Sunoco MidAmerica Marketing and Refining - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
The Sunoco Inc. (R&M) MidAmerica Toledo, OH Refinery, hereafter referred to as as Sunoco MidAmerica Refinery, has a long-standing commitment to worker, contractor, and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Sunoco MidAmerica Refinery, located in Toledo, Ohio, operates a variety of processes to produce petroleum products (e.g. gasoline, fuel oil, propane, butane) from raw crude oil. The refinery has several regulated flammables, such as propane, butane, etc. The refiner
y does not have any of the listed regulated toxic chemicals above the threshold quantity for reporting.
HAZARD ASSESSMENT RESULTS
The worst-case scenario (WCS) associated with a release of flammable substances in Program 3 processes at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing normal butane (n-butane). No administrative controls are in place to limit the storage inventory in the tank; therefore: the full tank inventory of 8,300,000 lb is assumed to release, completely vaporize, and ignite, resulting in a VCE. This event would have off-site consequences. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for active or passive mitigation measures was taken into account in evaluating this WCS.
The alternative release scenario (ARS) for flammable substances at the refinery is a VCE resulting from the release of propane from a broken pipe fitting on a transfer p
ump at our propane pipeline transfer area (5,400 lb released over a four minute period). The release is expected to be isolated by operators within 4 minutes (active mitigation). This event would have off-site consequences. This event was selected as being a practical scenario for use in emergency planning and response.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program in place at the Sunoco MidAmerica Toledo Refinery. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.
The Sunoco MidAmerica Toledo Refinery encourages employees to participate in all elements of process safety management and accident prevention. Examples of employee participation include employees serving as
members on Process Hazards Analysis teams as well as incident investigation teams. Employees also serve as trainers and procedure writers in addition to serving as safety auditors. Employees also form the Emergency Response Fire Brigade and Hazardous Materials Teams for the refinery. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the refinery and addresses each accident prevention program element.
PROCESS SAFETY INFORMATION
The Sunoco MidAmerica Toledo Refinery keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the refinery are assigned responsibility for maintaining up-to-date process safety information. A
Process Safety Information directory summarizing the reference documents and their location is available in each control room within the refinery.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations are provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with inadvertent mixing of chemicals. For specific process areas, the refinery has documented safety-related limits for specific process parameters (e,g,, temperature , level, pressure) via the Process Hazards Analysis process. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems)
The refinery also maintains numerous technical documents that provide information about the design and c
onstruction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.
PROCESS HAZARDS ANALYSIS
The Sunoco MidAmerica Toledo Refinery has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.
The Sunoco MidAmerica Toledo Refinery primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thor
ough hazard evaluation techniques. The analyses are conducted using a multi-disciplined team with experience backgrounds across the organization. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.
The PHA team findings are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards do not eventually deviate significantly fr
om the original design safety features, the Sunoco MidAmerica Toledo Refinery periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.
The Sunoco MidAmerica Toledo Refinery maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually c
ertified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. These written operating procedures are readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks.
The Sunoco MidAmerica Toledo Refinery uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the refinery has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform refinery personnel of any hazards that they find during their work. This is accomplished by p
roviding contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the Sunoco MidAmerica Toledo Refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
PRE-STARTUP SAFETY REVIEWS (PSSRs)
The Sunoco MidAmerica Toledo Refinery conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the
equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting syst
ems are operationally ready. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
The Sunoco MidAmerica Toledo Refinery has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment.
Maintenance personnel receive training on (1) safety and health hazards, (2) applicable maintenance procedures, (3) emergency response plans, and (4) applicable
safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or key personnel will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.
Another integral part of the mechanical integrity program is positive material identification (PMI). The Sunoco MidAmerica Toledo Refinery incorporates PMI measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used
when repairs are made.
To complement the operating procedures, the Sunoco MidAmerica Toledo Refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees are required to complete a 36 month Apprenticeship Training Program. This program has been certified by the United States Department of Labor and the State of Ohio Bureau of Apprenticeship and Training. This program includes (1) formal in-unit training, (2) classroom training, (3) on the job training, (4) self study training, and (5) testing.
During the three year apprenticeship, each apprentice must successfully complete all
facets of the program which include: (1) basic industry training, (2) off the job related studies, (3) training, (4) testing (written & skill demonstration), (5) qualifying on a set number of jobs at the assigned unit, and (6) obtain a State of Ohio Stationary Engineers License. Each apprentice must record their work hours on different t
ypes of refinery equipment, attend all required safety training, and meet minimum requirements in supervisory evaluations every six months to remain employed. After successfully completing the apprenticeship program, the employee will have adequate knowledge to perform the duties of the assigned jobs at the assigned process unit within the refinery.
In addition, all operators are recertified every three years. This recertification process includes (1) any necessary refresher training, (2) written testing, and (3) skill demonstrations. Operators must recertify on all jobs on which they are qualified at their assigned process unit. All training and testing is documented for each individual operator.
SAFE WORK PRACTICES
The Sunoco MidAmerica Toledo Refinery has long-standing safe work practices in place to help ensure worker and process safety. Examples include (1) control of entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sou
rces for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
MANAGEMENT OF CHANGE
The Sunoco MidAmerica Toledo Refinery has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals technology (including process operating conditions), procedures and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing contro
ls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. Documentation of employee training on the change is covered under PSSR.
The Sunoco MidAmerica Toledo Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to refinery management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution o
f each finding or recommendation is documented, and the investigation results are reviewed with all employees who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that reports can be reviewed during future PHAs and PHA revalidations.
To help ensure that the accident prevention program is functioning properly, the Sunoco MidAmerica Toledo Refinery periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three years. The audit team develops findings that are forwarded to refinery management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
SPECIFIC PREVENTION STEPS
The processes at the Sunoco MidAmeric
a Toledo 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 caused by (1) equipment failures and (2) human errors.
In addition to the accident prevention program activities, the refinery has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following risk reduction and safety
measures are used at the refinery:
* Engineering & construction in accordance with recognized industry standards. * Substance abuse program/random drug testing.
* All process modifications reviewed for safety & health impacts.
* Redundant control systems with battery back-up.
* Monthly safety inspections in all pla
* Computer based training programs.
* Extensive computerized monitoring & 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 & Operational changes in refinery.
* Contractor Safety Program.
* Joint Union/Management Health & Safety Committee.
MATERIAL RELEASE PREVENTION:
* Equipment construction resistant to degradation from chemicals & process conditions.
* Equipment properly designed with protection from overpressure (relief valves, flare stacks, etc.).
* Extensive system of automatic & manual shutdown devices for critical systems.
* Operating systems monitored & controlled 24 hrs by dedicated operator.
* Piping systems inspected & tested as part of Mechanical Integrity program.
* Frequent operator inspections.
* Routine inspection & testing of instruments, analyzers,& safety interlocks.
* Hydrotesting & dye testing o
f vessels & equipment on a periodic basis.
* Testing & inspection of all boilers by state inspectors on a regulated basis.
* Vehicular traffic prohibited from critical areas.
* Limited facility access/24 hr security force.
* Liquid Petroleum Gas hoses tested every six months.
* Extensive Preventative Maintenance program.
* Piping & Instrumentation diagrams updated for accuracy.
* Dikes and curbing to minimize spreading of released material.
* Remotely operated shutoffs to limit release quantity.
* Manually operated valves to isolate leaks.
* Hydrocarbon & Toxic gas detectors at key areas to give early warning of leaks.
* Communication system for all groups.
* Advanced Emergency Response Teams specializing in:
1. Fire Control and Extinguishment
2. Advanced Technical Rescue
3. Hazardous Materials Control
* Extensive Fire Protection Systems provide high volume water supply
anywhere in the refinery.
* Automatic sprinkler system
s 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
* Communication system with local emergency responders and regulatory
* Emergency Management System to manage and coordinate emergencies.
* Strong mutual aid program with Oregon Fire Dept. and BP Refinery.
* Participation with the Lucas County Emergency Planning Committee (LEPC)
in a leadership role.
* Sophisticated dispersion modeling capabilities at the facility.
* Onsite medical facility staffed with doctor and nurse.
* Annual emergency training for employees.
FIVE YEAR ACCIDENT HISTORY
The Sunoco MidAmerica Toledo Refinery has had two RMP reportable accidents in the last five years. On November 9,1996 a release of propane from a failed relief valv
e on a railroad tankcar had off-site consequences. Fifty persons from an adjacent neighborhood were evacuated from their homes for seven hours as a precautionary measure while the contents of the car were safely removed. On September 3,1998 a release of butane from an underground pipeline in our tank farm had off-site consequences. 450 students from adjacent Coy Elementary School were sent home early as a precautionary measure until the leak could be secured. We investigate incidents very carefully to determine ways to prevent similar incidents from occurring.
EMERGENCY RESPONSE PROGRAM INFORMATION
The Sunoco MidAmerica Toledo Refinery maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all
aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, post-incident cleanup and decontamination requirements. In addition, the Sunoco MidAmerica Toledo Refinery has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to refinery processes or other refinery facilities. Affected personnel are trained on the changes to the emergency response program.
The overall emergency response program for the Sunoco MidAmerica Toledo Refinery is coordinated with the Lucas County (State of Ohio)
Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which include local emergency officials, local government officials, and industry representatives. The Toledo Refinery has around the clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire departments). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Toledo Refinery conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.
PLANNED CHANGES TO IMPROVE SAFETY
The Sunoco MidAmerica Toledo Refinery resolves all priority 1 and priority 2 findings from PHAs, some of which result in modifications to the process. The follow
ing types of changes are planned:
1) Installation of additional hydrocarbon/H2S detectors throughout the refinery.
2) Improvements in heater safety systems.
3) Improvement and enhancement of the fire protection system.
4) Revisions to Operating Procedures to reflect changes to the process.