgeable in the unit operations and operating and maintenance practices in Process Hazards Analy ses (PHAs) and the development of needed changes in procedures and practices. Meetings of Operations, Maintenance, and Safety personnel promote involvement. Safety meetings, department communications, operator participation in PHAs of operating units, pre-startup/shutdown reviews, training classes, operator involvement in training, operating procedure review/development, maintenance involvement, procedure development, review and updates are all examples of employee participation. Additionally, employee involvement in incident investigation is needed to ensure that fact finding is complete, as these employees will normally be familiar with the process or area being investigated. Employees are consulted and participation is encouraged in PSM and in the RMP. 2. Process Safety Information In accordance with Section 68.65 of the RMP rule, we systematically control the creation, updating, and retention of written documentation associated with our process chemicals, process technology, an d process equipment. This information is essential for supporting all of the other elements of our risk management program. We also use this information to ensure that our equipment is suitable for its intended use. We maintain the following chemical process information for each regulated substance in a covered process as well as for other hazardous materials in both covered and noncovered processes: * Toxicity information * Permissible exposure limits * Physical data * Reactivity data * Corrosivity data * Thermal and chemical stability data * Hazardous effects of inadvertent mixing of different materials that could foreseeably occur We use material safety data sheets (MSDSs) to provide most of the process chemical information. Whenever required information, such as corrosivity data or hazardous effects of inadvertent mixing, is not available in MSDSs, we develop the missing data from other sources and provide it in separate documents. We maintain the following required process tec hnology information: * Block flow or simplified process flow diagrams (PFDs) * Process chemistry * Maximum intended inventory * Safe upper and lower limits for parameters such as temperature, pressure, flow, or composition * Evaluation of the consequences of deviations from established operating limits Most of this information comes from the engineering design documents for the processes, but in some cases, we have developed such information through special projects. Additionally, operating limits, maximum intended inventories, and consequences of deviations not available from engineering design documentation were developed as part of PHAs. We also maintain the following information pertaining to equipment in our regulated processes (as well as for many of our nonregulated processes): * Materials of construction * Piping and instrument diagrams (P&IDs) * Electrical classification information * Relief system design and design basis * Ventilation system design * Design codes and sta ndards employed * Material and energy balances for processes built after 5/26/1992 * Safety systems (interlocks, detection, or suppression systems) Other information contained in the PSI are process descriptions, PFDs and process safety information cards that are widely used throughout the refinery to inform all personnel of the location of equipment, fire systems, escape routes, means of communication and the chemicals found in the area. Again, most of this information comes from the engineering design documents for the processes as well as from our own maintenance files. Whenever required information was not available, we obtained the information from equipment vendors, process designers, plant engineering, and/or research and development departments. In conjunction with our equipment information collection efforts, we document that our equipment complies with recognized and generally accepted good engineering practices. For our older processes, where design information is obsol ete, our Engineering Department evaluated the existing design against appropriate safety criteria and documented that the equipment is designed, maintained, inspected, tested, and operated in a safe manner. 3. Process Hazard Analysis In accordance with Section 68.67 of the RMP rule, we use Process Hazards Analyses (PHAs) to systematically identify, evaluate, and control process hazards. The most important results of our PHAs are findings that address the reduction of risks associated with accidental chemical releases. We ensure that all findings from our PHAs are resolved appropriately, and we ensure that information from our PHAs is communicated to all potentially affected employees. We conduct systematic PHAs of our regulated processes and other hazardous processes at our facility according to an established schedule. Each PHA is updated/revalidated at least every five years (or more often if necessary because of process changes). We also conduct PHAs of all new processes before those processes are placed in service. We primarily use the HAZOP or What if/checklist techniques to perform PHAs, although we use other EPA-/OSHA-approved techniques when they are more appropriate for specific applications. The following are some of the items addressed in a PHA: * Hazards of the process * Identification of any previous incident that had a potential for catastrophic consequences * Engineering and administrative controls applicable to the hazards and their interrelationships * Consequences of failure of engineering and administrative controls * Stationary source (facility) siting * Human factors * Qualitative evaluation of a range of the possible safety and health effects of failure of controls Our PHA teams are composed of personnel with engineering and process operating experience, including at least one person who has knowledge and experience in the process to be evaluated and a PHA team leader trained in the application of the hazard evaluation technique used fo r the PHA. We have a computer program, developed by Sunoco, to promptly resolve PHA team findings, and we communicate findings and resolutions to potentially affected personnel. PHAs are implemented in a written report for each analysis soon after the analysis meetings are completed. The PSM department, operating personnel and process engineering review and resolve the PHA findings after receiving the report. We maintain a written action plan tracking the resolution status of each finding, including an individual responsible for resolving each finding and a target completion date. We document the final resolution of each finding and communicate this information to the appropriate personnel. 4. Operating Procedures In accordance with Section 68.69 of the RMP rule, we use operating procedures to define how process-related job tasks assigned to our personnel should be performed to avoid incidents. We use these procedures to (1) train our employees/contractors before they perform task s in the field, (2) serve as reference guides for personnel performing tasks, (3) specify what to do if a process upset or operating emergency occurs and (4) provide reference guides in the startup and shutdown of equipment Our process engineers, operators, and shift supervisors work together to develop and maintain our operating procedures for all phases of operations including: * Initial startup * Normal operations * Temporary operations * Emergency shutdown, including the conditions under which emergency shutdown is required and assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner * Emergency operations * Normal shutdown * Startup following a turnaround or after an emergency shutdown Our development teams use PSI, information from process designers/equipment manufacturers, and their own experience to create and validate the procedures. Our procedures address the following information: * Steps for safely conducting activities * Safe operating limits * Consequences of process deviations, as well as steps required to correct or avoid such deviations * Safety and health considerations including; - properties of, and hazards presented by, the chemicals used in the process - precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment - control measures to be taken if physical contact or airborne exposure occurs - quality control for raw materials and control of regulated substance inventory levels - any special or unique hazards * Safety systems and their functions In addition to our process-specific procedures, we also develop and maintain more widely applicable safe work practices addressing issues such as lockout/tagout, confined space entry, opening process equipment or piping, and control of access to processes. These safe work practices apply to our employees and contractors. We have a form al review process to approve procedures and changes to procedures. Furthermore, we annually review existing procedures, make any needed revisions, and certify the procedures as current and accurate. We keep our procedures in locations that are readily accessible to employees who may need the procedures. The following outlines some of the details. * Development. Operating procedures are developed by knowledge and experienced operators and craftsmen, reviewed by crews and engineers, validated by experienced operators, and approved by supervision. The format is designed to be as easy as possible for the operators/craftsmen to use and to efficiently accomplish tasks safely and without incident. The procedures development employs the following steps: - The initial steps in the development of Operating Procedures is the compilation of operating and technical information and preparing a job inventory. This information is then discussed with a Technical Advisor (an operator) to confirm the tasks that are performed on the unit. A review by supervisory personnel is helpful in ensuring all work tasks have been covered. Regulatory research insures that applicable portions of current regulations are also taken into consideration. - The next step in the procedure development is the drafting of all the action steps that are necessary to accomplish a major task. Additional information, (safety regulations, P&IDs, MSDS, technical information, etc) , is provided to supplement the action step. This drafting can be done by either an experienced operator or by a developer. - In the final step the procedure draft is then sent to the field for review and comment. Any necessary changes are made and if significant differences exist, the procedure drafts are circulated to gain consensus. Once a consensus is reached, the procedure drafts are formatted to include appropriate warnings, cautions and operating data. The newly formatted procedures are then put back into the review cycle. * Review. The Operating Procedures Technical Review process involves members of the procedure review team, usually the Area Superintendent or designee, a technical person (engineer), the procedure writer and any other appropriate personnel. - The review process is conducted with all team members present. - Once the procedure has been reviewed and the comments incorporated, it is ready for approval and distribution to the field for use. * Responsibility. The trainer maintains the Operating Procedures implementation, management and control plan. The operating supervisor is responsible for assuring that operating procedures are in place, kept current, utilized and annually certified as accurate. * Operating Procedure Management of Change (MOC). Any change(s) to an existing operating procedure is considered MOC and employees involved in operating the process must be informed of, and receives training in, the change(s). * Procedure Certification. Management will certify annually that the procedures are current and accurate. 5. Training In accordance with Section 68.71 of the RMP rule, we train our employees to safely perform their assigned tasks. Our training program includes initial training as well as periodic refresher training and training updates when major process/equipment changes are made. As part of our training, we include provisions for ensuring that employees understand the training (written tests, field demonstrations, etc.). Training is provided for all personnel responsible for operating the facility, in accordance with their duties and responsibilities. Training is addressed in the operating procedures, including any change in technology or facilities. We provide our operators with initial and refresher training, which includes a general overview of the process, properties of chemicals in the process, and safety and health hazards, as well as a detailed understanding of the process operating procedures and safe work practices. We provide in itial training to new hires or newly assigned employees before they are allowed to work independently as operators. The following are some of the training modules we provide to out employees. * Refinery Orientation - Fundamentals of Refining Program * Operator Apprenticeship * Operator Duty Station Training * On-The-Job Training (OJT) * Cross Training * Maintenance Training Program * Environmental, Safety, and Health Training (ES&H) * Operator Refresher Training * Pre Start-up Training (PSSR) * Management of Change Training (MOC) * Skill Enhancement Training Training is fully documented and employees are tested throughout the programs of instruction. Employees must pass written performance and situational (procedures) testing for each job responsibility. Classes devoted to skill enhancement, incident reduction, safety, environment, and health are provided. Five percent of total man-hours is devoted as a minimum to training each year. All training records are maintained in files on a computer-based data system. The Qualifications Policy for the Refinery outlines the training programs. Periodically, at least every three years, we provide our operators with refresher training that, depending on job classification, can include operating procedure training, equipment-specific training, and/or advanced (beyond HAZCOM) chemical-specific training. Our refresher training courses emphasize process overview information, safe work practices, operating procedures that are rarely used such as emergency shutdown, emergency operation and startup following an emergency shutdown, and any operating issues requested by the shift group. Our operators are consulted at safety meetings and their input is documented and considered when preparing training schedules. Some form of evaluation to verify that our training has been understood accompanies all training. We use a combination of physical demonstration of skills, oral reviews using a one-on-one format, and written tests. We revie w the information missed by an employee who does not pass all testing requirements, and we do not allow resumption of work until minimum testing requirements are met. All training is documented and includes the employee's name, date of training, and the means used to verify that the employee understood the training. 6. Contractor Safety Program In accordance with Section 68.87 of the RMP rule, we have a contractor screening procedure to help ensure that we hire and use only contractors who accomplish the desired job tasks without compromising the safety and health of our plant employees, the public, or the environment. Contractor safety procedures are coordinated and implemented by the Marcus Hook Refinery Contractor Representative. Contractor safety regulations are sent with all bid packages. These regulations are discussed at all pre-job meetings through the use of a checklist that the contractor signs upon completion of the meeting (copies are kept in the job file). The program also includes videos with exams that are shown to all contractor employees at the Process Center. Depending where the contractor worker will be working and what duties he/she will perform, he/she will be given the General Orientation Video and exam or a combination of videos and exams. Each contractor worker must successfully pass the exam(s). Annual refreshers for reviewing the videos and taking the exams are required. We select contractors based on prior site work history and on information that they are required to provide as part of the bid process. The bid information includes their current safety programs (i.e., safety organization, employee education and training, and accident prevention program) and their prior safety performance (i.e., OSHA injury rates, property loss experience, regulatory compliance history, and worker's compensation insurance experience). Bidders that do not provide all of the requested information, that do not have the desired skills, or that have an uns atisfactory safety record are dropped from further consideration. If a contractor currently working in our plant is under consideration, we review recent safety audits and contact our people on the job site to verify satisfactory job performance before we authorize the purchase order. We provide a safety orientation for Contractor Supervisors before they begin work on site. (We require these Contractor Supervisors to provide this same safety orientation to their employees who will work in our plant.) We use the orientation meeting to familiarize contractors with the type of operations and associated hazards in the areas in which they will be working. We show a videotape that describes (1) the plant's hazardous chemicals, including toxic, fire/explosion, physical, and chemical properties, (2) safe work practices in use at our facility, and (3) actions they must take in the event of a plant emergency. We provide copies of our Contractor Safety Manual containing plant safety rules/poli cies, safe work practices, a material hazards summary, and an outline of emergency actions for contractors. We provide MSDSs for our hazardous materials that may affect the contractor work area, copies of plant safe work practices and policies, and emergency response actions associated with the contractor's work. We then take the Contractor Supervisors on a tour of the job site to point out the hazards we discussed in the meeting, introduce our personnel with whom they will communicate, identify break and restricted areas, note locations of any alarm boxes, and show where medical attention may be provided. We require our contractors to perform the following tasks to help ensure process safety: * Train each of their employees in the work practices necessary to safely perform the contracted work * Provide each of their employees with the same safety orientation that we provide for contractors and supervisors * Train each of their employees on our plant's safe work practices * Document that each of their employees has received and understands the training noted above * Ensure that each of their employees follows our plant safety rules and safe work practices * Report to our staff any hazards created or found by their employees at the job site * Provide access and responses to our personnel who may appear at the job site to evaluate contractor safety performance * Provide information on contract employee job site injuries/illnesses to our designated representative 7. Pre-Startup Safety Review In accordance with Section 68.77 of the RMP rule, we perform a pre-startup review as a final check to ensure the safety of a new or modified process before it is placed in service. The Management of Change process will dictate the need for a pre-startup safety review any time new facilities are installed, or existing facilities are modified. The review will be made by a safety review team, and all appropriate approvals obtained before placing new or modified equipment in s ervice. We perform pre-startup reviews on new stationary sources and on modified stationary sources when the modification is significant enough to require a change in the process safety information. Our pre-startup review is completed before regulated substances are brought into the process and only after we have confirmed that: * Construction and equipment are in accordance with design specifications * Safety, maintenance, operating, and emergency procedures are in place and are adequate * PHAs have been performed on new stationary sources and all recommendations have been resolved * MOC requirements have been satisfied for modified processes * Training has been completed (and documented) for affected employees We use a Pre-Startup Safety Review Checklist and Approval Form as an aid in documenting the performance of our pre-startup reviews. Our checklist contains a list of safety questions covering process considerations that must be addressed prior to startup. The person responsib le for the project or maintenance task prepares the Pre-Startup Safety Review Checklist and Approval Form and provides the names of the reviewer responsible for confirmation of each of the pre-startup review safety questions. Each reviewer signs off on the checklist and approval form when satisfied that all assigned safety questions are complete and no problems exist. All reviewers must sign off on the Pre-Startup Safety Review Checklist and Approval Form before startup can be authorized. 8. Mechanical Integrity In accordance with Section 68.73 of the RMP rule, we maintain the mechanical integrity (MI) of our process equipment using an inspection and testing program and a quality assurance program, and we ensure that our equipment is designed and installed correctly so that it operates properly. We train our maintenance personnel in the hazards of the process, and we also provide additional training on procedures for maintaining the ongoing integrity of our process equipment to ensu re that job tasks are performed safely. We consider all process-related equipment and safety systems that are critical for preventing and/or mitigating releases of regulated substances to be covered by our MI program. Examples include: * Pressure vessels and storage tanks * Piping systems including valves * Relief and vent systems and devices * Emergency shutdown systems * Controls such as monitoring devices, sensors, alarms, and interlocks * Pumps Our MI program uses equipment surveillance and preventive maintenance to identify equipment that is deteriorating and needs repair or replacement before failure occurs. This program also specifies the repairs (or parts replacement) needed to return deteriorated equipment to acceptable specifications. We maintain written procedures that support our MI program as follows: * Our plant operating procedures specify functional tests that operators must perform on specific equipment, as well as procedures to remove equipment from operation fo r maintenance or return equipment to service following maintenance. Also, temporary operating procedures exist for continuing safe operations when certain equipment deficiencies occur. * Our standard maintenance procedures describe the methods that mechanics use to perform repairs, replacements, and installations. * Our procedures for safe work practices and safety policies specify safe practices for performing maintenance tasks such as lockout/tagout, hot work, confined space entry, line or equipment opening, and control over entry/exit for a covered facility by plant and/or contract maintenance personnel. * Our inspection, test, and preventive maintenance procedures describe the methods used by mechanics to perform inspections, tests, and preventive maintenance tasks on process equipment. The procedures follow generally accepted good engineering practices. The equipment inspection and test frequency is based on mean time to failure estimates provided by the manufacturer, adjuste d by our own experience. We document all inspection, test, and preventive maintenance activities including: * Date of inspection, test, or preventive maintenance * Person performing the activity * Equipment identifier * Description of the activity performed * Results of the activity (including any deficiencies noted) We identify equipment deficiencies through our inspection, test, and preventive maintenance activities or from routine operating and maintenance tasks and correct them promptly. If we cannot immediately correct identified equipment deficiencies, we implement protective measures to ensure safe operation until repairs can be made. We have a quality assurance program that addresses new facilities, equipment, maintenance materials, and spare parts. Our program seeks to verify proper fabrication of new equipment, proper installation of new or repaired/replaced equipment, and use of suitable maintenance materials and spare parts in the preventive maintenance and repair task s. We have a comprehensive training program covering all MI issues. Our program uses the procedures described previously. For example, all mechanics, maintenance supervisors, and maintenance engineers are trained on hazards for all RMP-covered processes and on safe work practices. Our maintenance personnel also receive training on safe maintenance procedures, preventive maintenance practices, and special skills requiring craft certification. All training, as described above, occurs before employees perform tasks in RMP-covered areas. 9. Hot Work Permitting In accordance with Section 68.85 of the RMP rule, we use our hot work permit program to ensure that OSHA's fire prevention and protection precautions, specified in 29 CFR 1910.252(a), are in place before hot work (work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operation) begins on or near a process. Area must be made safe by removing flammable or combustible materials or protecting these materials from ignition sources. The Operations department has the responsibility for gas testing of the area (minimum O2/LEL) and the inspection of the area to ensure that the area is safe to work. The Operations department retains sole authority to issue hot work permits. The proper fire prevention and response equipment is provided for all hot work with a firewatch on site. 10. Management of Change In accordance with Section 68.75 of the RMP rule, we evaluate and approve all proposed changes (i.e., modifications that are not replacements in kind) to covered process chemicals, technology, equipment, and procedures prior to implementation through our management of change (MOC) program. This program helps ensure that inadvertent or unintended changes are prevented, that any safety and health impacts are addressed, that affected procedures are updated, and that our employees and contract employees are informed of and trained in the approved changes. We use this close scrutiny of all changes to help ensure that changes do not adversely impact employees, public safety, or the environment. The Marcus Hook Refinery Management of Change Procedure provides guidance, sets responsibilities, and establishes steps to implement Management of Change within the Marcus Hook Refinery. Specifically, this procedure guides employees to: * Determine if the proposed work is a change * Provide the purpose and justification (technical basis) for the change * Review the change through appropriate analysis for possible impact on the health and safety of employees and the community * Revise pertinent drawings and procedures that guide employees in the safe operation of the facility * Train affected personnel regarding the change * Verify that the appropriate reviews, document(s) revision, and training have been performed for the change * Document that all requirements of OSHA regulation 29 CFR 1910.119 are met for each change so audits may be conducted and compliance demonstrate d Our MOC procedure contains a step-by-step description of the confirmation process. It defines and provides examples of changes and replacements-in-kind. Also, it describes in detail the requirement for each confirmation step based on the type of change being considered. We use a Request for Change Review and Approval Form to document each step in the confirmation process. Changes that pass the confirmation criteria are communicated to our employees and contract employees who are affected by the change before the change is implemented. When approved changes require updates to our process safety information and/or operating procedures, we revise these documents and train employees on these changes before operations resume. All training is documented as formal operator training. 11. Incident Investigation In accordance with Section 68.81 of the RMP rule, we perform incident investigations to help ensure that incidents with catastrophic magnitude or potential are thoroughly investiga ted, root causes are identified and corrected, and relevant findings are communicated throughout our organization to help prevent a recurrence. The Marcus Hook Refinery instituted the "TOP" (triangle of prevention) program for incident investigation. The program was developed by OCAW as an effective method of identifying root causes of incidents, analyzing them and developing solutions to prevent them from recurring. A volunteer group of salaried and hourly employees investigates every incident, and the union is responsible for communicating the results of the investigation to all workers. The company and the union work together as a team to prevent future incidents. The Marcus Hook Refinery is guided by standards that: * Identify and investigate serious incidents or recordable injuries thoroughly to a consistent level, using the Root Cause Failure Analysis (RCFA) process. The RCFA process is a systematic investigative process for determining the root cause(s) of an event. Minor inc idents such as first aid cases do not involve RCFA or formal documentation. * Track and trend root causes to identify trends common to all investigations. * Share incident investigation reports with affected workers. We investigate all incidents (including near misses) that result in, or could reasonably have resulted in, a large uncontrolled release of a regulated substance, serious injuries to our employees or the public, and/or damage to the environment. We train our employees to identify occurrences requiring investigation and to notify the appropriate person should such an event occur. If the incident meets RMP-classification criteria, we initiate an investigation within 48 hours. We assemble a TOP investigation team consisting of: * Trained hourly and salary TOP investigators * A contract employee if the incident or near miss incident involved the work of a contractor or had acute, adverse health effects on contract employees * Others with appropriate knowledge and skills to thoroughly investigate and analyze the event We train our investigation team leaders in investigation techniques, including root cause analysis. The investigation team follows a written investigation protocol that addresses the key steps of fact finding, determination of cause, and development of recommendations/actions to be taken. From the raw data collected, the incident investigation team prepares the text for an incident summary report, which contains: * Date and time of the event * Date and time the investigation started * Description of the event * Identification of contributing factors * Recommendations from the investigation We resolve the report recommendations and develop action plans that are tracked to completion. We review the incident investigation report and action plan items with employees (and contract employees, as appropriate) who work in the affected area and/or perform job tasks relevant to the investigation findings. We accomplish this by monthly communication with all workers throughout the refinery. We retain incident reports for five years. 12. Emergency Response The Marcus Hook Refinery maintains an Emergency Response Team consisting of both hourly and salaried personnel for response to fires, rescues and environmental emergencies. The Team is primarily used in the Refinery, but can also respond to different Sun facilities, industries and municipal fire districts to provide mutual aid. The Supervisor of Fire and Emergency Response (Refinery Fire Chief) is the Team Manager and the response to all incidents / drills are managed using the Refinery Incident Command System. The Refinery maintains compliance with local, state and federal regulations including OSHA CFR 1910.120, Oil Pollution Act of 1990, Sara Title III and the Refinery Emergency Response Plan. The Emergency Response Team requires competency in the following: * Control and extinguishment of process unit, storage tank and related petrochemical hazard fires * Control and extinguishment of structural fires * Knowledge of foam operations and the ability to apply fire fighting foam * Deployment of spill boom and knowledge of spill containment and confinement * Mitigation of hazardous leaks utilizing protective equipment * Familiarity with boat handling and operations in the Delaware River * Rescuing injured people from a confined space or elevated tower * Basic first aid and CPR The full time members of the Emergency Response Department are certified Emergency Medical Technicians and respond to medical emergencies 24 hours a day and are responsible for emergency patient care of employees, visitors and contractors and coordinating medical transportation to the Refinery Medical Department or community hospitals. In order to accomplish the E.R.T. mission, members are trained in fire suppression, rescue techniques, spill and leak containment / control. This training is accomplished through instruction and hands-on practice. For purposes of fire control or suppression the members are trained in: * Interior Structural Fire fighting. The physical activity of fire suppression, rescue or both, inside buildings or enclosed structures which are involved in a fire situation beyond the incipient stage. * Advanced Exterior Fire Fighting. This involves efforts to advance on the fire to reduce its size and ultimately extinguish it. * Rescue. For purposes of rescue the members are trained in technical rescue scenarios including confined space (CFR 1910. 146) and rope rescue for high angle. * Leaks and spills. For purposes of leaks and spills members are trained according to 29 CFR 1910 Technician level and in operating other specialized equipment such as spill boom and boat handling. Training sessions are held on a monthly basis and are typically one half or one day in duration but can be extended to two or more days depending on the training subject. The majority of sessions are held in the Refinery and occasionally the training is done at an off-site area. In addition to the regular sessions, individuals or groups of members may periodically attend special advanced training that requires travel up to a week in duration. Additionally, the Emergency Medical Technicians train 16 hours each year to maintain proficiency and certification. The Refinery maintains a fleet of fire/rescue equipment, spill response apparatus, multiple fire pump installations and several hundred fire detection/suppression systems in a high state of readiness. 13. Auditing In accordance with Section 68.79 of the RMP rule, we audit our RMP-covered processes to be certain that our prevention programs are effective. Our compliance audit program seeks to confirm that RMP prevention program practices for the covered process are consistent with written programs, that the programs adequately address all requirements of the RMP regulations, and that management systems are in place to ensure continued compliance. We conduct and certify compliance audi ts of the prevention programs for RMP-covered processes at least every three years. We integrate these audits into PSM audits. Our audit teams consist of a team leader and an appropriate number of team members based on the size and complexity of the processes to be audited. The audit team collectively possesses the following skills and knowledge: * Ability to understand the prevention program requirements of the RMP regulation (49 CFR Part 68) * Capability to conduct interviews and collect audit data * Capability to document audit results * Knowledge of the processes to be audited Our audit team members receive training in RMP regulatory requirements, interview techniques, and methods for data collection before participating in an audit. We use a protocol that contains a series of questions that systematically address each requirement of the RMP regulation. The team leader assigns each auditor specific RMP elements to cover in the audit. Information obtained through field observation s, interviews, and document reviews is documented, and weaknesses or areas of noncompliance are identified. At the conclusion of the audit, our audit team prepares a report that identifies any specific noncompliance issues that need to be addressed. We have a plant management committee that promptly reviews the audit findings, determines an appropriate response for each finding, assigns responsibility for implementation of a corrective action, and assigns a target completion date. The corrective actions are placed in a tracking system and progress is monitored quarterly until open issues are resolved. We retain the two most recent audit reports. 14. Trade Secrets OSHA PSM requires the refinery to make available all information necessary to those persons responsible for compiling the process safety information, those assisting in the development of the process hazards analysis, those responsible for developing operating procedures, and those involved in incident investigations, emer gency planning and response, and compliance audits, without regard to possible trade secret status of such information. Generally, the need for trade secret agreements would apply only to non-company personnel (i.e. contractors, employee representatives, etc.) who are involved in the PSM elements. Company employees are generally covered by the confidentiality agreement, which they sign when they are hired. OSHA believes that employees are entitled to know process safety information even though it may contain trade secret information. The access procedures discussed in the Hazard Communication standard 29 CFR 1910.1200 discuss the conditions under which trade secret information should be made available. While these sections apply primarily to disclosing trade secret information to "health professionals", OSHA intends that the same principles apply to disclosure to Company employees and their representatives PLANNED CHANGES At the Marcus Hook Refinery, we believe that evaluation an d improving safety systems within the facility is a key element in reducing risk in the facility. The following improvements are examples of areas targeted for upgrades to further reduce risk in the plant: 1. Improvements to fire protection systems 2. Design and installation of additional gas and hydrocarbon detectors in key locations in the refinery 3. Installation of remote shutdowns and Remotely Operated Emergency Isolation Valves (ROEIVs) 4. Improvements to instrument and computer systems 5. Upgrade of heater safety systems The processes at the Marcus Hook Refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all processes at the refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be result from equipment failures and human errors. In addition to the accident prevention program activities, the refinery has safety feature s on many units to help contain/control a release, quickly detect a release, and reduce the consequences of (mitigate) a release. The following risk reduction and safety measures are used at the refinery: General: * Positive materials identification * PHAs on units and changes in the facility * TOP program for incident investigation * Engineering and construction in accordance with recognized industry standards * Substance abuse program/random drug testing * All process modifications reviewed for safety and health impacts * Redundant control systems with battery back-up * Monthly safety inspections in all plant areas * Extensive computerized monitoring and control of process operation * Quality Control Laboratory to ensure accurate unit operation * Regular safety meetings and extensive safety awareness * Program to manage effects of Engineering and Operational changes in refinery. * Contractor Safety Program * Joint Employee/Management Health and Safety Committee Material Release Pr evention Systems: * Equipment construction resistant to degradation from chemicals and process conditions * Equipment properly designed with protection from overpressure (relief valves, flare stacks, etc.) * Extensive system of automatic and manual shutdown devices for critical systems * Operating systems monitored and controlled 24 hrs by dedicated operator * Piping systems inspected and tested as part of Mechanical Integrity program * Frequent unit surveillance by operators * Routine inspection and testing of instruments, analyzers, and safety interlocks * Hydrotesting and dye testing of vessels and equipment on a periodic basis * Testing and inspection of all boilers by state inspectors on a regulated basis * Vehicular traffic prohibited from critical areas * Limited facility access and 24 hr security force * Extensive Preventative Maintenance program * Process safety information updated for accuracy Release Mitigation Systems: * High level shutoff valves * Dikes and curbing to m inimize spreading of released materials * Remotely operated shutoffs to limit release quantities * Manually operated valves to isolate leaks * Hydrocarbon and Toxic gas detectors at key areas to give early warning of leaks * Communication system for all groups * Advanced Emergency Response Teams specializing in fire control, rescue, HAZMAT and emergency medical treatment * Extensive Fire Protection System to provide high volume water supply * Automatic sprinkler systems and fixed fire monitors for fire control * Dedicated fleet of emergency response apparatus specially designed for industrial fire protection * Emergency drills with plant personnel, regulatory agencies, and community emergency responders to enhance response skills and coordination among agencies * Communication system with local emergency responders and regulatory agencies * Emergency Management System to manage and coordinate emergencies * Fire Detection Systems * Emergency Response Technicians on duty 24 hours per day * Strong mutual aid program with Local Fire Department * Participation with the Local Emergency Planning Committee (LEPC) * Onsite medical facility staffed with doctor and nurse * Annual emergency training for employees |