Sinclair Casper Refinery - Executive Summary
Accidental Release Prevention and Emergency Response Policies |
Sinclair Oil Corporation Safety and Health Policy
The Management of Sinclair Oil Corporation recognize and firmly believe in the need for a safe and healthful work place, free from recognized hazards that are likely to cause harm to its employees.
Therefore, it is the policy of Sinclair to conduct all of its activities in a safe, healthful, and workmanlike manner; to prevent injury or illness to persons; and prevent damage to property and equipment. Sinclair's policy is to establish on-the-job safety and health as a way of life and as a way of thinking, and to comply with all local, state, and federal laws regarding health, welfare, and safety of employees and the public.
All on-the-job injuries/illness can be prevented. Prevention of all on-the-job injuries/illness is a realistic goal.
No task shall be undertaken until adequate safeguards have been provided to protect every involved employee from injury due to recogni
zed hazards. Where it is not reasonable or practical to eliminate the sources of possible injury, measures must be taken to use safe procedures, guards, safety devices, and protective clothing. No matter what the exposure, an effective safeguard can be provided.
All employees have the responsibility for safety of themselves and others and must be aware of and follow established safety and health rules, regulations, or procedures.
The line organization has the responsibility for every operational activity of the company. Each first-line supervisor must accept the responsibility for the safety and health of their employees and must assure that no employee is given a job assignment without first determining that the employee can perform his or her duty under safe conditions.
Only when supervisors and employees, together, give safety the attention it must have to avoid injuries, on and off the job, can the future well being of Sinclair and its employees be assured.
Any violation of thi
s policy will result in disciplinary action up to and including termination.
President, Oil Division
March 17, 1997
Corporate Philosophy for Process Safety Management
Sinclair Oil Corporation will work proactively to provide a safe workplace for each employee and continue to promote safety practices among employees for their health and welfare. This will be accomplished at all facilities by actively assuring wide employee participation in a thorough Process Safety Management program and complete safety training.
The Process Safety Management program will be managed by a Corporate team, but completed on a facility basis under the specific direction of the facility manager. The program will conform to OSHA'' regulations contained in 29 CFR Part 1910.
Sinclair Oil Corporation has devoted the leadership, manpower, and capital investment necessary to complete the program. Sinclair Oil Corporation will update the Safety Management Program every five years. Emphasis is placed on managin
g the higher risk areas of our facilities first, the priority of which will be established by each facility team.
Statement of Sinclair Casper Refinery
The Management of the Sinclair Casper Refinery in Evansville, Wyoming recognizes and firmly believes in the need for a safe environment for both the refinery and the local community.
Our policy is to ensure that our efforts with prevention-through planning, training, reasonable process controls, timely maintenance, and communication with our neighbors-will help us prevent foreseeable releases of regulated substances. If a release does occur, however, our trained personnel, in conjunction with trained personnel from the community, will respond to control and contain the release.
Description of the Stationary Source and Regulated Substances
The Sinclair Casper Refinery operates a variety of processes in petroleum refining to produce products (gasoline, diesel, kerosene, asphalt, butane, and propane) from raw crude oil. Most of the p
rocesses use heat, catalyst, and pressure to produce the above products from the crude.
The Sinclair Casper Refinery has the following regulated flammables in its processes:
* Butane and isomers (C4)
* Propane (C3)
The Sinclair Casper Refinery also has the following regulated toxics in its processes:
* Hydrogen Sulfide (H2S)
* Sulfur Dioxide (SO2)
Of the above substances, only butane and its isomers, and propane meet the RMP threshold quantity levels.
By RMP definition, our entire facility falls under one RMP process. Our facility is a petroleum refinery under NAICS code 32411, and must meet the requirements of Program Level 3.
We are reporting the following two regulated chemicals in the RMPlan:
* Flammable Mixture (Mixed Butanes): This represents a butane/butene mix in storage. The maximum quantity of Flammable Mixture onsite is 5.9 million pounds.
* Propane. The maximum quantity of propane onsite is 2 million pounds.
H2S and SO2 in the Sinclair Casper Refinery do not meet t
hreshold levels. We have four units that process or remove H2S from the processes. Our total amount does not exceed the RMP threshold quantities for these substances; therefore, we do not trigger RMP. Prevention and safety programs are in place for all H2S-handling units as part of our Process Safety Management Program.
In the past, the Sinclair Casper Refinery used chlorine to treat water for its boilers and cooling towers. With the release modeling required under RMP, the Sinclair Casper Refinery determined that the potential impact of chlorine on the surrounding community was not necessary. Therefore, we replaced chlorine with an alternate, non-gaseous treatment system. This treatment system is more expensive to operate, yet we felt it was essential to remove chlorine in order to improve the safety of the community and minimize any toxic footprint from our facility.
Hazard Assessment Results
The Sinclair Casper Refinery has no toxic substance onsite that meets the threshold requ
irements for RMP coverage. We are subject to RMP only for flammable substances.
Worst Case Scenario. The worst-case scenario (WCS) was developed using the RMP-defined parameters, which may not accurately reflect properties of the substances or available mitigation controls. Because of the RMP definition of WCS, the following event is very unlikely to occur.
The WCS associated with the flammable substances is a vapor cloud explosion (VCE) involving the full inventory of the largest butane sphere (Tank 217) containing the Flammable Mixture. The tank can contain up to 9,700 barrels. Therefore, the full tank inventory is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is 1.0 mile (as calculated by RMP*Comp). Although we have numerous controls to prevent such releases and to manage their consequences, we took no credit for passive mitigation measures in evaluating the WCS.
Alternative Release Scenario. The a
lternative release scenario (ARS) for flammable substances at the Sinclair Casper Refinery is based on our largest historical release of an RMP flammable substance. It was a butane release resulting from a lineup error in transferring the gas to a truck. It is important to note that this release was successfully mitigated and no VCE occurred.
For purposes of the ARS, the amount released was 1,028 lb over 30 minutes. We assumed that the gas would stay around the tank and, with a perfect fuel-to-air mixture, be released in a VCE. The release is expected to be isolated by the operators within 30 minutes (active mitigation). The maximum distance to the 1-psi endpoint for this event is 0.10 mile (as calculated by RMP*Comp). The endpoint crossed the northeast boundary of the facility by approximately 300 feet and impacted only industrial land.
5-Year Accident History
The Sinclair Casper Refinery has not had any RMP-defined accidents. While releases have been documented, none have been o
f threshold substances, nor have these releases had offsite consequences. After each release, we investigated what happened, recorded the recommendations, and made changes to our processes, procedures, or safety systems to mitigate and eliminate future problems.
Accident Release Prevention Program and Chemical-Specific Prevention Steps
The following is a summary of the general accident prevention program in place at the Sinclair Casper Refinery. For the one RMP process being reported by the Sinclair Casper Refinery, encompassing the entire refinery, RMP allows us to use OSHA's PSM standard as our prevention program. This summary addresses each of the OSHA PSM elements that are part of the RMP, and describes the system in place to implement the accident prevention program.
The elements are as follows:
* Employee Participation
* Process Safety Information
* Process Hazard Analysis
* Operating Procedures
* Pre-Startup Safety Reviews (PSSRs)
* Mechanical Integr
* Safe Work Practices
* Management of Change
* Incident Investigation
* Compliance Audits
The Sinclair Casper Refinery encourages and invites employees to participate in every aspect of process safety management and accident prevention. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the Sinclair Casper Refinery and addresses each accident prevention program element.
Employees have access to all information that is part of the accident prevention program. Copies of information that is used daily is located in the unit operations buildings for quick access.
Examples of employee participation include participating in the HAZOP analysis of each unit, updating and compiling technical documents and chemical information for their unit area, and reviewing and being trained on any changes to operational or mechanical information that may affect them. Employees
are also participants on our teams that address both process and worker safety. Teams are often comprised of representatives from plant management, safety, operations, environmental, maintenance, and engineering.
Process Safety Information
The Sinclair Casper Refinery keeps technical and safety documentation for each unit that falls under the PSM standard. This information helps ensure and maintain safe operation for the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis and configuration information.
The Safety, Engineering, and Maintenance departments are assigned responsibility within the plant to keep the process safety information updated. A table summarizing the reference documents and their location is readily available as part of the file in the Technical Manager's office in the main building. Duplicate copies of critical information are included ons
ite in each control room.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is 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 the inadvertent mixing of chemicals. For specific process areas, the Sinclair Casper Refinery has documented safety-related limits for specific parameters (e.g., temperature, pressure, level, flow) used in monitoring and controlling operations. The Sinclair Casper Refinery ensures that the process is maintained within these parameters using process controls and monitoring instruments, highly trained personnel, and protective instrument systems.
The Sinclair Casper Refinery also maintains numerous technical documents that provide information about the design and construction of the 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. This information is stored with the Inspection and Testing department.
Process Hazard Analysis
The Sinclair Casper Refinery has a comprehensive analysis program to ensure that hazards associated with the various processes are identified and controlled. Each process unit is systematically examined to identify hazards and ensure that adequate controls are in place to manage those hazards.
The Sinclair Casper Refinery uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP is a very systematic and thorough evaluation of potential hazards in the process unit. The Sinclair Casper Refinery conducts a Process H
azard Analysis (PHA) with a team formed of knowledgeable, trained personnel from safety, maintenance, operations, environmental, engineering, and plant management. The team evaluates potential process hazards and identifies accident prevention and mitigation measures to ensure safe operating and maintenance of the units. The team makes recommendations about systems, procedures, or practices to put in place to ensure the hazards are managed and mitigated.
The PHA team findings are forwarded to local and corporate management for review and resolution. Implementation of systems, procedures, and practices are based on a determination of risk with the items. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The Technical Manager's office includes all information about the HAZOP analysis, team members, recommendations, and resolutions.
To ensure that the process controls and/or process hazards do not deviate significan
tly from the original design safety features, the Sinclair Casper Refinery updates and revalidates the hazard analysis results. The revalidation team consists of the same types of personnel that the initial HAZOP does. These periodic reviews are conducted at least every 5 years and will continue on that schedule until the unit is no longer operating or is removed. Revalidated hazard analysis results are tracked, submitted for management review, and retained and documented until they are complete.
The Sinclair Casper Refinery maintains written procedures for all operations functions at the refinery. The procedures address various modes of unit operation, including:
* Unit Startup
* Normal Operations and Process Control
* Temporary or Special Operating Procedures
* Emergency Shutdown
* Normal Shutdown
Additional information present with the operating procedures include a process description, a process chemistry description, an equipment description,
operator responsibilities, safety concerns, chemicals in the unit, and utility and auxiliary systems.
These procedures are used to train personnel in their responsibilities at the unit, to reference during operation of the unit, and to provide checklists necessary for unit operation. These procedures are periodically reviewed and certified 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.
Operating procedures are kept in the unit control rooms for each unit and are readily available to personnel to help them complete their tasks in a safe manner.
The Sinclair Casper Refinery complements the written operating procedures with a comprehensive training program. New employees receive initial training in refinery operations and safety practices. After successfully completing this training, the new operator or technician receives a manual that guides them to
an understanding of their responsibilities. Operators are given a manual that discusses the equipment, how it works, and what is involved in its operation. Drawings and graphics help the new operator picture the vessels and equipment in the unit. Maintenance personnel also receive guidance on their responsibilities under training by current maintenance personnel.
New operators are paired with senior operators to learn process-specific duties and tasks. All new operators are tested on what they have learned, both by study and by demonstration. When operators demonstrate adequate knowledge to perform the duties and tasks in a safe manner on their own, they are allowed to work independently.
All operators periodically receive refresher training in operations to ensure that their skills and knowledge are at a proper level. The refresher training is conducted at least every 3 years, and is documented for each operator. Maintenance personnel receive refresher training through the certif
ications required for inspection and testing. Personnel are required to take the necessary certification training and tests on the appropriate schedule to keep current.
The Sinclair Casper Refinery also trains personnel in safety, emergency response, and HAZOP. Safety and emergency response training takes place at least yearly, where local emergency response personnel from the local communities join our onsite emergency personnel for coordinated training. This training ensures that our local emergency response groups are familiar with our facility and get to know our people and our capabilities.
Pre-Startup Safety Reviews (PSSRs)
The Sinclair Casper 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 systems are operationally ready.
The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as quality assurance by requiring verification that the accident prevention program requirements are properly implemented. The completed and signed PSSR checklist is included in the PSM files.
The Sinclair Casper 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:
* Conducting training of maintenance personnel
* Developing written procedures
* Performing inspections and tests
* Correcting identified deficiencies
* Applying quality assurance measures
These activities for
m a system that maintains the mechanical integrity of the process equipment.
The Sinclair Casper Refinery uses current versions of the applicable API and ASME standards as the basis for setting acceptable limits.
Maintenance personnel receive training on an overview of the process, safety and health hazards, applicable maintenance procedures, emergency response plans, and applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures for testing and inspecting help ensure that the work is performed consistently and provides a basis for training.
Personnel perform inspections and tests to ensure that equipment functions as intended, and to verify that equipment is within acceptable limits. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service, if possible, or the Sinclair Casper Refinery's Management of Change team will review the use of the equipment and determine what
actions are necessary to ensure the safe operation of the equipment.
The Sinclair Casper Refinery also integrates quality assurance within its mechanical integrity program by ensuring all equipment purchases and repairs and up to code and per specification. 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.
Sinclair's inspection and testing personnel are certified to the proper standards and have current training certificates on file. Personnel are certified to API 510, 653, and 570 specifications.
Safe Work Practices
The Sinclair Casper Refinery has long-standing safe work practices in place to help ensure worker and process safety. Examples of safe work practices include:
* Control of the entry/presence/exit of support personnel on Sinclair Casper Refinery property
* A lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance
* A procedure for s
afe removal of hazardous materials before process piping or equipment is opened
* A permit and procedures to ensure that adequate precautions are in place before entry into a confined space
These procedures and others, along with training of all affected personnel, form a system to help ensure that our operations and maintenance activities are performed safely.
Management of Change (MOC)
The Sinclair Casper 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 ensure that adequate controls are in place to manage any new hazards, and to verify that existing controls have not been compromised by the change.
Affected chemical hazard information, process operating limits, equipment information, and procedures are up
dated to incorporate these changes. Operating and maintenance personnel are provided any necessary training on the change.
The Sinclair Casper Refinery tracks all MOC changes and their details. The MOCs are stored in the Technical Manager's Office.
The Sinclair Casper Refinery promptly investigates all incidents that resulted in, or reasonably could have result in, a fire or explosion, a 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 action taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation
is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings.
The Sinclair Casper Refinery retains incident investigation reports for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.
To help ensure that the accident prevention program is functioning properly, the Sinclair Casper Refinery periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented.
Sinclair Oil Corporation has chosen to conduct compliance audits at least every 3 years using a knowledgeable team formed of corporate personnel, staff from other Sinclair refineries, and contractors, as required. The audit team reviews documentation and records, inspects the site, and interviews personnel to determine compliance. The audit team then develops findings that are forwarded to the refinery managem
ent for resolution. The final resolution of each finding is tracked and documented, and the two most recent audits are retained onsite as part of the PSM file.
Chemical-Specific Prevention Steps
The processes at Sinclair Casper Refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized above is applied to our Program Level 3 RMP-covered process. The prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.
In addition to the accident prevention program, the Sinclair Casper Refinery has safety features on many units to help contain/control releases, detect releases, and reduce the consequences of a release. The following types of safety features are used in various process units:
* Hydrocarbon detectors with alarms
* H2S detectors with alarms
Release Containment and Control
* Process relief valves that discharge to a monitored f
lare system. The flares capture and incinerate episodic releases
* Valves to permit isolation of the process (manual and automated)
* Automated shutdown systems for specific process parameters (e.g., high or low temperature, levels, pressures, etc.)
* Alarms for specific process parameters
* Vessels to remove process inventory in the event or a release (tank storage, bypass systems)
* Concrete curbing to contain liquid releases to unit areas only
* Redundant instrumentation and equipment (spare and backup systems)
* Atmospheric relief valves
* Fire suppression and extinguishing systems
* Deluge system for specific equipment
* Trained emergency response personnel (both Sinclair Casper Refinery personnel and local emergency response personnel)
* Personal protective equipment (e.g., protective clothing, self-contained breathing, bunker gear, eye-wash systems, etc.)
If a release does occur, these release prevention systems help Sinclair Casper Refinery contain and con
trol the release in a way that minimizes the risk to personnel and the public in the best way possible.
Emergency Response Program
The Sinclair Casper Refinery maintains a written emergency response program 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
* Cleanup and decontamination requirements
In addition, the Sinclair Casper Refinery has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipmen
Employees receive, as part of their initial and ongoing refinery training, instructions and procedures for carrying out their specific emergency response duties.
The emergency response program is updated when necessary based on modifications made to Sinclair Casper Refinery processes, changes in legal requirements, or Sinclair Casper Refinery policy. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes.
The overall emergency response program for the Sinclair Casper Refinery is coordinated with the Natrona County Local Emergency Planning Committee (LEPC). LEPC members include local emergency response officials, local government officials, and industry representatives. The Sinclair Casper Refinery has periodic meetings with the LEPC, and has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations, including the fire depart
ment. 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 the periodic meetings, the Sinclair Casper Refinery conducts periodic emergency drills that involve the LEPC and emergency response organizations. We invite these organizations to train with us at our site to achieve a dual purpose:
* To provide annual refresher training to local emergency responders regarding the layout of the facility and the hazards of regulated substances in the Sinclair Casper Refinery.
* To ensure that local emergency responder get to meet and interact with Sinclair's personnel in addressing response actions.
The fulfillment of these purposes help us ensure we meet the requirements of the emergency response program and have a practiced and effective plan in place that has the full confidence of the LEPC and local emergency response groups.
Planned Changes to Improve Safety
The Sinclair Casper Refinery resol
ves all safety-related findings from PHAs and other safety issues, some of which result in modifications to processes. For each modification, changes will be made to procedures and processes to ensure that they match the new equipment or changes. All affected personnel will be trained prior to their operation of the equipment.