This bulletin is to include roles and steps to conduct the siting analysis, anticipated use and estimated occupancy levels, management review and approval, and retention of associated documentation. The document should address long-term installation of trailers during normal operations and short-term installations that may occur during major turnarounds or significant construction projects and alterations.

The purpose of this document is to ensure that all temporary structures proposed on site receive a facility siting analysis and approval so that they are not exposed to fire/explosion overpressure waves or toxic releases that can result in serious personnel injury or illness. This document should be applied to all temporary structures (portable trailers, temporary buildings, shipping containers, mobile vans, box trailers) which are transported to their location and contain or are occupied by Company employees, contractors, visitors, or other on-site personnel under Company control where there is a potential impact from fires, explosions, toxics, or similar hazardous events.

This document applies to both long term (semi-permanent) location of temporary structures, as well as those that may be installed for shorter periods of time such as during unit shutdowns/turnarounds, environmental remediation, capital project work, or dismantlement.

This document does not apply to temporary structures that are not intended for human occupancy and/or which will be used solely for storage of materials or equipment or other applications that do not involve personnel occupancy.

  1. Prior to siting any temporary structure/portable building, a multi-disciplined team must conduct a facility siting analysis in order to ensure that the temporary structure/portable building is not exposed to fire/explosion overpressure waves or toxic releases that can result in serious personnel injury or illness. The following checklist, at the minimum, should be initiated, completed, routed and approved by line management who have responsibility for and control over the proposed location. Team members should include area PHA leader or resource, site or area Facility Siting Review team member, Area Production or Maintenance Manager/Superintendent, at least one occupant of proposed temporary structure/portable building.
    • Type of temporary structure
    • Purpose of structure
    • Proposed location of structure (attach map of site or area with proposed location)
    • Estimated time structure to be present at location
    • Estimated occupancy rates (person hours per week)
    • Potential hazards (fire, vapor cloud explosion, toxic materials, dusts, other), list documents reviewed
    • Is the proposed location outside of explosion overpressure wave zones at or above 1.0 psi (review site facility siting maps or PHA’s/Consequence Analysis results from adjacent operating areas); if not, additional explanation and risk analysis is required
    • Temporary structure connected to or can clearly hear site and unit/area emergency alarms and PA system announcements
    • Temporary structure has visibility to local wind socks or similar methods to detect wind direction
    • Emergency Evacuation Documents and Conditions: Location of designated muster point for accounting; Location of designated Safe Haven (if applicable); Special PPE Requirements (e.g., number of staged Emergency Escape Breathing Devices); Special controls (e.g., electrical classification, lighting, detectors)
    • The team should sign whether the proposed temporary structure location is acceptable OR not acceptable based on the checklist information provided and facility siting analysis
  2. All buildings should meet local building-code regulations and applicable Company design standards. All buildings should comply with the applicable regulations of NFPA 101.
  3. Buildings intended to house personnel or critical functions within fire hazard zones should be fire resistant. Exterior walls facing the fire hazard should have a fire-resistance rating of at least 30 minutes. The building roof should have a fire-resistance rating of at least 30 minutes, where the exposure of the building roof is credible. Exits should be arranged in a manner that is sufficient in number to permit occupants to evacuate from the fire hazard and move to a safe location.
  4. In border areas or facility interfaces which may involve different businesses or production areas, coordination between the areas or units is necessary to help ensure all potential hazards and siting requirements are addressed.
  5. The proposed location of the temporary structure should be identified on a site map and attached to the checklist mentioned above during the review and approval process.
  6. All relevant information should be obtained and provided in checklist mentioned above prior to final review and approval.

Completed checklist and all attachments should be maintained for all authorized temporary facilities and/or portable buildings for the duration of their installation. Checklists are retained in area/unit files that have control over the area where the structure is sited.

Current completed checklist should be made available to cyclic Process Hazards Analysis teams.

Line Management in control of the areas where a temporary structure is proposed or located is responsible to ensure all information and approvals are provided.

Site Engineering Team should approve and manage the actual location and hook-up of temporary structures.

PSM/PHA and EHS site resources should provide input and technical guidance on hazards, consequence analysis, and site facility siting studies.