Sunoco Tulsa Refinery - Executive Summary |
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RMP EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION & EMERGENCY RESPONSE POLICIES The Sunoco Inc. (R&M) Tulsa Oklahoma Refinery, hereafter referred to as the Sunoco Tulsa 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 Tulsa Refinery, located in Tulsa, Oklahoma, operates a variety of processes to produce petroleum products (e.g. gasoline, fuel oil, propane, butane, lubricating oils, wax and coke) from raw crude oil. The refinery has several regulated flammables, such as propane, butane, etc. The refinery does not have any of the listed regulated toxic chemicals above the threshold quantity for reporting. The refinery covered processes are included in the RMP Program 3 criteria. HAZARD ASSESSMENT RESULTS The worst-case scenario (WCS) associated with a release of flammable substances in the covered processes at the refinery is a vapor cloud explosion (VCE) involving the largest storage tank containing normal butane (n-butane). This scenario would release 6,300,000 pounds of butane, assumed to release instantaneously, completely vaporize, and ignite, resulting in a VCE. This event would have off-site consequences from the explosion pressure wave. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this WCS. There are three alternate release scenarios (ARSs) considere d more credible for flammable releases. These scenarios are at different locations in our refinery and thus could affect different public areas. These ARSs are also for flammable substances at the refinery and are represented by a VCE resulting from the release of butane or propane. - A broken pipe at the base of a product butane sphere releasing a flammable mass of 6,920 pounds of butane. - A ruptured loading hose loading into a butane transport releasing a flammable mass of 6,990 pounds of butane. - A split pipe at the base of a process unit propane storage tank releasing a flammable mass of 8,020 pounds of propane. These events would have off-site consequences. These events are selected as being practical scenarios 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 Tulsa Refinery. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject to the OSHA Process Safety Management (PSM) standard, this summary addresses each applicable OSHA PSM element and describes the management system in place to implement the accident prevention program. EMPLOYEE PARTICIPATION The Sunoco Tulsa 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. Employees also form the Emergency Response Fire Brigade and Haz Mat teams for the refinery and receive a high level of training to maintain qualifications. Employees participate in our Joint Health, Safety and Environmental committee. Also, there is a voluntary Safety Environmental Rover program in which our employees provide their services performing various audits and enhancing their safety a wareness. Our process unit operators monitor their areas of responsibility and provide monthly reports on the status of various safety and emergency response equipment. PROCESS SAFETY INFORMATION The Sunoco Tulsa 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 (PSI). Each process unit has its specific PSI training material for the operating personnel. 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 conce rns and any known hazards associated with inadvertent mixing of chemicals. Each process area also has available all the equipment listed including what, if any, chemicals or hydrocarbons are present and a hazard rating based on the National Fire Protection Association system. For each process area, the refinery has documented safety-related limits for specific process parameters (e.g.; temperature, level, pressure) and studied hazard scenarios 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 construction 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 (PHA) The Sunoco Tulsa 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 Tulsa Refinery primarily uses the Hazard and Operability (HAZOP) analysis and What-If technique to perform these evaluations. HAZOP and What-If analysis are recognized as the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a multi-disciplined team with experience backgrounds across the organization. This team identifies and evaluates h azards 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 documented for local management. 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. Resolution of items can be categorized as Procedures, Repairs of Existing Equipment, Engineering Studies and Installing new equipment. 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 from the original design safety features, the Sunoco Tulsa Re finery 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. OPERATING PROCEDURES The Sunoco Tulsa 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 certified as current and accurate. The procedures are updated through a process cal led Management of Change (MOC). 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. CONTRACTORS The Sunoco Tulsa 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. Our contractor safety program is accomplished by providing contractors with an initial orientation meeting which provides: (1) site specific hazards by using Point of Work (POW) Card s, (2) information about general safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the Sunoco Tulsa Refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance and perform various audits to ensure that contractors are fulfilling their safety obligations. A weekly Contractor Safety meeting is held with representatives of our contractors. Contractors participate by presenting topics and the minutes are distributed to all attendees. PRE-STARTUP SAFETY REVIEW (PSSR) The Sunoco Tulsa 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 safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This r eview provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. A PSSR involves field verification of the construction and serves a quality assurance function by verifying that accident prevention program requirements are properly implemented. MECHANICAL INTEGRITY The Sunoco Tulsa 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 facility Mechanical Integrity Program includes: (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 equipment 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, 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) for equipment containing alloy materials. The Sunoco Tulsa Refinery incorporates PMI measures into equipm ent 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. TRAINING To complement the operating procedures, the Sunoco Tulsa Refinery has a comprehensive training program for all employees involved in operating a process. New employees are required to complete a thorough training program. This program includes (1) formal in-unit training, (2) classroom training, (3) on the job training, (4) self-study training, and (5) testing. The program could take up to 36 months to complete depending on the experience level of hired employees. Personnel with experience in the refinery or related industry may receive credit towards the completion of the training program. During the training program, each trainee must successfully complete all facets of the program which include; (1) basic refinery training, (2) off the job related studies, (3) job specific training, (4) testing ( written & skill demonstration), and (5) qualifying on a set number of jobs at the assigned unit. Each trainee must attend all required safety training, and meet minimum requirements in supervisory evaluations every six months to remain employed. After successfully completing the trainee 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 in accordance with OSHA 29 CFR 1910.119. 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 Tulsa 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 sources 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 (MOC) The Sunoco Tulsa Refinery has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemical technology (including process operating conditions), procedures and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) en sure that adequate controls are in place to manage any new hazards and (2) verify that existing controls 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. Any change which has a potential impact on quantities of new or existing toxic or flammable hydrocarbons must be review by the RMP Coordinator. Documentation of employee training on the change is covered under PSSR. INCIDENT INVESTIGATION The Sunoco Tulsa Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and to develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team is led by an experienced supervisor or technical representative, and includes other required technical support and those employees responsible for the work in the area of the incident. The incident 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 of 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 PHA revalidations. COMPLIANCE AUDITS To help ensure that the accident prevention program is functioning properly, the Sunoco Tulsa Refinery periodically hosts a Sunoco Audit Team to determine whether the procedures and practices required by the accident prevention program are being imp lemented. 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 Tulsa 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 r elease. The following risk reduction and safety measures are used at the refinery: GENERAL: - Engineering and 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 plant areas. - Monthly refresher 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 Employee/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 unit surveillance by operators. - Routine inspection & testing of instruments, analyzers, & safety interlocks. - Hydrotesting & dye testing of 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 loading hoses tested every six months. - Extensive Preventative Maintenance program. - Piping & Instrumentation diagrams updated for accuracy. RELEASE MITIGATION: - 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 4. Emergency Medical Service - Extensive Fire Protection System to provide high volume water supply anywhere in the refinery. - 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 Tulsa Fire Department. - Partici pation with Tulsa's Local Emergency Planning Committee (LEPC). - Onsite medical facility staffed with doctor and nurse. - Annual emergency training for employees. FIVE YEAR ACCIDENT HISTORY In accordance with the RMP rule, an accidental release is defined as one associated with an EPA listed chemical that resulted in death, injuries, significant property damage, evacuations, shelter in place, or environmental damage. The Sunoco Tulsa Refinery has had one (1) RMP reportable accident in the last five years. An incident occurred on April 25, 1999 at our Coker Unit during startup activities. A process tower had an internal explosion and resulted in a fire. One Sunoco employee received a recordable injury as a consequence of the blast shock. There was no exposure to the public of any hazardous material. There was no outside residential damage attributed to this event. There was no damage to the environment. The fire was contained by the Sunoco Emergency Response Brigade, but the Tulsa Fire Department responded to our site on their own initiative. They provided seconday damage assessment at the incident location. In addition EMSA, Tulsa Police and Tulsa County Sheriff Department also responded on their own initiative on standby service. The Sunoco Tulsa Refinery does not have any reportable "toxic" chemicals in quantities that meet the threshold criteria in the RMP rule. Some of the community may recall an incident in 1988 at our refinery where a small amount of toxic HF Acid vapors were released and drifted into an area adjacent to the refinery. However, in 1992 the refinery was reconfigured and the process which contained HF Acid was taken out of service. EMERGENCY RESPONSE PROGRAM INFORMATION The Sunoco Tulsa 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 th e 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 Tulsa 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 respons e program for the Sunoco Tulsa Refinery is coordinated with the Tulsa County - Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency officials, local government officials, and industry representatives. The Sunoco Tulsa 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 Sunoco Tulsa 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. The Sunoco Tulsa Refinery maintains an in-house trained group for initial response for fires or emergencie s. PLANNED CHANGES TO IMPROVE SAFETY The Sunoco Tulsa Refinery resolves all significant findings from PHAs, some of which result in modifications to the process. The following types of changes are planned in future risk reduction projects: 1) Installation of additional hydrocarbon/H2S detectors in the refinery. 2) Improvements in heater safety systems 3) Improvement and enhancement of the fire protection system 4) Improvements in instrumentation systems. The Sunoco Tulsa Refinery is resolved to have a program of continued improvement for safety and risk reduction investments. For example, various new installations over the last five years (1994-1998) have resulted in spending about $2,300,000 for projects improving safety and fire protection. In addition, a significant expenditure to install some new vessels to improve reliability and reduce risk amounted to $1,600,000 spending in 1998, with additional spending and completion of this project extending into 1999. |