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Sinclair Wyoming Refining Company

Parent Companies:
Sinclair Oil Corporation
EPA Facility ID:
100000116867
Other ID:
82334SNCLREASTL
Facility DUNS:
135912483
Parent Company DUNS:
0

Location:

Address:
100 E. Lincoln Highway
Sinclair, WY 82334
County:
CARBON
Lat / Long:
41.779, -107.108 (Get map)
Method:
Interpolation - Satellite
Description:
Administrative Building
Horizonal accuracy:
1 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Sinclair Oil Corporation
Phone:
(801) 524-2700
Address:
550 East South Temple
Salt Lake City, UT 84102
Foreign Address:

Person responsible for RMP implementation:

Name:
John Pfeffer
Title:
Environmental Manager

Emergency contact:

Name:
Steve Sondergard
Title:
Refinery Manager
Phone:
(307) 328-3543
24-hour phone:
(307) 324-3404
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(801) 524-2767
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Carbon County LEPC
Full-Time Equivalent Employees:
505
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
30-145
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 7, 2013
Inspecting Agency:
State occupational safety agency
Using Predictive Filing:
No

Processes:

582 Vacuum/Crude
RMP ID:
1000049126
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
320,000
No
Public OCA Chemical
0
No
581 Crude
RMP ID:
1000049127
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
240,000
No
Public OCA Chemical
0
No
Ref;HDS;LEF;Nph.Sp;Am.Reg
RMP ID:
1000049128
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
330,000
No
Public OCA Chemical
0
No
780 FCC
RMP ID:
1000049129
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
120,000
No
Public OCA Chemical
0
No
GasRec;Alky;Poly;Slop;C3
RMP ID:
1000049130
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
1,300,000
No
Propane
74-98-6
780,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Tank Farm, Spheres
RMP ID:
1000049131
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
230,000,000
No
Butane
106-97-8
7,800,000
No
Isobutane [Propane, 2-methyl]
75-28-5
3,700,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Hydrocracker Unit
RMP ID:
1000049132
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
270,000
No
Public OCA Chemical
0
No
#4 HDS Unit
RMP ID:
1000049133
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
13,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Sage Environmental Consulting, L.P.
Address:
410 Grand Street
Suite 304
Laramie, WY 82070
Foreign Address:

Phone:
(307) 745-8370

Latest RMP Submission:

Date:
March 31, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000039872

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Tank Farm, Spheres)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • Blast walls
not considered:
  • None

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Tank Farm, Spheres)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • Blast walls
not considered:
  • Dikes
  • Fire wall
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

Sept. 27, 2013 at 22:00
ID:
1000032825
NAICS:
Petroleum Refineries (32411)
Duration:
6 hours
Chemicals involved:
  • Hydrogen
Release events:
Gas release
Fire
Explosion
Weather conditions at time of event
Wind speed:
25.0 miles/h WSW
Temperature:
36.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$40000000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Improper procedure
  • Process design failure
  • Unsuitable equipment
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Process material information assessment
May 25, 2012 at 22:00
ID:
1000032824
NAICS:
Petroleum Refineries (32411)
Duration:
15 minutes
Chemicals involved:
  • Butane
Release events:
Gas release
Fire
Weather conditions at time of event
Wind speed:
4.0 miles/h NNW
Temperature:
47.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
2
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$5000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Improper procedure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised operating procedures
May 8, 2012 at 09:00
ID:
1000032823
NAICS:
Petroleum Refineries (32411)
Duration:
15 minutes
Chemicals involved:
  • Butane
Release events:
Gas release
Fire
Weather conditions at time of event
Wind speed:
3.0 miles/h ENE
Temperature:
40.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
4
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$10000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Improper procedure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised operating procedures
Sept. 2, 2011 at 12:00
ID:
1000032809
NAICS:
Petroleum Refineries (32411)
Duration:
3 hours
Chemicals involved:
  • Flammable Mixture
Release events:
Fire
Weather conditions at time of event
Wind speed:
18.0 miles/h WSW
Temperature:
71.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$6000000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Maintenance activity/inactivity
  • Unsuitable equipment
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised training

7. Prevention: Program level 3

582 Vacuum/Crude, Petroleum Refineries (32411)
Prevention Program ID:
1000042467
Safety Review Date
Feb. 20, 2014
PHA Update Date
April 27, 2011
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 12, 2014
Training Review Date
Oct. 23, 2013
Maintenance Review Date
May 31, 2009
Maintenance Inspection Date
March 19, 2014
Equipment Tested
Yes
Management of Change Most Recent Date
March 13, 2014
Management of Change Review Date
Dec. 28, 2013
Pre-startup Review Date
March 13, 2014
Compliance Audit Date
Aug. 15, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
March 13, 2014
Incident Invest. Change Completion Date
April 14, 2014
Participation Plan Review Date
Oct. 11, 2012
Hot Work Review Date
Dec. 6, 2012
Contractor Safety Review Date
Dec. 6, 2012
Contractor Safety Eval. Date
March 5, 2014
581 Crude, Petroleum Refineries (32411)
Prevention Program ID:
1000042468
Safety Review Date
Sept. 5, 2013
PHA Update Date
March 30, 2012
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Increased Inventory
  • Process Parameters
  • Process Controls
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 1, 2014
Training Review Date
Oct. 23, 2013
Maintenance Review Date
May 31, 2009
Maintenance Inspection Date
March 10, 2014
Equipment Tested
Yes
Management of Change Most Recent Date
March 21, 2014
Management of Change Review Date
Dec. 28, 2013
Pre-startup Review Date
March 21, 2014
Compliance Audit Date
Aug. 15, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
March 9, 2014
Incident Invest. Change Completion Date
April 12, 2014
Participation Plan Review Date
Oct. 11, 2012
Hot Work Review Date
Dec. 6, 2012
Contractor Safety Review Date
Dec. 6, 2012
Contractor Safety Eval. Date
March 5, 2014
Ref;HDS;LEF;Nph.Sp;Am.Reg, Petroleum Refineries (32411)
Prevention Program ID:
1000042469
Safety Review Date
Aug. 14, 2013
PHA Update Date
Sept. 1, 2011
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Reduced Inventory
  • Process Controls
  • Process Detection
  • Perimeter Monitoring
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 19, 2014
Training Review Date
Oct. 23, 2013
Maintenance Review Date
May 31, 2009
Maintenance Inspection Date
March 17, 2014
Equipment Tested
Yes
Management of Change Most Recent Date
March 25, 2014
Management of Change Review Date
Dec. 28, 2013
Pre-startup Review Date
March 25, 2014
Compliance Audit Date
Aug. 15, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
Feb. 6, 2014
Incident Invest. Change Completion Date
March 7, 2014
Participation Plan Review Date
Oct. 11, 2012
Hot Work Review Date
Dec. 6, 2012
Contractor Safety Review Date
Dec. 6, 2012
Contractor Safety Eval. Date
March 5, 2014
780 FCC, Petroleum Refineries (32411)
Prevention Program ID:
1000042470
Safety Review Date
Feb. 13, 2013
PHA Update Date
March 28, 2014
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Increased Inventory
  • Perimeter Monitoring
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 13, 2014
Training Review Date
Oct. 23, 2013
Maintenance Review Date
May 31, 2009
Maintenance Inspection Date
March 13, 2014
Equipment Tested
Yes
Management of Change Most Recent Date
March 19, 2014
Management of Change Review Date
Dec. 28, 2013
Pre-startup Review Date
March 19, 2014
Compliance Audit Date
Aug. 15, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
Feb. 28, 2014
Incident Invest. Change Completion Date
April 3, 2014
Participation Plan Review Date
Oct. 11, 2012
Hot Work Review Date
Dec. 6, 2012
Contractor Safety Review Date
Dec. 6, 2012
Contractor Safety Eval. Date
March 5, 2014
GasRec;Alky;Poly;Slop;C3, Petroleum Refineries (32411)
Prevention Program ID:
1000042471
Safety Review Date
Oct. 7, 2013
PHA Update Date
Aug. 9, 2013
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Purge System
Mitigation Systems
  • Dikes
  • Fire Walls
  • Deluge System
  • Enclosure
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 17, 2014
Training Review Date
Oct. 23, 2013
Maintenance Review Date
May 31, 2009
Maintenance Inspection Date
March 14, 2014
Equipment Tested
Yes
Management of Change Most Recent Date
March 14, 2014
Management of Change Review Date
Dec. 28, 2013
Pre-startup Review Date
March 14, 2014
Compliance Audit Date
Aug. 15, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
March 5, 2014
Incident Invest. Change Completion Date
April 11, 2014
Participation Plan Review Date
Oct. 11, 2012
Hot Work Review Date
Dec. 6, 2012
Contractor Safety Review Date
Dec. 6, 2012
Contractor Safety Eval. Date
March 5, 2014
Tank Farm, Spheres, Petroleum Refineries (32411)
Prevention Program ID:
1000042472
Safety Review Date
Jan. 24, 2014
PHA Update Date
Aug. 13, 2009
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
  • Process Controls
  • Process Detection
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 8, 2014
Training Review Date
Feb. 2, 2013
Maintenance Review Date
May 31, 2009
Maintenance Inspection Date
March 13, 2014
Equipment Tested
Yes
Management of Change Most Recent Date
March 19, 2014
Management of Change Review Date
Dec. 28, 2013
Pre-startup Review Date
March 19, 2014
Compliance Audit Date
Aug. 15, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
March 6, 2014
Incident Invest. Change Completion Date
April 7, 2014
Participation Plan Review Date
Oct. 11, 2012
Hot Work Review Date
Dec. 6, 2012
Contractor Safety Review Date
Dec. 6, 2012
Contractor Safety Eval. Date
March 5, 2014
Hydrocracker Unit, Petroleum Refineries (32411)
Prevention Program ID:
1000042473
Safety Review Date
June 27, 2013
PHA Update Date
April 5, 2013
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None Recommended
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 14, 2014
Training Review Date
Oct. 23, 2013
Maintenance Review Date
May 31, 2009
Maintenance Inspection Date
March 17, 2014
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 12, 2014
Management of Change Review Date
Dec. 28, 2013
Pre-startup Review Date
Feb. 12, 2014
Compliance Audit Date
Aug. 15, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
Jan. 27, 2014
Incident Invest. Change Completion Date
March 6, 2014
Participation Plan Review Date
Oct. 11, 2012
Hot Work Review Date
Dec. 6, 2012
Contractor Safety Review Date
Dec. 6, 2012
Contractor Safety Eval. Date
March 5, 2014
#4 HDS Unit, Petroleum Refineries (32411)
Prevention Program ID:
1000042474
Safety Review Date
July 18, 2013
PHA Update Date
May 28, 2010
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None Recommended
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 17, 2014
Training Review Date
Oct. 23, 2013
Maintenance Review Date
May 31, 2009
Maintenance Inspection Date
Dec. 2, 2013
Equipment Tested
Yes
Management of Change Most Recent Date
March 19, 2014
Management of Change Review Date
Dec. 28, 2013
Pre-startup Review Date
March 19, 2014
Compliance Audit Date
Aug. 15, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
March 11, 2014
Incident Invest. Change Completion Date
April 13, 2014
Participation Plan Review Date
Oct. 11, 2012
Hot Work Review Date
Dec. 6, 2012
Contractor Safety Review Date
Dec. 6, 2012
Contractor Safety Eval. Date
March 5, 2014

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Feb. 28, 2013
Local Response Agency:
Local Response Agency Phone:
(307) 324-2776
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

Risk Management Plan - Executive Summary





Sinclair Wyoming Refining Company (SWRC) as part of its Safety and Regulatory Excellence Program has instituted the following Commitment to Safety and the Environment with the following goals:

* No harm to people

* No damage to the environment

* Safe and reliable production







ACCIDENTAL RELEASE PREVENTION



Everyone who works for the SWRC is responsible for getting Safety & Environmental performance right. Exceptional Safety & Environmental performance is critical to the success of our business of refining crude oil and delivering quality products. No activity is so important that it cannot be performed safely and meet environmental standards and requirements.



SWRC will work to deliver these goals by:

* Demonstrating safe and efficient operation of our facilities.

* Pollution prevention; reduction of waste, emissions and discharges; and energy efficiency improvement.

* Providing a secure working environment by protecting ourselves, our assets and our operations against loss or damage from criminal, hostile or malicious acts.

* Ensuring everyone is informed, well trained, engaged and committed to compliance with legal and other requirements.

* Recognizing those who contribute to improved outstanding safety and environmental performance.

* Producing quality products for our customers.

* Communicating effectively with our employees, neighbors, customers, public interest groups, and those who work with us.



SWRC will work together to accomplish these goals, and when necessary, utilize Stop Work Authority to intervene before an unsafe condition or environmental violation may occur.







DESCRIPTION OF SWRC AND THE REGULATED SUBSTANCES HANDLED



The refinery was constructed in 1923 and operated by the Producers and Refiners Company. Sinclair Refining Company purchased the refinery in 1934 and operated it until 1972, including a period of operations as a subsidiary of Atlantic Richfield Company. I
n 1972, PASCO purchased the refinery and operated it until 1976 when it was acquired by Sinclair Oil Corporation, the present owner and operator. Sinclair Wyoming Refining Company is official name of the refinery.



Description of Refinery Processes:

SWRC includes modern process units typically used for production of petroleum fuels; atmospheric and vacuum distillation, hydrotreating, reforming, fluidized catalytic cracking, delayed coking, alkylation and associated supporting operations such as crude oil unloading, sulfur recovery, blending and crude oil/product storage and transport. The NAICS code for the SWRC is 32411.



Description of Refinery Products:

SWRC manufacturers the following generic products/by-products:



* Asphalt

* Black Oil

* Diesel Fuel

* Fuel Oil

* Gasoline

* Jet Fuel

* Liquefied Petroleum Gases

* Petroleum Coke

* Sulfur



RMP Program - Definition of Processes and Regulated Substances:

The 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). For petroleum refineries, RMP guidance recommends establishing process boundaries matching the PSM process boundaries.



Per the RMP definition, SWRC has the following RMP regulated flammable substances in its processes:



* Hydrogen

* Methane

* Ethane

* Propane

* n-Butane

* Isobutane

* Pentane

* Isopentane

* Flammable Mixtures



SWRC has the following regulated toxic substances in its processes:



* Hydrogen Sulfide

* Sulfur Dioxide

* Ammonia



Of the above flammable and toxic substances, only flammable mixtures, n-Butane, Propane, and Isobutane exceed the R
MP threshold quantity for flammables. There are multiple processes where flammable mixtures present in quantities above RMP threshold. None of the toxic substances listed above exceed the threshold quantity for toxics. Based upon threshold quantities and process definition, the SWRC is reporting the following eight processes in its RMP:



* 582 Vacuum/Crude Unit

* 581 Crude Unit

* Reformer, # 1 HDS, # 2 HDS, LEF, Naphtha Splitter, Amine Regeneration # 1, Amine Regeneration # 2

* 780 Fluid Catalytic Cracking Unit

* Gas Recovery, Straight Run Gas Recovery, Old Alky, Poly, New Alky, Slop Recovery and Propane Storage

* Tank Farm, Spheres

* Hydrocracker Unit

* #4 HDS Unit



Other processes at the SWRC either do not have regulated flammable substances or contain such substances in quantities below the RMP applicability threshold.



SWRC has multiple processes that contain Hydrogen Sulfide and Sulfur Dioxide. The maximum quantity of Hydrogen Sulfide and Sulfur Dioxide in any process does not exceed 10,000 pounds and 5,000 pounds, respectively. Ammonia is used in several processes in amounts less than 10,000 pounds at each process. Because the quantities of these toxic substances are less than their respective RMP threshold values, none of the toxic substances are RMP reportable. Nevertheless, SWRC has prevention and safety programs in place for these toxic substances as part of its PSM Program.







ACCIDENTAL RELEASE PREVENTION PROGRAM AND PROCESS SPECIFIC PREVENTION STEPS



SWRC's accidental release prevention program includes the provisions of the Risk Management Plan (RMP) program that is summarized below and includes the associated provisions of OSHA's Safety Management (PSM) Program. SWRC works proactively to provide a safe workplace for each employee and continues to promote safety practices among employees for their health and welfare. This is accomplished by actively assuring wide employee participation in a thorough Process PSM program
and appropriate safety training.



The PSM program is managed by a corporate team and implemented on a facility basis under the specific direction of the facility manager. The PSM program conforms to OSHA regulations contained in 29 CFR 1910. SWRC has devoted the leadership, manpower, and capital investment necessary to complete the program. SWRC updates the Safety Management Program and Risk Management Program for each significant process change and at least every five years. Emphasis is placed on managing the higher risk facilities first, the priority of which is established by each facility team.



SWRC's management recognizes and firmly believes in the need for a safe environment for both the refinery and the local community. SWRC's policy ensures that its efforts with prevention through planning, training, reasonable process controls, timely maintenance and communication with our neighbors will help prevent unforeseeable releases of regulated substances. Should a release nevertheless occur, SWRC's trained personnel, in conjunction with trained personnel from the community, have been trained to respond, mitigate, and contain the release.



PSM Program:

For the RMP-covered processes, RMP allows SWRC to use OSHA'S PSM standard as our prevention program. SWRC's RMP submitted to the U.S. EPA 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

* Contractor Safety

* Pre-Startup Safety Reviews

* Mechanical Integrity

* Hot Work Program

* Management of Change (MOC)

* Incident Investigation

* Compliance Audits

* Emergency Planning and Response



Employee Participation:

The SWRC encourages and invites employees to participate in every aspect of process safety management and accident prevention. Specific wa
ys that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the SWRC and addresses each accident prevention program element. In addition, there is a group of SWRC employees (Employee Participation Task Force) charged with finding opportunities to improve employee participation. It includes management, professional, and hourly employees.



Employees have access to all information that is part of the accident prevention program. Copies of the information are located in the unit operations buildings for quick access.



Examples of employee participation include participating in the HAZOP analysis of each unit, updating and compiling technical documents and chemical information for their unit area and 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 SWRC 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 responsibilities 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 found 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, SWRC has documented safety-related limits for specific parameters (e.g. temperature, pressure, level and flow) used in monitoring and controlling operations. The SWRC ensures that the process is maintained within these parameters using process controls and monitoring instruments, highly trained personnel and protective instrument systems.



SWRC also maintains numerous technical documents that provide information about the design and construction of the equipment. This information includes material 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:

SWRC 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.



SWRC 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 company 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 units. The team makes recommendations about systems, procedures or practices to put in place to ensure that hazards are managed and mitigated.



The PHA team findings are forwarded to local management for review and resolution. Implementation of systems, procedures and practices are based on a determination of risk associated with the findings. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The PSM Coordinator'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, SWRC updates and revalidates the hazard analysis results. The revalidation team consists of the same types of personnel as the initial HAZOP team. 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/documented until they are complete.



Operating Procedures:

SWRC maintains written procedures for all operations and worker functions at the refinery. The procedures address various modes of unit operation, including:



* Pre-Startup

* Unit Startup

* Normal Operations and Process Control

* Temporary or Special Operating Procedures

* Emergency Shutdown

* Normal Shutdown



Additional information present within 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.



There is a current project to review operating procedures for correction, updates or creation of new procedures as needed. This effort also invoices
input from hourly employees.



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 MOC 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:

SWRC compliments the written operating procedures with a comprehensive training program. New employees receive initial training in refinery operations and safety practices. After successfully completing this training, the new operator or technician receives a manual that guides them to an understanding of their responsibilities. Operators are given a manual that discusses the equipment, how it works and what is involved in its operation. Drawings and graphics help the new operator picture the vessels and equipment in the unit. Maintenance personnel also receive guidance on their responsibilities under training by current maintenance personnel.



New operators are paired with experienced operators to learn process-specific duties and tasks. All new operators are tested on what they have learned, both by study and by demonstration. When operators demonstrate adequate knowledge to perform the duties and tasks in a safe manner on their own, they are allowed to work independently.



All operators periodically receive refresher training in operations to ensure that their skills and knowledge area at a proper level. The refresher training is conducted at least every 3 years and is documented for each operator. Maintenance personnel receive refresher training through the certifications required for inspection and testing. Personnel are required to take the necess
ary certification training and tests on the appropriate schedule to keep current.



SWRC 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:

SWRC conducts a Pre-Startup Safety Review (PSSR) for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready.



The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as quality assurance by requiring verification that the accident prevention program requirements are properly implemented. The completed and signed PSSR checklist is included in the PSM files.



Mechanical Integrity:

SWRC has well established practices and procedures to maintain pressure vessels, piping systems, relief vent systems, controls, pumps, compressors and emergency shutdown systems in a safe operating condition. The basic aspects of this program include:



* Conducting training of maintenance personnel

* Developing written procedures

* Performing inspections and tests

* Correcting identified deficiencies

* Applying quality assurance measures



These activities form a system that maintains the mechanical integrity of the process equipment. SWRC uses current versions of the applica
ble 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 ensure that they can perform their job in a safe manner. Written procedures for testing and inspecting help ensure that the work is performed consistently and provides a basis for training.



Personnel perform inspections and tests to ensure that equipment functions as intended and to verify that equipment is within acceptable limits. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service, if possible, or the refinery's MOC team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. SWRC also integrates quality assurance within its mechanical integrity program by affirming that all equipment purchases and repairs are up to code and per specification. This approach ensures that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.



The refinery's inspection and testing personnel (including contractors) are certified to proper standards and have current training certificates on file. Personnel are certified to API 510, 653 and 570 specifications.



Safe Work Practices:

SWRC has a long-standing safe work practices in place to help ensure worker and process safety. Examples of safe work practices include:



* Control of the entry/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 permi
t and procedures to ensure that adequate precautions are in place before entry into a confined space



These procedures and other measures, 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:

SWRC has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process-operating conditions), procedures and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and to verify that existing controls have not been compromised by the change.



Affected chemical hazard information, process-operating limits, equipment information and procedures are updated to incorporate these changes. Operating and maintenance personnel are provided any necessary training on the change.



SWRC tracks all MOC changes and their details. The MOC documentation is stored in the PSM Coordinator's office.



Incident Investigation:

SWRC 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 root cause 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 investigations team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendations is documented and the investigation results are reviewed with all employees (including contractors) who could be affected by t
he findings.



SWRC retains incident investigation reports on file in the EHS Department 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, SWRC periodically conducts audits to determine whether the procedures and practices required by the accident prevention program are being implemented.



SWRC has chosen to conduct compliance audits at least every 3 years using a knowledgeable team formed of corporate personnel, staff from other Sinclair Oil Corporation facilities 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, documented and the two most recent audits are retained onsite as part of the PSM file.



Chemical-Specific Prevention Steps:

The processes at SWRC 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 processes. 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, SWRC has safety features on many units to help contain/control releases, detect releases and reduce the consequences of a release. The following types of safety features are used in various process units:



* Release Detection

* Hydrocarbon detectors with alarms

* HYDROGEN SULFIDE detectors with alarms

* Release containment and control

* Process relief valves that discharge to a monitored flare system. The flare captures and incinerates episodic releases. (Monitored by a video camera)

* 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. fire retardant clothing, self-contained breathing, bunker gear, eyewash systems, etc.)



If a release does occur, these release prevention systems help SWRC contain and control the release in a way that minimizes risk to personnel and the public.







5-YEAR ACCIDENT HISTORY



SWRC has had the following RMP-reportable incidents that occurred during the previous 5-year period:



* In September 2011, a fire occurred at the 582 Crude Unit as a result of a seal failure on a desalter crude oil pump. The fire resulted in significant property damage.

* In May of 2012, a fire occurred in the Gas Recovery Unit because of the release of butane. The butane was released due to operators draining a caustic wash vessel to refinery sewer. The Caustic level became insufficient and allowed the butane to "blow-through". Four operators working in the area were injured, three of which experienced severe burns and days away from work.

* In May of 2012, a fire occurred in the Alkylation unit because of bleeding a Butane pump to the atmosphere. Two operators involved in the task were treated for burn injuries.

* In September of 2013, a fire occurred in the #4 HDS unit because of a valve flange failure that resulted in the release of hydrogen. The fire resulted in significant property damage.







EM
ERGENCY RESPONSE PROGRAM



SWRC maintains a written emergency response program to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including:



* Proper first-aid and medical treatment for exposures

* Evacuation plans and accounting for personnel after an evacuation

* Notification of local emergency response agencies and the public if a release occurs

* Cleanup and decontamination requirements



In addition, SWRC 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 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 SWRC is coordinated with the Local Emergency Planning Committee (LEPC). LEPC members include local emergency response officials, local government officials and industry representatives. SWRC has periodic meetings with 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, SWRC conducts periodic emergency drills that involve the LEPC and emer
gency 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 and to ensure that local emergency responders get to meet and interact with SWRC's personnel in addressing response actions.



The fulfillment of these purposes help us ensure that we meet the requirements of the emergency response program and have a practical and effective plan in place that has the full confidence of the LEPC and local emergency response groups.



SWRC resolves all safety-related finding 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 changes. All affected personnel will be trained prior to their operation of the equipment.







PLANNED CHANGES TO IMPROVE SAFETY



SWRC is in the process of implementing the following changes to improve safety at the facility:



* Supervisor Training: Improving and enhancing the safety skills and knowledge of its Supervisory Staff through a nationally recognized certification process known as the Safety Trained Supervisor (STS) Certification. To achieve this, supervisors must qualify through education, study and work experience to sit for and pass a comprehensive exam. The designation is awarded by the Board of Certified Safety Professionals. SWRC currently has 13 supervisors who have earned this designation with 25 others working towards final testing. It is SWRC's goal to eventually have all its supervisors earn the STS designation. In addition to the certification process, beginning in 2012, SWRC has also implemented a monthly 2 hour Supervisor training session designed to continually communicate management's expectations and requirements with regard to their safety responsibi
lities and accountabilities. This is also the forum for supervisors to ask questions or bring up safety related issues they may be having in the field.

* Operations Supervision: The Operations department has incorporated a new position designation of "Stillman" on each shift that is intended to provide immediate access to supervision for all levels of operations. Additionally, the Stillman is intended to provide guidance and training for his crew as this position allows for Operations supervision on each shift. SWRC has added 20 new positions to achieve this objective.

* Mechanical Integrity Team: A cross sectional team made up of individuals from Operations, Inspections, Process Safety, Engineering and Technical Services has been assembled and is currently functioning to identify gaps in the process designed to inspect, evaluate and mitigate mechanical integrity risks. This team has been in place since December 2013, and it is chaired by the Corporate Process Safety Manager.

* Safety Showers: SWRC has spent considerable resources to identify the appropriate type of eyewash/safety showers to be installed at the facility. These well-designed, reliable eyewash/safety showers are maintainable and are managed to provide the protection employees must have. In addition, SWRC is continuing to communicate and work with safety equipment vendors to ensure it achieves the goal of reliable effective protection for its employees.

* Incident Reporting: SWRC has employed the use of KMS (a data management program) to improve its incident reporting. This system has been in place for 2 years and its use has become part of the daily routine in reporting incidents (e.g. safety, process safety and environmental) and near misses. The KMS reporting process has been reviewed by both a third party PSM Auditor and an Insurance Auditor with positive evaluations.

* Emergency Response: Improvements have been made in the element of Emergency Response that includes organizationa
l changes to include a full-time Fire Chief, five rotating emergency response specialists, a facility nurse and part-time Physician's Assistant. In addition, there have been improvements made in Fire Protection hardware, including upgrades to fixed deluge systems, water-spray systems and in-ground firewater delivery systems in conjunction with a new firewater tank and pumping capacity.

* Operating and Maintenance Procedures: SWRC has attempted to implement an improved, clear, concise set of operating procedures that meet all operational and regulatory requirements. These previous efforts have not been entirely successful for many reasons. SWRC believes it has identified the majority of the issues that have hampered its efforts in the past and implementation of both the updated operating and maintenance procedures in under way.

* Management Support - Safety and Regulatory Excellence (S&RE) organization: Corporate Management fully supports the efforts to improve safety at the facility. This can be demonstrated by the significant increase in safety resources over the last few years including creation of an independent organization, the Safety and Regulatory Excellence (S&RE) organization, which reports directly to the Chief Executive Officer. The S&RE organization includes all Health, Safety, Environmental and Process Safety staff as well as the hiring of new personnel who have been selected for their professional credentials and experience.

* Training: Improvements have been established in the Operations and Maintenance training efforts that include a new Operations Training Coordinator who has been tasked with developing and implementing New-Hire and ongoing refresher training. The new Stillman position (discussed above) allows the current unit trainers to focus solely on training without having additional responsibilities to distract them. This improvement also includes installation and implementation of a new and improved data management system for
tracking and maintaining all training records.

* Wyoming Refining Safety Alliance (WRSA): SWRC has benefitted from helping to establish, chair and participate in the periodic WRSA meetings. There have been numerous lines of communication opened and all members have benefitted from the shared learnings discussed at each meeting.

* Metrics and Assessment: SWRC is in the process of developing a more comprehensive set of safety and health metrics for our management to provide an improved set of tools to manage the safety aspects of their job. SWRC will include both leading and lagging indicators as part of that toolbox.

* Injury Rates: Recognizing that injury rates are only one of many indicators of safety performance, SWRC's injury rate has declined generally over the past several years. In two of the past three years, SWRC has achieved a Recordable Injury rate lower than our industry average.