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2107 - Lloyds Assessment of Sarpom Trecate Refinery
2107 - Lloyds Assessment of Sarpom Trecate Refinery
ALLEGATO A.12
Certificato del Sistema di Gestione Ambientale
ISO 14001 and OHSAS 18001 Attestation
Surveillance, and CCR Assurance
Report for:
Attachments
Trecate Refinery 2016 Assessment Schedule
Lloyd's Register Quality Assurance Limited, its affiliates and subsidiaries and their respective officers, employees or agents are,
individually and collectively, referred to in this clause as "LRQA". LRQA assumes no responsibility and shall not be liable to any person
for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that
person has signed a contract with the relevant LRQA entity for the provision of this information or advice and in that case any
responsibility or liability is exclusively on the terms and conditions set out in that contract.
Assessment outcome:
There was visible correlation between the SARPOM 1 Trecate Refinery (Trecate) systems and the
requirements of the ExxonMobil OIMS with the requirements of ISO 14001 and OHSAS 18001. The
Trecate Refinery functions with two operational teams for onsite and offsite operations, respectively.
There was evidence that there is a mature system in place at Trecate to address OIMS. In this
assessment, the OIMS Stewardship and Assessment processes were reviewed, as well as various
safety, health, and environmental programs. A small number of Isolated Incidents were identified related
to ISO 14001 nor OHSAS 18001 attestation, there was one “Suggestion for Improvement”. It is concluded
that there is sufficient evidence at Trecate to continue to support a positive Attestation conclusion for
ExxonMobil.
In addition, the Trecate processes used for the development, collection and reporting of the data for the
ExxonMobil Corporate Citizenship Report (CCR) are effective in delivering safety, health and
environmental indicators. The indicators are useful for assessing corporate performance and are
consistent with IPIECA/API Guidelines.
Employees and contractors at all levels interviewed demonstrated recognition of risks, with sincere
commitment to controlling these risks. The assessment took three person-days, and was conducted from
March 16-18, 2016.
Continual improvement:
It is suggested that senior management at Trecate Refinery continue to maintain focus on OIMS oversight
at the field level, particularly with respect to LPS implementation and environmental awareness.
The LRQA assessment was conducted from March16-18, 2016 alongside the ExxonMobil External OIMS
Assessment of the Trecate Refinery (Trecate). The OIMS system at Trecate has been effectively
established and implemented.
Findings including suggestions and observations are collected in the findings log below. Overall highlights
of improvements and areas for management attention are reflected in the executive summary of this
report. The LRQA Continual Improvement Tracking Log was not used.
Nothing in this document is intended to override the corporate separateness of ExxonMobil Corporation
and its affiliates. Working relationships discussed in this document do not necessarily represent a
reporting connection, but may reflect a functional guidance, stewardship, or service relationship. Where
shareholder consideration of a local entity matter is contemplated in this document, responsibility for action
remains with the local entity. The term ExxonMobil, as used in this document is used merely for
convenience and simplicity. Depending on the context, this term may refer to ExxonMobil Corporation, to
one of its divisions, to the companies affiliated with ExxonMobil Corporation, or to any one or more of the
foregoing.
OIMS System 1.1 addresses responsibilities for policy adoption, review, and revision. OIMS system to
address operational requirements at the refinery through the two operational teams, for onsite and offsite
operations.
Employees and contractors at Trecate were aware of the applicable SSHE policies, especially ‘Nobody
Gets Hurt’ and ‘Actively Caring’, though there was less awareness of ‘Protect Tomorrow Today’ with some
contractors.
Roles and responsibilities for SSH&E performance and improvement are well documented in the OIMS
system documents. Revisions have been made recently to restructure OIMS leadership. The site uses one
Assessment of: Objectives & Targets Auditee(s): Veronica Canever, Roberto Scolari
and Programs – all
OIMS processes
Trecate OIMS System 1.1 includes Improvement Plan and Business Plan requirements that define how
Trecate establishes objectives, targets and programs for the OIMS systems. Several systems were
reviewed using the “annual reviews”. Mechanisms for approval of the objectives and targets and methods
for reviewing progress toward achieving objectives are described within the OIMS systems.
System 2.1 outlines the requirements for health & safety risk assessments. Also, System 6.2 defines when
Job Safety Analyses are required for permitted work activities, and System 6.5 includes the need for
environmental aspect evaluations. The Loss Prevention System (LPS) is also used to identify risks
associated with “questionable” steps in work activities. Trecate implements these processes to identify and
evaluate potential health, safety, and environmental hazards associated with their operating and
maintenance activities. A Risk Assessment schedule has been developed, and was updated in 2015.
LRQA sampled the system using data and reports for pipeline risk assessment and facility siting and
building risk. Both of these issues were being given considerable attention by Trecate based on the results
of the risk studies. For example, a new Yard office building is under construction to ensure occupants are
situated at a safe distance from VCE overpressure hazards. Also, pipeline maintenance and refurbishment
activities are planned as a result for smart pig analyses.
System 6.5 outlines the requirements for environmental management including the need for an
environmental aspects register and development of annual Environmental Business Plans (EBPs) and
work plans. Trecate has processes to identify and evaluate environmental risks associated with their
manufacturing operations. Tools used include the corporate Environmental Aspects guidance.
A new Environmental Permit was issued to Trecate by the regional and national authorities in January
2015, after an extensive authority approval process. Permit includes combination of air emissions limits for
some sources and a “bubble” that places limits on total emissions. Trecate has appealed the current
“prescription” because of a number of inconsistencies among the various requirements of the permit. A
second phase of permitting will occur in the next three years to address more complex air emissions
challenges and the installation of CEMS systems. The permit process is a major component of the
facility’s EBP, and the permit requirements are requiring a substantial investment of CapEx funds to
implement. The EBP covers the next five years, including Phase 2 of the permitting process.
Trecate has procedures in place for managing environmental issues involving air emissions, water
discharges, waste handling and spill prevention. These are being updated to account for changes that are
needed to meet new permit conditions.
Suggest: Trecate should developing clear boundaries that define which offsite assets under the refinery’s
control (including terminals, tanks and pipelines), and how those assets are accounted for in the
Environmental Protection system and the EPI reporting process (e.g., for VOC emissions, wastewater
discharge limits, waste generation, and ECIs).
Suggest: Because of the changes made in the fuel streams used for combustion to reduce emissions
under the new Environmental Decree, the terminology used in emission calculation spreadsheets does not
always give a clear indication of the fuel composition. Trecate should consider addressing this issue in the
Air Emissions Procedure that is currently under revision in response to the most recent OIMS Internal
Assessment.
Trecate has processes and systems in place to identify legal and other requirements including changes.
Evaluation of compliance is conducted through a range of inspections and internal and external
compliance assurance assessments. A comprehensive compliance audit was conducted by an
ExxonMobil corporate team in September 2015. This resulted in four emphasis areas and 23 actions, ten
of which were completed by March 2016.
Trecate has a process for identifying legal and regulatory requirements, and they maintains a
comprehensive register of regulatory requirements and obligations. Environmental regulations –
particularly for air and GHG emissions – are becoming more stringent over time, and this has led to a
need for new environmental permits for Trecate.
Key highlights of the Trecate 2016 Action Plan for Regulatory Compliance include a focus on new major
laws, review of plans based on new laws, Environmental Decree application for process safety (Seveso)
and firefighting (2016), personal safety and industrial hygiene (2017) and other consolidated regulation
checks (2018).
None
Trecate has rigorous systems in place to evaluate and control risks associated with operations and
maintenance procedures including the need for written procedures, work permits and job safety analyses.
There is significant emphasis on the LPS program which is a core initiative being used to achieve safe
working conditions. There is clear evidence of management commitment and contact with workers.
During the last three years, Trecate has maintained excellent safety performance through this period of
intense work including the Kite streamlining project, tank movements, and a major turnaround. In 2015,
more than 40,000 permits were issued. Currently the site has been injury-free for more than 600 work
days.
Three permitted work activities were observed during the assessment involving an excavation (confined
space), scaffold erection, and a crane lift in the process area. One observation and one suggestion are
summarized below.
Suggest: For permitted work that uses a template JSA for identification and control of hazards, the
process could be improved if the JSA was designed in a way that would allow additional hazards identified
at the job site to be added in a succinct way.
Observation: During a field verification visit to the hydroskimmer area, two concerns were noted relating
to a permitted job involving a crane as follows. Upon arrival, the crane jib was idle above an active
roadway that was not barricaded or taped off, and there was no sampling or monitoring for hydrocarbon
vapors in the area as required by the hot work permit.
A current focus of the Incident Investigation system is on HLVI, with a new proposal being considered for
establishing an “HLVI Committee” that will review all HLVIs and local actions to address them at Trecate,
including action item closures. Corrective and preventive actions following incidents and NLI investigations
are stewarded through OIMS.
The “System Health” tracking matrix (updated monthly) does not include data on a complete set of incident
and near losses that are reported, but those metrics are tracked in other systems (e.g., System 1.1 and
5.1, where they are tracked together with LPS metrics.
In recent years the system has received a lower rating from Internal Assessments (3.0), attributable to the
limited number of staff trained in the “Causal Factor Why Tree” method and limited action to address
HLVIs. These are being addressed in the 2016 work plan.
None
System 11.1 describes the Trecate mechanisms for periodic assessment and audits. Internal audits have
been conducted annually in accordance with the OIMS requirements. Audit schedules are developed,
audit protocols and checklists have been developed, and auditor training requirements defined and
completed.
Reports from internal and external (corporate) assessments were reviewed. Action plans to address the
findings are developed and reviewed by management. System status is reported to OIMS Committee
twice a year.
A new process is being implemented to account for the 53 OIMS Critical V&Ms, and responsibilities will be
shared across all OIMS systems.
None
• ExxonMobil EPI Manual for Preparation of EPI Data, effective January 1, 2013
• C-EDMS for Trecate Refinery, 2015
• BREF Baseline Review
• Statement of Third Party Verification for GHG Emissions 2014 (Ernst & Young)
• CEMS Installation schedule (7 priority emission sources)
• PTS 1055 – procedure for estimating air emissions
• Hazardous and Non-hazardous aggregated waste summary spreadsheets for 2015
• Trecate Air Emissions calculation worksheet, 2015
• Trecate spreadsheets for reporting Greenhouse Gas indirect emissions
• ExxonMobil IIHL Manual for reporting injuries and illnesses, Part I, 2013
• Review of 2015 incident data reported in IMPACT
The processes used for collecting and reporting IIHL and EPI data were reviewed during the assessment.
For environmental data, some of the processes and methods used are in flux as reporting requirements
change due to the new permit requirements. For example, changes are occurring from the use of natural
gas in place of fuel oil, and for air emissions, some sources are being equipped with new CEMS systems
which will replace fuel-based calculation methods over time. For fugitive (VOC) emissions from tanks, new
models for calculating emissions are available but not yet used by Trecate.
Because of these changes, the processes used by Trecate for reporting air and GHG emissions are not
clearly explained in the local procedures. This issue was discussed above, under Environmental
Protection. The site should consider using consistency in the description of fuel gas generated and
consumed. Two issues are (1) FG terminology now that NG is being used in place of Fuel Oil, and (2)
inclusion/exclusion of inerts in gas composition. For GHG emissions, the data are subject to third party
verification which substantially mitigates these concerns. Trecate received a positive verification statement
for 2014, and the 2015 verification is soon to be completed.
Injury data were confirmed using reports generated from IMPACT. The number of hours used in the injury
rates is from HR for employees and from the Contractor Safety Coordinator for contractors. All of these
data are from daily gate entry/exit data. Only two recordable injuries have been reported in last five years,
and the site has now gone more than 600 days without a recordable injury. As such Trecate achieved the
zero injury target in 2015.
For 2015, there was one spill to containment in which a tank drain leaked to the API separator. For water
consumption and waste generation, the C-EDMS and spreadsheet data were reviewed for consistency.
None
Grade Status Finding Corrective action review Process / aspect Date Reference Clause
1 2 3 4 5 6 7 8
Observat New Based on a small sample of waste collection Environmental Protection 18 Mar 0316JIJ01 OIMS
ion areas in the hydroskimmer process areas 2016 6.5
(approximately 15 drums), it was noted that waste
was not always properly segregated (as general
waste, contaminated waste, and metals). This
was the case in about half of the drums.
Observat New During a field verification visit to the Work Permits 18 Mar 0316JIJ02 OIMS
ion hydroskimmer area, two concerns were noted 2016 6.2
relating to a permitted job involving a crane as
follows. Upon arrival, the crane jib was idle above
an active roadway that was not barricaded or
taped off, and there was no sampling or
monitoring for hydrocarbon vapors in the area as
required by the hot work permit.
Suggest New Trecate should developing clear boundaries that Environmental Protection 18 Mar 0316JIJ03 OIMS
define which offsite assets under the refinery’s 2016 6.5
control (including terminals, tanks and pipelines),
and how those assets are accounted for in the
Environmental Protection system and the EPI
reporting process (e.g., for VOC emissions,
wastewater discharge limits, waste generation,
and ECIs).
Major Nonconformity
The absence of, or the failure to implement and maintain, one or more management system elements, or a situation
which would, on the basis of the available objective evidence, raise significant doubt of the management to achieve:
• the policy, objectives or public commitments of the organisation
• compliance with the applicable regulatory requirements
• conformance to applicable customer requirements
• conformance with the audit criteria deliverables.
Minor Nonconformity
A finding indicative of a weakness in the implemented and maintained system, which has not significantly impacted on
the capability of the management system or put at risk the system deliverables, but needs to be addressed to assure
the future capability of the system.
Observation (O)
This term will be used on occasions when an assessor finds an isolated error that needs correction.
Suggest
This term will be used by assessors to indicate ways in which the system or business improvement can be achieved
by your organization. You can choose to act on these suggestions and there will be no automatic follow up by the
assessor
Additional information
Confidentiality
We will treat the contents of this report, together with any notes made during the visit, in the strictest confidence and
will not disclose them to any third party without written client consent, except as required by the accreditation
authorities.
Sampling
The assessment process relies on taking a sample of the activities of the business. This is not statistically based but
uses representative examples. Not all of the detailed nature of a business may be sampled so, if no issues are raised
in a particular process, it does not necessarily mean that there are no issues, and if issues are raised, it does not
necessarily mean that these are the only issues.
Terms and conditions
Client obligations are detailed in Section 6 of the LRQA contract.
LRQA information
The client is also reminded of the information and guidance available to them from our website www.lrqausa.com
This includes information on our QMS, EMS, OHSAS, Verification and Validation products, our Training Services and
our CE Directives products. Client Information Notes and camera-ready marks are available on our Extranet website.
10:00am 1.1 Leadership/Accountability Join OIMS team in Field Recap with Site OIMS
8.1 Third Party Services (Veronica Canever)
(Veronica/Roberto) Contractor Buddy Manager
11:00am Adjust and Finalize Join OIMS team in Field Leadership (1.1) Environmental (6.5)
6.3, 8.1 – T1BP site walk XXXX
Meeting Schedule (Edoardo)