Refinery turnaround – a necessary yet behemoth task. Turnaround provides a critical window for equipment maintenance and replacement as well as site clean-up and compliance. Refineries generally conduct a turnaround every couple of years, and schedules vary based on facility needs. While somewhat routine in that sense, turnarounds remain incredibly complex undertakings, with each event presenting unique challenges.
In this article, we explore the role the environmental oversight team plays during refinery turnarounds and the value it brings to the bigger picture. Often seen as a behind-the-scenes necessity, environmental oversight can help smooth the wrinkles of overall operational complexity during refinery turnaround.
The environmental oversight team helps enable site-wide compliance, both during turnaround activities and after standard operations are restored. The upfront work of environmental oversight not only helps prevent compliance headaches down-the-line, but can also help facilities steer clear of regulatory violations and fines.
Should a spill occur during turnaround, the environmental oversight team facilitates a quick and efficient clean-up before the spill creates a bigger issue. Additionally, the environmental oversight team monitors the cleaning pad to confirm the proper handling and disposal of hazardous waste and can inspect equipment after it has been cleaned to confirm it is clean enough to be put back into service or scrapped. Finally, the environmental oversight team can assist crews in determining the difference between hazardous waste-contaminated personal protective equipment (PPE) and non-contaminated PPE, which need to be disposed of differently.
Turnaround events bring an influx of people to a site, some of whom are familiar with the site layout and operations and others who are not. Additionally, even those who are familiar with a site are donning new hats as part of turnaround activities. Without effective communication, the mixture of more people and new roles can be a recipe for chaos at best. At worst, lack of communication can lead to compromised safety or damaged equipment.
The environmental oversight team can serve as an integral communications facilitator. Those responsible for environmental oversight during turnaround are constantly conducting rounds of the units in which turnaround is occurring and are therefore readily available, possess good visibility into turnaround activities as a whole, and are easy to track down should guidance or clarification be needed.
Additionally, because even a minor spill must be addressed, environmental oversight has a direct line of communication to each crew, and these lines of communication can help facilitate various types of information to keep crews on the same page.
Environmental oversight’s effective communication practices also support a site’s recordkeeping requirements, as those tasked with environmental oversight work to confirm all hazardous waste is accounted for when turnaround is over and the refinery resumes normal operations.
AN EYE FOR SAFETY
In addition to keeping units clean and tidy and addressing spills, the environmental oversight team can also serve as site safety champions, helping confirm proper PPE and exercising “stop-work-authority” – as well as coaching others to recognize situations when stop-work-authority should be applied. During turnaround, some workers may be conducting relatively new tasks or working night shifts, and unfamiliarity and fatigue can increase the risk of safety incidents. With so many moving parts and crews working demanding schedules, the environmental oversight team can be tapped into as a resource to check in with crews periodically to assess and address safety questions and concerns.
Once turnaround is complete, things like accumulated wastes need to go somewhere. A part of environmental oversight’s responsibilities includes confirming the site owner and operator has the proper records and documentation.
For example, the environmental oversight team can help with recordkeeping needs such as:
- Tracking hazardous waste drums (to ensure they are rounded up and removed from a site within the 90-day window per Resource Conservation and Recovery Act [RCRA] requirements)
- Tracking roll-off boxes that contain hazardous waste (to ensure they are rounded up and removed from site within the 90-day window per RCRA requirements)
- Tracking heat exchanger bundles and other equipment at the cleaning location (to track if all hazardous waste has been removed and properly contained, what equipment is from which unit, if it has been cleaned, if it has been inspected and is good-to-go, or if it fails inspection and needs recleaned or repaired, if it is for scrap or if it is going back into service, and when all these things happen)
- Tracking loads to the landfill to confirm wastes are being disposed of in the proper location per regulations
While environmental oversight may seem like a small cog in the gearing needed to make a turnaround event successful, there are numerous activities and secondary roles the environmental oversight team can play to help turnaround go off without a hitch.
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