Sinclair Wyoming Refinery - Executive Summary |
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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/illnesses can be prevented. Prevention of all on-the-job injuries/illnesses is a realistic goal. No task shall be undertaken until adequate safeguards have been provided to protect every involved employee from injury due to recognized hazards. Where it is not reasonable or practical to el iminate 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 this policy will result in disciplinary action up to and in cluding 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 by May 1997. Sinclair Oil Corporation will update the Safety Management Program every five years thereafter. Emphasis will be placed on managing the higher risk areas of our facilities first, the priority of which will be established by each facility team. Statement of the Sinclair Wyoming Refinery. The Management of the Sinclair Wyoming Refinery 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. Definition of Processes and Regulated Substances The Sinclair Wyoming Refinery includes modern process units typically used for production of petroleum fuels: atmospheric and vacuum distillation, hydrotreating, reforming, fluidized catalytic cracking, alkylation, and associated supporting operati ons such as crude unloading, sulfur recovery, blending, storage and product loading. The NAICS code for the Sinclair Wyoming Refinery is 32411 and must meet the requirements of RMP Program Level 3. The Risk Management Plan (RMP) rule defines a process as "Any activity involving a regulated substance, including any use, storage, manufacturing, handling, or on-site movement of such substances, or combination of these activities. For the purposes of this definition, any group of vessels that are interconnected, or separate vessels that are located such that a regulated substance could be involved in a potential release, shall be considered a single process." (re: 40 CFR 68.3) Per the RMP definition, the Sinclair Wyoming Refinery has the following RMP regulated flammables in its processes: Pentane Butane Isobutane Propane Ethane Methane The Sinclair Wyoming Refinery also has the following regulated toxins in its Processes: Hydrogen Sulfide (H2S) Chlorine (Cl2) Sulfur Dioxide (S02) Of th e above substances, only pentane, butane, and propane meet the RMP threshold quantity level for flammables. Only chlorine meets the RMP threshold quantity level for toxics. Based upon threshold quantities and process definition, the Sinclair Wyoming Refinery is reporting the following three processes in its RMP: C4 Mixture: This represents a butane/butene mix in storage. The maximum quantity of C4 Mixture onsite at any time is estimated to be 26,000,000 pounds. This estimate is based upon the total storage capacity of C4 Mixture with an allowance for piping and material in process. Propane: This represents propane in storage. The maximum quantity of propane onsite at any time is estimated to be 1,300,000 pounds. This estimate is based upon the total storage capacity of propane with an allowance for piping and material in process. Chlorine: Chlorine is used for cooling tower water and for Municipal/Refinery water treatment. Ch lorine is fed to this process from 2000-pound bullet tanks. The maximum quantity of chlorine onsite at any one time is estimated to be 36,000 pounds. The Sinclair Wyoming Refinery has multiple processes, which contain H2S and SO2. The maximum quantity of H2S and SO2 on site does not exceed 10,000 pounds and 5,000 pounds, respectively. Therefore, these compounds do not meet RMP threshold levels. However, we do have prevention and safety programs in place for all H2S-handling units as part of our Process Safety Management Program. Hazard Assessment Results Worst Case Scenario-Flammables: The worst-case scenario (WCS) associated with the flammable substances is a vapor cloud explosion (VCE) involving the full inventory of the largest tank containing C4 Mixture. Tank 668 has a capacity of 30,000 bbls and is also the closest tank to an offsite receptor. For the WCS, the full tank inventory of 6,000,000 pounds is assumed to release, completely vaporize and ignite, resulting in a VC E. The maximum distance to the 1-psi endpoint for this WCS is 1.5 miles (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. It is important to note the WCS is based upon the simultaneous occurrence of several highly unlikely events, therefore the probability of the WCS actually occurring is extremely low. Alternative Release Scenario-Flammables: The alternative release scenario (ARS) for flammable substances at the Sinclair Wyoming Refinery is based upon the failure of a flexible hose used to load butane into tank trucks. For this scenario, the quantity of butane released was based upon the maximum pump capacity of 305 gpm over a 60-minute interval or 92,000 lbs. As with the WCS, we assumed all liquid would vaporize and ignite resulting in a VCE. The distance to the 1-psi endpoint for this event is 0.2 mile (as calculated by RMP*Comp.). Worst Case Scenario-Toxics: There are two WCS associated with toxic substances at this facility. WCS-1 is a release of chlorine from a chlorine bullet tank at the refinery. WCS-2 is a release of chlorine from a chlorine bullet tank at the River Pump Station. For both WCS, a full bullet tank inventory of 2,000 pounds is assumed to release within 10 minutes. The maximum distance to the toxic endpoint for this WCS is 3.0 miles (as calculated by RMP*Comp). It is important to note the WCS is based upon highly unlikely events, therefore the probability of the WCS actually occurring is extremely low. Alternative Release Scenario-Toxics: There are two ARS for toxic substances at this facility. ARS-1and ARS-2 are based upon the mechanical failure of a thermal plug which is located in the dished-head of the chlorine bullet tank. For these scenario, the release rate of chlorine is based upon the maximum flowrate through the thermal plug orifice. For modeling purposes, this flowrate was maint ained until the bullet tank was emptied. The maximum distance to the toxic endpoint for both ARS-1 and ARS-2 is 1.0 miles (as calculated by DEGADIS). 5-Year Accident History The Sinclair Wyoming Refinery has not had any RMP-defined accidents. While releases have been documented, none have been of 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 Wyoming Refinery. For the RMP Processes being reported by Sinclair, 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 Training Contractors Pre-Startup Safety Reviews (PSSR's) Mechanical Integrity Safe Work Practices Management of Change Incident Investigation Compliance Audits Employee Participation The Sinclair Wyoming 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 Wyoming 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 analysi s 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 Wyoming 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 onsite in each control room. Chemical Specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in Material Safety Data Sheets (MSDS's). 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 Wyoming Refinery had documented safety-related limits for specific parameters (e.g. temperature, pressure, level, and flow) used in monitoring and controlling operations. The Sinclair Wyoming Refinery ensures that the process is maintained within these parameters using process controls and monitoring instruments, highly trained personnel, and protective instr ument systems. The Sinclair Wyoming 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 Wyoming 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 Wyoming 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 Wyoming Refinery conducts a Process Hazard 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 trac ked 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 significantly from the original design safety features, the Sinclair Wyoming Refinery updates and revalidated 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. Operating Procedures The Sinclair Wyoming Refinery maintains written procedures for all operations functions at the refinery. The procedures address various modes of unit operation, including: Pre-Startup Unit Startup Normal Operations and P rocess Control Temporary or Special Operating Procedures Emergency Shutdown Normal Shutdown Additional Information present with the operating procedures includes 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. These 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. Training The Sinclair Wyoming Refinery complements the written operating p rocedures 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 t raining 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 though the certifications 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 Wyoming 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 The Sinclair Wyoming Refinery conducts a PSSR for any new facility or facility modification that requires a cha nge 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. Mechanical Integrity The Sinclair Wyoming 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. T he 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 form a system that maintains the mechanical integrity of the process equipment. Sinclair 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 iden tified, employees will correct the deficiency before placing the equipment back into service, if possible, or the 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. Sinclair also integrates quality assurance within its mechanical integrity program by ensuring all equipment purchases and repairs are 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. The Sinclair Wyoming Refinery'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 Wyoming Refinery has long standing safe work practices in place to help ensure worker and process safety. Examples of safe work practices include: Contr ol of the entry/presence/exit of support personnel on refinery property. A lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance. A procedure for safe removal of hazardous materials before process piping or equipment undergoing maintenance. A procedure for safe 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 Wyoming 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 b efore 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 updated to incorporate these changes. Operating and maintenance personnel are provided any necessary training on the change. Sinclair tracks all MOC changes and their details. The MOC's are stored in the Technical Manager's Office. Incident Investigation The Sinclair Wyoming Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted 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. Sinclair retains incident investigation reports for at least five (5) years so that the reports can be reviewed during future PHA's and PHA revalidation. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Sinclair Wyoming 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 management 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 Wyoming 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, Sinclair has safety features on many units to help contain/control releases, detect releases, and reduce the cons equences of a release. The following types of safety features are used in various process units: Release Detection Hydrocarbon detectors with alarms H2S detectors with alarms Release containment and control Process relief valves that discharge to a monitored flare 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 back-up systems) Atmospheric release valves Release Mitigation Fire suppression and extinguishing systems Deluge system for specific equipment Trained emergency response personnel (both refinery personnel and local emergency response personnel ) Personal protective equipment (e.g. protective clothing, a self-contained breathing, bunker gear, eye-wash systems, etc.) If a release does occur, these release prevention systems help Sinclair Wyoming Refinery contain and control the release in a way that minimizes the risk to personnel and the public in the best way possible. Emergency Response Program The Sinclair Wyoming 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 requ irements In addition, Sinclair 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, 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 refinery processes, changes in legal requirements, or 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 Wyoming Refinery is coordinated with the Local Emergency Planning Committee (LEPC). LEPC members include local emergency response officials, local government officials, and industry representatives. The Sinclair Wyoming Refinery has periodic meetings wit h the LEPC, and has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations, including the fire department. 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 Wyoming 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 refinery. To ensure that local emergency responders 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 Wyoming Refinery resolves all safety-related findings from PHA's and other safety issues, some of which result in modification 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. |