Puerto Rico Sun Oil Co. - Executive Summary |
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EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At the Yabucoa, Puerto Rico Refinery of Puerto Rico Sun Oil Company, A wholly owned subsidiary of SUNOCO Inc., we are committed to operate and maintain all of our processes in a safe and responsible manner to our employees, contractors, and the general public. We use a combination of resources including personnel training, consideration of safety in the design, installation, operation and maintenance of the different refinery processes. We have accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 7 A description of our facility and use of substances regulated by EPA's RMP regulation 7 A summary of results from our assessment of the potentia l offsite consequences from accidental chemical releases 7 An overview of our accidental release prevention programs 7 A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 7 An overview of our emergency response program 7 An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment 7 The certifications that EPA's RMP rule requires us to provide 7 The detailed information (called data elements) about our risk management program FACILITY DESCRIPTION, STATIONARY SOURCE, AND REGULATED SUBSTANCE PRSOC Refinery produces and distributes petroleum lubricants and distillate products from Reduced Crude and Crude Oil Feedstock's. The Refinery is located approximately two miles east of the municipality of Yabucoa, at State Road 901, kilometer 2.8, Camino Nuevo, Yabucoa, Puerto Rico. The Refinery occupies 252 acres of land in th e eastern most region of the municipality. The Refinery Manager is responsible for assuring that the Refinery is prepared to respond to an emergency. The PRSOC Refinery have an Environmental Quality Board CAA Permit #PFE-TV-2911-0397-0025. The PRSOC Refinery uses the following flammable chemical that has been identified as regulated under the EPA's RMP rule with the potential to cause offsite consequences in the event of an accidental release: Propane - Used for refrigeration purposes in the MEK Unit. It is also used as fuel in the Utilities Unit especially during start up and shutdown operations. We have two propane storage bullets, one located at the MEK Unit Area, which contains 121,000 Lbs. (full capacity) and the other propane storage bullet located at the Utilities Area, which contains 142,000 Lbs. (full capacity). No regulated toxic material is handled or stored in quantities above the threshold limit values established for reporting by the regulation. HAZARD ASSESSMENT PROGRAM The hazard assessment program of EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The EPA's Offsite Consequence Analysis (OCA) guideline was used for the calculation of the Worst Case Scenario (WCS) results. It is important to understand that this scenario is based on the regulatory guidelines and it is calculated using the EPA rules. The worst-case scenario associated with a release of a flammable substance in Program 3 processes at the Refinery, a vapor cloud explosion (VCE), follows: Worst-case Release Scenario - Regulated Flammable Chemicals A catastrophic rupture of the second largest propane vessel of the refinery occurs releasing the total content (121,000 Lbs.) of the flammable substance. This release forms a Vapor Cloud Explosion (VCE) involving the full inventory of the vessel. This event would have off-site consequences. The largest propane vess el was not considered as the worst case scenario because of its location within the Refinery. When the Offsite Consequence Analysis (OCA) was done for this vessel the results were within the extent of the second largest vessel's distance. Even though key administrative controls and mitigation measures available to limit the exposure distances were not considered in this analysis, it is important to mention them. We have mitigation measures such as: tank level control, sewer systems within the tank dike area, fire suppression systems at the intermediate tank area that can be used to reduced the amount of vapors from the area. Alternative Release Scenario - Regulated Flammable Chemicals A Line rupture of the Propane Make - Up line that runs from V-003-01 to V-023-11. These vessels are located between the MEK Intermediate tank area and the MEK Unit. A 15 minutes duration release, releasing 717 Lbs. of propane was simulated. The alternative release scenario, a Vapor Cloud Explosion (VCE), was simulated using a computer model program called PHAST (Process Hazard Analysis Software Tool). The event was selected on the basis of probability and past history and it was discussed with the Operating Specialist and the Operators. This event would have off-site consequences. Mitigation resources available are operator response, dikes, and fire suppression systems around the unit area (fire monitors) that can be use to reduced the amount of vapors. ACCIDENTAL RELEASE PREVENTION PROGRAM Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. We also take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems HES Best Practices, Process Safety Management and Personnel training programs address each of the key elements of successful prevent ion programs. HES Best Practices and OSHA PSM Standard There are various elements of the Health, Environmental and Safety (HES) Best Practices program that are directly related to the elements of the OSHA PSM standard. Employee Participation PRSOC Refinery employees are encouraged to participate in various activities that are directly related to a good hazard prevention program. Employees participate in the Plant Safety Committee, where items reviewed in this committee are the result of incident investigations, status of safety work orders (most of them created by them), and engineering requests, unit inspection minutes and any significant safety concern. They participate in the Process Hazards Analysis of the units in the Refinery giving their experience and expressing their view of the process being evaluated. They also participate in Incident investigations where root cause analyses are conducted and findings are developed to reduce or mitigate hazards that resulted from an incident. Process Safety Information Process Safety information is available to all employees at the different control room areas. Access to information related to the chemicals used in the Units, including a list of such chemicals, as well as the Material Safety Data Sheet (MSDS) for them are available. There is also information about the technology of the process, flow or block diagrams to show the process. Brief descriptions of the type of processes (i.e. Distillation, filtration, and extraction) are also available as well as inventory information and acceptable operating ranges. The Refinery also maintains process equipment information such as material of construction, design codes and standards, relief systems, electrical ratings etc. Process Hazards Analysis Process Hazards Analysis (PHA's) are conducted in each process unit including new projects by a selected group of people, to identify possible hazards and to address findings to reduce or eliminate such hazards. The group members are selected based on the process to be analyzed. Typically its composition is a Team Leader (with knowledge of the PHA's techniques), an operating representative (knowledge of the unit to be studied), a technical representative (engineering) and a maintenance representative. A systematic approach is used in order to conduct these studies. It can be a Checklist, a What If or a Hazard and Operability Study (HAZOP). Results of these studies are documented, and records of implementation and follow up are maintained. Operating Procedures PRSOC Refinery maintains procedures that address various modes of process operations, such as unit startup, normal operations, emergency shutdown, normal shutdown, and 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 certified as current and accurat e. The procedures are maintained by revising them as necessary to reflect changes made through the management of change process. These 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. Training There is a training program for all employees involved in operating a process. New employees are required to complete an Apprenticeship Training Program. This program includes classroom training, formal in-unit training, on the job training; self study training, written and hands-on tests. The program includes basic skills training, qualifying on a set number of jobs at the assigned unit. Each apprentice must work on different types of refinery equipment, attend required safety training, and meet minimum requirements in the evaluations. After successfully completing the apprenticeship program, the employee will have adequate knowledge to perform the duties of the assigned jobs a t the assigned process unit within the refinery. In addition, operators are re-certified every three years. This re-certification process includes any necessary refresher training, written testing, and skill demonstrations. Operators must re-certify on the jobs on which they are qualified at their assigned process unit. All training and testing is documented for each individual operator. Mechanical Integrity PRSOC Refinery has established policies and practices committing it to providing a safe workplace for its employees and to protecting the environment in its areas of operation. The primary goal of the Mechanical Integrity Program is to assure that all equipment and systems used to handle or process highly hazardous chemicals are designed, built, installed and maintained to control the risk of releases and other accidents. The program outlines the commitments of the Refinery to ensure that its workplaces are safe. This is done by defining the organization and controls, a nd the guidelines and procedures to be used by all personnel to protect the employees and the facilities. The program is intended to eliminate or mitigate the consequences of a release of toxic or hazardous chemicals. The refinery will continue to design, maintain, and operate its facilities, equipment and resources in a cost-effective manner, which recognizes that compliance with safety and environmental regulations is paramount. We are prepared to respond promptly and professionally should an incident occur. Management of Change PRSOC 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 ensure that adequate controls are in place to manage any new hazards and verify that existing controls have not been comp romised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. Pre-Startup Safety Review For any new facility or facility modification that requires a change in the process safety information a Pre-Start Up Safety Review is conducted. The purpose of the pre-start up safety review 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 support systems are operationally ready. A Pre-Startup Safety Review involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Compliance Audits Corporate compliance audit s are conducted at least every three years. This ensures that the Process Safety Program is being maintained as required. This is accomplished by conducting a formal evaluation and certification. The Refinery Process Safety Manager follows up on the programs on a regular basis to verify compliance of the elements of the PSM program. Incident Investigation The purpose of an Incident Reporting and Investigation procedure is to establish a consistent and effective system of internal reporting. It is also the means for investigation and follow up of all undesired events that resulted, or could have resulted, in physical harm to people, loss of production, or harm to the environment so that the potential for the recurrence of such events is minimized. An incident investigation committee that collects the facts and data of the incident that occurred conducts the incident investigation. This committee will then analyze the data to identify immediate and root causes. Based on t hese findings, appropriate actions will be taken to reduced or eliminate future incidents. These action items will be followed up to ensure proper implementation. Hot Work Permit PRSOC Refinery develops implements and maintains an effective system of safe work permit procedures, which shall include the requirements set forth in the different types of work in the refinery. The Hot Work permit is a written authorization to proceed with maintenance or construction activities after the review of the status and conditions of the equipment or area. The hazards of the equipment or area, and the procedures and or equipment, including personal protective equipment required to performed the work safely, are evaluated. Contractors PRSOC Refinery maintains a contractor safety program which includes initial contractor orientation, safety audits, safety reports, incident investigation and program compliance. The refinery employs contractors to supplement its work force during normal p eriods or periods of increased maintenance or construction activities. Contractor safety procedures are coordinated and implemented by the Refinery Contractor Representative. Evaluation of the Contractors safety record and training program is used in selecting the Contracting Company. The safety regulations require Contractors to train their employees in the safe work practices and safety rules of the refinery. Contractors are also required to report any safety hazards that the contract work may cause for the facility or any hazards found by the contract employees. SPECIFIC PREVENTION STEPS As part of our prevention efforts, we have implemented the following chemical-risk reduction and safety measures as specific prevention steps: General: 7 Engineering and construction in accordance with recognized industry and company standards 7 Equipment designed with pressure safety relief valves 7 Technical drawings, Piping & Instrument Diagrams and Process Flow Diagrams 7 Al l process modifications reviewed for safety & health impacts 7 Television surveillance capabilities 7 Redundant control systems 7 Inspection and testing of instruments, analyzers, and safety interlocks 7 Testing and inspection of all boilers by state inspectors Regular safety meetings and safety awareness programs 7 Employees/Management Health & Safety Committee 7 Computer based training programs 7 Scheduled safety inspections 7 Safety showers and eyewash stations 7 Self-contained breathing apparatus located in process units 7 Substance abuse program and random drug testing 7 On-site first aid medical facility Material Release Prevention 7 Operating systems monitored and controlled 24 hrs a day by trained Operators 7 Computerized monitoring and control of process operation 7 Daily checks of tanks and vessels level and operational status. 7 Automatic and manual shutdown devices for critical systems 7 Quality Control Laboratory to ensure accurate unit operation 7 Vehicular traffic control 7 Limited facility access. 7 Radio communication system Release Mitigation 7 Minimization of flammables and toxic chemical inventories 7 Dikes and curbing to minimize spreading of released material 7 Automatic and remotely operated shutoffs to limit release quantity 7 Strategically located valves to isolate leaks 7 Hydrocarbon and toxic gas detectors to warn of a chemical release 7 Water sprays to contain vapor clouds and cool high temperature equipment 7 Automated water sprays and fixed fire monitors for fire control 7 Chemical release dispersion modeling capabilities at the facility 7 Piping systems inspected & tested as part of Mechanical Integrity program. 7 Dedicated emergency response equipment specially designed for industrial fire protection. The specific prevention steps mentioned above work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business , and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility covered under EPA's RMP rule during the past five years. No significant incidents of the covered substances had occurred in the PRSOC Refinery during the past five years. EMERGENCY RESPONSE PROGRAM INFORMATION We maintain an integrated contingency plan, named "Emergency Plan" that consolidates various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. Our emergency response applies to all areas of the Refinery, including Oil Transfer, Marine and surround ing areas as specified by the Emergency Plan. This plan is designed to stand on its own. A corporate emergency plan defines expanded resources available within SUNOCO INC. The emergency plan is not designated to be a prescriptive document as each emergency incident is a unique event. The plan is designed to incorporate flexible emergency response, which addresses the needs of the emergency. The plan is supported by a set of Emergency Procedures. These emergency procedures call for enough qualified personnel in the Emergency Response Organization (ERO), to respond to an event and established a proper Incident Command System. The incident command system is well explained in the Emergency Response Plan. The Incident Commander (Refinery Manager) is responsible for assuring that the Refinery personnel are prepared to respond to an emergency. The Health, Environmental, and Safety Manager (Planning Officer) is responsible for development, maintenance, distribution, and training for the ERO personnel and administration of the Emergency Response Plan. We use this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. General Emergency Response The following are the resources available to respond during emergencies: 7 Emergency Management System to manage and coordinate emergencies 7 Emergency Response Teams 7 Periodic emergency training for employees 7 Emergency alert system 7 Communication systems with local emergency responders and regulatory agencies 7 Emergency drills with plant personnel and community emergency responders 7 Emergency response equipment specially designed for industrial fire protection 7 Mutual Aid agreement with other companies (CAER Program) PLANNED CHANGES TO IMPROVE SAFETY PRSOC Refinery will continue maintain a safe working operation by ensuring that appropriate safety programs are followed. This will be accomplished by maintaining the programs established in the areas of Equipment Reliability, Mechanical Integrity, Procedures Revisions and Safety. Action items from the HAZOPS will be follow up to completion based on the priority assigned. Example of this is the installation of additional hydrocarbon monitors in specified areas to enhance the facility warning system. Compliance Audits will be followed up to ensure that action items are developed and implemented. EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At the Yabucoa, Puerto Rico Refinery of Puerto Rico Sun Oil Company, A wholly owned subsidiary of SUNOCO Inc., we are committed to operate and maintain all of our processes in a safe and responsible manner to our employees, contractors, and the general public. We use a combination of resources including personnel training, consideration of safety in the design, installation, operation and maintenance of the different refinery processes. We have accidental release prevent ion programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: A description of our facility and use of substances regulated by EPA's RMP regulation A summary of results from our assessment of the potential offsite consequences from accidental chemical releases An overview of our accidental release prevention programs A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule An overview of our emergency response program An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment The certifications that EPA's RMP rule requires us to provide The detailed information (called data elements) about o ur risk management program FACILITY DESCRIPTION, STATIONARY SOURCE, AND REGULATED SUBSTANCE PRSOC Refinery produces and distributes petroleum lubricants and distillate products from Reduced Crude and Crude Oil Feedstock's. The Refinery is located approximately two miles east of the municipality of Yabucoa, at State Road 901, kilometer 2.8, Camino Nuevo, Yabucoa, Puerto Rico. The Refinery occupies 252 acres of land in the eastern most region of the municipality. The Refinery Manager is responsible for assuring that the Refinery is prepared to respond to an emergency. The PRSOC Refinery have an Environmental Quality Board CAA Permit #PFE-TV-2911-0397-0025. The PRSOC Refinery uses the following flammable chemical that has been identified as regulated under the EPA's RMP rule with the potential to cause offsite consequences in the event of an accidental release: Propane - Used for refrigeration purposes in the MEK Unit. It is also used as fuel in the Utilities Unit espec ially during start up and shutdown operations. We have two propane storage bullets, one located at the MEK Unit Area, which contains 121,000 Lbs. (full capacity) and the other propane storage bullet located at the Utilities Area, which contains 142,000 Lbs. (full capacity). No regulated toxic material is handled or stored in quantities above the threshold limit values established for reporting by the regulation. HAZARD ASSESSMENT PROGRAM The hazard assessment program of EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The EPA's Offsite Consequence Analysis (OCA) guideline was used for the calculation of the Worst Case Scenario (WCS) results. It is important to understand that this scenario is based on the regulatory guidelines and it is calculated using the EPA rules. The worst-case scenario associated with a release of a flammable substance in Program 3 processes at the Re finery, a vapor cloud explosion (VCE), follows: Worst-case Release Scenario - Regulated Flammable Chemicals A catastrophic rupture of the second largest propane vessel of the refinery occurs releasing the total content (121,000 Lbs.) of the flammable substance. This release forms a Vapor Cloud Explosion (VCE) involving the full inventory of the vessel. This event would have off-site consequences. The largest propane vessel was not considered as the worst case scenario because of its location within the Refinery. When the Offsite Consequence Analysis (OCA) was done for this vessel the results were within the extent of the second largest vessel's distance. Even though key administrative controls and mitigation measures available to limit the exposure distances were not considered in this analysis, it is important to mention them. We have mitigation measures such as: tank level control, sewer systems within the tank dike area, fire suppression systems at the intermediate ta nk area that can be used to reduced the amount of vapors from the area. Alternative Release Scenario - Regulated Flammable Chemicals A Line rupture of the Propane Make - Up line that runs from V-003-01 to V-023- 11. These vessels are located between the MEK Intermediate tank area and the MEK Unit. A 15 minutes duration release, releasing 717 Lbs. of propane was simulated. The alternative release scenario, a Vapor Cloud Explosion (VCE), was simulated using a computer model program called PHAST (Process Hazard Analysis Software Tool). The event was selected on the basis of probability and past history and it was discussed with the Operating Specialist and the Operators. This event would have off-site consequences. Mitigation resources available are operator response, dikes, and fire suppression systems around the unit area (fire monitors) that can be use to reduced the amount of vapors. ACCIDENTAL RELEASE PREVENTION PROGRAM Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. We also take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems HES Best Practices, Process Safety Management and Personnel training programs address each of the key elements of successful prevention programs. HES Best Practices and OSHA PSM Standard There are various elements of the Health, Environmental and Safety (HES) Best Practices program that are directly related to the elements of the OSHA PSM standard. Employee Participation PRSOC Refinery employees are encouraged to participate in various activities that are directly related to a good hazard prevention program. Employees participate in the Plant Safety Committee, where items reviewed in this committee are the result of incident investigations, status of safety work orders (most of them created by them), and engineering requests, unit inspection minutes and any significant safety concern. They participate in the Process Hazards Analysis of the units in the Refinery giving their experience and expressing their view of the process being evaluated. They also participate in Incident investigations where root cause analyses are conducted and findings are developed to reduce or mitigate hazards that resulted from an incident. Process Safety Information Process Safety information is available to all employees at the different control room areas. Access to information related to the chemicals used in the Units, including a list of such chemicals, as well as the Material Safety Data sheet (MSDS) for them are available. There is also information about the technology of the process, flow or block diagrams to show the process. Brief descriptions of the type of processes (i.e. Distillation, filtration, and extraction) are also available as well as inventory information and acceptable operating ranges. The Refinery also maintains process equipment information such as material of construction, design codes and standards, relief systems, electrical ratings etc. Process Hazards Analysis Process Hazards Analysis (PHA's) are conducted in each process unit including new projects by a selected group of people, to identify possible hazards and to address findings to reduce or eliminate such hazards. The group members are selected based on the process to be analyzed. Typically its composition is a Team Leader (with knowledge of the PHA's techniques), an operating representative (knowledge of the unit to be studied), a technical representative (engineering) and a maintenance representative. A systematic approach is used in order to conduct these studies. It can be a Checklist, a What If or a Hazard and Operability Study (HAZOP). Results of these studies are documented, and records of implementation and follow up are maintained. Op erating Procedures PRSOC Refinery maintains procedures that address various modes of process operations, such as unit startup, normal operations, emergency shutdown, normal shutdown, and 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 certified as current and accurate. The procedures are maintained by revising them as necessary to reflect changes made through the management of change process. These 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. Training There is a training program for all employees involved in operating a process. New employees are required to complete an Apprenticeship Training Program. This program includes classroom training, formal in-unit training, on the job training; self study training, written and hands-on tests. The program includes basic skills training, qualifying on a set number of jobs at the assigned unit. Each apprentice must work on different types of refinery equipment, attend required safety training, and meet minimum requirements in the evaluations. 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, operators are re-certified every three years. This re-certification process includes any necessary refresher training, written testing, and skill demonstrations. Operators must re-certify on the jobs on which they are qualified at their assigned process unit. All training and testing is documented for each individual operator. Mechanical Integrity PRSOC Refinery has established policies and practices committing it to providing a safe workplace for its employees and to protecting the en vironment in its areas of operation. The primary goal of the Mechanical Integrity Program is to assure that all equipment and systems used to handle or process highly hazardous chemicals are designed, built, installed and maintained to control the risk of releases and other accidents. The program outlines the commitments of the Refinery to ensure that its workplaces are safe. This is done by defining the organization and controls, and the guidelines and procedures to be used by all personnel to protect the employees and the facilities. The program is intended to eliminate or mitigate the consequences of a release of toxic or hazardous chemicals. The refinery will continue to design, maintain, and operate its facilities, equipment and resources in a cost-effective manner, which recognizes that compliance with safety and environmental regulations is paramount. We are prepared to respond promptly and professionally should an incident occur. Management of Change PRSOC 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 ensure that adequate controls are in place to manage any new hazards and 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. Pre-Startup Safety Review For any new facility or facility modification that requires a change in the process safety information a Pre-Start Up Safety Review is conducted. The purpose of the pre-start up safety review 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 support systems are operationally ready. A Pre-Startup Safety Review involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Compliance Audits Corporate compliance audits are conducted at least every three years. This ensures that the Process Safety Program is being maintained as required. This is accomplished by conducting a formal evaluation and certification. The Refinery Process Safety Manager follows up on the programs on a regular basis to verify compliance of the elements of the PSM program. Incident Investigation The purpose of an Incident Reporting and Investigation procedure is to establish a consistent and effective system of internal reporting. It is also the means for investigation and follow up of all undesired events that resulted, or could have resulted, in physical harm to people, loss of production, or harm to the environment so that the potential for the recurrence of such events is minimized. An incident investigation committee that collects the facts and data of the incident that occurred conducts the incident investigation. This committee will then analyze the data to identify immediate and root causes. Based on these findings, appropriate actions will be taken to reduced or eliminate future incidents. These action items will be followed up to ensure proper implementation. Hot Work Permit PRSOC Refinery develops implements and maintains an effective system of safe work permit procedures, which shall include the requirements set forth in the different types of work in the refinery. The Hot Work permit is a written authorization to proceed with maintenance or construction activities after the review of the status and conditions of the equipment or area. The haz ards of the equipment or area, and the procedures and or equipment, including personal protective equipment required to performed the work safely, are evaluated. Contractors PRSOC Refinery maintains a contractor safety program which includes initial contractor orientation, safety audits, safety reports, incident investigation and program compliance. The refinery employs contractors to supplement its work force during normal periods or periods of increased maintenance or construction activities. Contractor safety procedures are coordinated and implemented by the Refinery Contractor Representative. Evaluation of the Contractors safety record and training program is used in selecting the Contracting Company. The safety regulations require Contractors to train their employees in the safe work practices and safety rules of the refinery. Contractors are also required to report any safety hazards that the contract work may cause for the facility or any hazards found by the contract employees. SPECIFIC PREVENTION STEPS As part of our prevention efforts, we have implemented the following chemical-risk reduction and safety measures as specific prevention steps: General: Engineering and construction in accordance with recognized industry and company standards Equipment designed with pressure safety relief valves Technical drawings, Piping & Instrument Diagrams and Process Flow Diagrams All process modifications reviewed for safety & health impacts Television surveillance capabilities Redundant control systems Inspection and testing of instruments, analyzers, and safety interlocks Testing and inspection of all boilers by state inspectors Regular safety meetings and safety awareness programs Employees/Management Health & Safety Committee Computer based training programs Scheduled safety inspections Safety showers and eyewash stations Self-contained breathing apparatus located in process units Substance abuse program and random drug test ing On-site first aid medical facility Material Release Prevention Operating systems monitored and controlled 24 hrs a day by trained Operators Computerized monitoring and control of process operation Daily checks of tanks and vessels level and operational status. Automatic and manual shutdown devices for critical systems Quality Control Laboratory to ensure accurate unit operation Vehicular traffic control Limited facility access. Radio communication system Release Mitigation Minimization of flammables and toxic chemical inventories Dikes and curbing to minimize spreading of released material Automatic and remotely operated shutoffs to limit release quantity Strategically located valves to isolate leaks Hydrocarbon and toxic gas detectors to warn of a chemical release Water sprays to contain vapor clouds and cool high temperature equipment Automated water sprays and fixed fire monitors for fire control Chemical release dispersion modeling capabilities at th e facility Piping systems inspected & tested as part of Mechanical Integrity program. Dedicated emergency response equipment specially designed for industrial fire protection. The specific prevention steps mentioned above work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility covered under EPA's RMP rule during the past five years. No significant incidents of the covered substances had occurred in the PRSOC Refinery during the past five years. EMERGENCY RESPONSE PROGRAM INFORMATION We maintain an integrated contingency plan, named "Emergency Plan" that consolidates various federal, state, and loc al regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. Our emergency response applies to all areas of the Refinery, including Oil Transfer, Marine and surrounding areas as specified by the Emergency Plan. This plan is designed to stand on its own. A corporate emergency plan defines expanded resources available within SUNOCO INC. The emergency plan is not designated to be a prescriptive document as each emergency incident is a unique event. The plan is designed to incorporate flexible emergency response, which addresses the needs of the emergency. The plan is supported by a set of Emergency Procedures. These emergency procedures call for enough qualified personnel in the Emergency Response Organization (ERO), to respond to an event and esta blished a proper Incident Command System. The incident command system is well explained in the Emergency Response Plan. The Incident Commander Refinery Manager) is responsible for assuring that the Refinery personnel are prepared to respond to an emergency. The Health, Environmental, and Safety Manager (Planning Officer) is responsible for development, maintenance, distribution, and training for the ERO personnel and administration of the Emergency Response Plan. We use this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. General Emergency Response The following are the resources available to respond during emergencies: Emergency Management System to manage and coordinate emergencies Emergency Response Teams Periodic emergency training for employees Emergency alert system Communication systems with local emergency responders and regulatory agencies Emergency drill s with plant personnel and community emergency responders Emergency response equipment specially designed for industrial fire protection Mutual Aid agreement with other companies (CAER Program) PLANNED CHANGES TO IMPROVE SAFETY PRSOC Refinery will continue maintain a safe working operation by ensuring that appropriate safety programs are followed. This will be accomplished by maintaining the programs established in the areas of Equipment Reliability, Mechanical Integrity, Procedures Revisions and Safety. Action items from the HAZOPS will be follow up to completion based on the priority assigned. Example of this is the installation of additional hydrocarbon monitors in specified areas to enhance the facility warning system. Compliance Audits will be followed up to ensure that action items are developed and implemented. |