MI Refining Division, Woodhaven Cavern Facility - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

                Risk Management Program Plan 
1.     Executive Summary 
 Marathon Ashland Pipe Line LLC (MAPL) is committed to operating Woodhaven Cavern 
 Facility (WCF), owned by Marathon Ashland Petroleum LLC, Michigan Refining Division, 
 in a manner that is safe for employees, contractors, the public, and the environment.  It is the 
 WCF's policy to conduct its operations in accordance with the highest standards of 
 environmental stewardship, employee and contractor safety and community responsibility.  
 As part of this policy, the WCF has established systems to help ensure safe operation of the 
 processes at this facility.  One part of these systems is a risk management program (RMP) 
 that helps manage the risks at the WCF and that complies with the requirements of the 
 Environmental Prot 
ection Agency's (EPA's) rule 40 CFR part 68, Accidental Release 
 Prevention Requirements:  Risk Management Programs (the RMP rule). One of the 
 requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the 
 risk management program at WCF.  This document is intended to satisfy the RMP Plan 
 executive summary requirement of the RMP rule and to provide the public with a description 
 of the risk management program at the Woodhaven Cavern Facility. 
 1.1  Accidental Release Prevention and Emergency Response Policies 
      WCF has a long-standing commitment to the safety of the public, its employees and 
      contractors and to the preservation of the environment.  One primary element of this 
      commitment is the prevention of accidental releases of hazardous substances in and 
      around the facility.  WCF utilizes engineering controls, inspection programs, and 
      detailed procedures as a means to prevent accidental releases. 
      In the even 
t of a release, as a non-responding facility, WCF personnel are instructed 
      to dial  911 to notify the Woodhaven Fire Department via telephone to  respond and 
      to mitigate the release.  WCF has coordinated emergency response to the facility with 
      the Woodhaven Fire Department.  In conjunction with the Wayne County local 
      emergency planning committee (LEPC), the Woodhaven Fire Department  has the 
      ability to notify the local community through media broadcasting systems.  
      The MAPL Eastern District Manager has overall responsibility for the development 
      and implementation of the risk management program for the EPA-regulated process 
      at the WCF.  However, the specific responsibilities for certain aspects of that 
      program have been delegated to other personnel who report either directly, or through 
      other management personnel, to the Eastern District Manager.  Those relationships 
      are depicted on the Eastern District organi 
zation chart.  Specific responsibility for the 
      implementation of the WCF process safety management (PSM) and accident 
      prevention program has been delegated to the Woodhaven Area Supervisor, along 
      with responsibility for the RMP hazard assessment and risk management plan.  
      Technical support for the RMP hazard assessment and risk management plan was 
      assigned to Marathon Ashland Petroleum LLC's, Michigan Refining Division PSM 
      Coordinator.  The Eastern District's emergency response program, including 
      compliance with the RMP aspects of that effort, is the responsibility of the MAPL 
      Environmental and Safety Manager.  In keeping with our policy that safe operation 
      is part of everyone's job, many other WCF personnel are also involved in RMP 
      activities on an ongoing basis. 
 1.2  WCF Regulated Substances 
      WCF is a liquefied petroleum gas (LPG) storage facility with six underground 
      solution-mined storage caverns 
and five above ground storage vessels.  The storage 
      caverns are used to store flammable mixtures, primarily butane and propane, for use 
      in Marathon Ashland Petroleum LLC's Michigan Refining Division, Detroit 
      Refinery, or for LPG truck sales.  The flammable mixtures are covered under the 
      RMP rule and are present at the WCF above the EPA threshold quantity of 10,000 
      WCF has no toxic substance regulated by the RMP rule in sufficient quantity to be 
      covered by the RMP rule. 
 1.3  Offsite Consequence Analysis 
      MAPL performed an offsite consequence analysis to estimate the potential for an 
      accidental release of a regulated substance that could affect the public or the 
      environment.  The offsite consequence analysis consisted of evaluating both worst-case scenarios and alternative release scenarios.  MAPL does not expect a worst-case 
      release scenario to ever occur.  An alternative release scenario represent 
s a release 
      that might occur during the lifetime of a facility like WCF. Alternative release 
      scenarios can be used to help the LEPC and Woodhaven Fire Department improve 
      the community emergency response plan.  We have submitted release scenarios to 
      EPA, and have shared that information with the LEPC and other organizations 
      involved in emergency response activities. It is also available to local residents and 
      businesses.  If you are interested in this information, please contact the Woodhaven  
      Cavern Facility at (734) 676-7775 and ask for the Woodhaven Area Supervisor. 
      The paragraphs below briefly describe some of the scenarios we analyzed and are the 
      scenarios for which we have included detailed information in our risk management 
      plan.  Please recognize that none of these events have occurred at our facility.  Also, 
      for some of these events, we have emergency mitigation systems that could help 
      reduce t 
he consequences of the events if they occurred.  In all cases, if such events 
      occurred, WCF would notify the Woodhaven Fire Department via telephone, by 
      dialing 911, and take appropriate actions to protect our employees. 
      Worst-case Release Scenario 
      Because WCF has no toxic substances regulated by the RMP rule in sufficient 
      quantity to be covered by the RMP rule, the risk management plan does not include 
      a worst-case scenario associated with toxic substances. 
      As no single Worst-case Scenario (WCS) encompasses all potential Worst-case 
      Release Scenarios, six WCS must be reported.  Failure of piping could result in the 
      release of 706,000 pounds of flammables consisting mainly of butane or 609,000 
      pounds of mainly propane.  The analysis assumes each release completely vaporizes 
      and ignites, resulting in a vapor cloud explosion. Because there are some public 
      receptor locations just outside the WCF proper 
ty, this event could affect members of 
      the public at those closest locations. 
      There are no Program 1 processes at the WCF, therefore, no additional worst-case 
      analyses are reported for such processes.  Also, WCF did not identify any worst-case 
      scenarios that would affect public receptors other than the receptors affected by the 
      scenarios reported above. 
      Alternative Release Scenario 
      Because WCF has no toxic substances regulated by the RMP rule in sufficient 
      quantity to be covered by the RMP rule, the risk management plan does not include 
      an alternate release scenario associated with toxic substances 
      The alternative case scenario in our risk management plan for flammable substances 
      at the WCF is from a failure of a vessel containing propane.  The failure would 
      release 36,700 pounds of flammable material.  The analysis assumed that all of this 
      material would be involved in a Boiling Liquid Ex 
panding Vapor Explosion 
      (BLEVE) and showed that the fire hazard resulting from the explosion would affect 
      public receptor locations outside of the WCF. 
      As stated previously, we have included details regarding these scenarios in the 
      additional information submitted to the EPA with this executive summary, and have 
      shared that information with the LEPC, other organizations involved in emergency 
      planning, and members of the local community.  If you are interested in this 
      information, please contact the WCF at (734) 676-7775 and ask for the Woodhaven 
      Area Supervisor. 
 1.4  Accidental Release Prevention Program 
      The following is a summary of the general accident prevention program in place at 
      the Woodhaven Cavern Facility. Because processes at the WCF that are regulated by 
      the EPA RMP regulation are also subject to the Occupational Safety and Health 
      Administration (OSHA) process safety management (PSM) sta 
ndard, and because 
      the OSHA PSM requirements are very similar to the EPA RMP requirements, this 
      summary addresses each of the OSHA PSM elements.  The PSM program at this 
      facility has been extended by the WCF, where necessary, to satisfy EPA's Program 
      Level 3 accident prevention program requirements. 
      Employee Participation 
      WCF encourages employees to participate in all facets of process safety management 
      and accident prevention.  Examples of employee participation range from updating 
      and compiling technical documents and chemical information to participating as a 
      member of a process hazard analysis (PHA) team, incident investigation, and 
      compliance audit teams.  Employees have access to all information created as part 
      of  WCF's accident prevention program. Specific ways that employees can be 
      involved in the accident prevention program are documented in an employee 
      participation plan that is main 
tained at  WCF.  In addition, WCF has a number of 
      initiatives that address process safety and employee safety issues.  These initiatives 
      include teams which promote both process and personal safety, such as the 
      Woodhaven Area Safety Management Group, the Woodhaven Area Training 
      Management Group, and monthly Safety and Operations Meetings with management 
      and hourly employees. Management groups typically have members with various 
      areas of expertise, including operations, maintenance, and management. 
      Process Safety Information 
      WCF keeps a variety of technical documents at the WCF that are used to help 
      maintain safe operation of the process.  These documents address chemical properties 
      and associated hazards, limits for key process parameters and specific chemical 
      inventories, and equipment design basis/configuration information.  Specific WCF 
      Operations personnel are assigned responsibility for maintaini 
ng up-to-date process 
      safety information.  A table summarizing the reference documents and their location 
      is readily available as part of the WCF Operations Manual to help employees locate 
      any necessary process safety information. 
      Chemical-specific information, including exposure hazards and emergency 
      response/exposure treatment considerations, is provided in material safety data sheets 
      (MSDSs).  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, WCF has documented safety-related 
      limits for specific process parameters (e.g., temperature, level, composition) in the 
      WCF Operations Manual. WCF ensures that the process is maintained within these 
      limits by using process controls and monitoring instruments, operating procedures, 
      highly trained personnel, 
and protective instrument systems (e.g., automated 
      shutdown systems). 
      WCF also maintains numerous technical documents that provide information about 
      the design and construction of process equipment.  This information includes 
      materials 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. 
      Process Hazard Analysis 
      WCF has a comprehensive Process Hazard Analysis (PHA) program to help ensure 
      that hazards associated with the process are identified and controlled.  Within this 
      program, the covered process and future processes are systematically examined to 
      identify hazards and e 
nsure that adequate controls are in place to manage those 
      WCF primarily uses the hazard and operability (HAZOP) analysis technique to 
      perform this evaluation.  HAZOP analysis is recognized as one of the most 
      systematic and thorough hazard evaluation techniques available.  The analysis is 
      conducted using a team of people who have operating and maintenance experience 
      as well as engineering expertise.  This team identifies and evaluates hazards of the 
      process as well as recommends accident prevention and/or mitigation measures when 
      the team believes such measures are necessary. 
      The PHA report is forwarded to the MAPL Eastern District Manager to review and 
      approve. A schedule is developed to address the PHA team's recommendations 
      (Action Items) in a timely and prioritized manner.  The final resolution and 
      completion of each Action Item is documented and retained at the WCF by 
      designated Op 
erations personnel. 
      To help ensure that the process controls and/or process hazards do not eventually 
      deviate significantly from the original design safety features, WCF periodically 
      updates and revalidates the Woodhaven Cavern Facility PHA. These periodic 
      reviews are conducted at least every five years and will be conducted at this 
      frequency until the process is no longer operating.  The PHA Team has considered 
      offsite effects of potential releases as part of  all PHA updates completed after 
      August, 1996.  The results and recommendations from these updates are documented 
      and retained.  Once again, the team findings are forwarded to management for 
      consideration, and the final resolution of the recommendations is documented and 
      Operating Procedures 
      WCF  maintains written procedures that address various modes of process operations, 
      such as (1) unit startup, (2) normal operations, (3) t 
emporary operations, (4) 
      emergency shutdown, (5) normal shutdown, and (6) 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.  Procedures are periodically reviewed 
      by a designated group of Operations personnel and annually certified by the 
      Woodhaven Area Supervisor as current and accurate. Procedures are maintained 
      current by revising them as necessary to reflect changes made to the process.  In 
      addition, the WCF operating procedures provide guidance on how to respond to 
      events that result in exceeding safe operating limits for specific process or equipment 
      parameters. The written operating procedures are readily available to the on-duty 
      WCF Operator and for other personnel to use as necessary to safely perform their job 
      To complement the written procedures for proce 
ss operation, WCF has implemented 
      a training program for all employees involved in operating the Woodhaven Cavern 
      Facility. New employees receive orientation training, which includes, but is not 
      limited to, the following topics:  Process Overview, Employee Involvement, General 
      Safety Rules, Safe Work Permit, Lockout/Tagout, Blinding and Line Breaking, and 
      the Safe Handling of LPG.  After successfully completing this training, a WCF 
      Operator Trainee is paired with a qualified WCF Operator to learn process-specific 
      duties and tasks.  Trainees spend time with all qualified WCF Operators before 
      training is complete.  After trainees demonstrate (e.g., through tests, skills 
      demonstration) having adequate knowledge to perform the duties and tasks in a safe 
      manner on their own, the trainee's performance and knowledge are reviewed by 
      qualified WCF Operators and a vote is taken to determine if he/she is qualified to 
   operate the Woodhaven Cavern Facility. 
      In addition, all WCF Operators periodically receive refresher training on operating 
      procedures to ensure that their skills and knowledge are maintained at an acceptable 
      level. This refresher training is conducted at least every 3 years.  Operators are given 
      the opportunity to take part in more frequent refresher training if desired.  All of this 
      training is documented for each operator, including the means used to verify that the 
      operator understood the training. 
      WCF uses contractors at the WCF to supplement its work force during periods of 
      increased maintenance or construction activities.  Because some contractors work on 
      or near process equipment, WCF has procedures in place to ensure that contractors 
      (1) perform their work in a safe manner, (2) have the appropriate knowledge and 
      skills, (3) are aware of the hazards in their workplace, (4) unde 
rstand what they 
      should do in the event of an emergency, (5) understand and follow site safety rules, 
      and (6) inform WCF personnel of any hazards that they find during their work. This 
      is accomplished by providing contractors with (1) a process overview, (2) 
      information about safety and health hazards, (3) emergency response plan 
      requirements, (4) safe work practices, and (5) a work permit process (i.e., for hot 
      work, confined space, etc.) prior to their beginning work. In addition, WCF evaluates 
      contractor safety programs and performance during the selection of a contractor.  
      WCF personnel periodically monitor contractor performance to insure that 
      contractors are fulfilling their safety obligations. 
      Pre-startup Safety Review 
      WCF conducts a pre-startup safety review for any new facility or facility 
      modification that requires a change in the process safety information (not required 
      for replaceme 
nt in kind).  The purpose of the review is to ensure 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 review uses checklists to verify all 
      aspects of readiness.  A review involves field verification of the construction and 
      serves a quality assurance function. 
      Mechanical Integrity 
      WCF has well-established practices and procedures to maintain pressure vessels, 
      piping systems, relief and vent systems, controls, pumps and compressors, and 
      emergency shutdown systems in a safe operating condition.  The basic aspects of this 
      program include:  (1) conducting training, (2) developing written procedures, (3) 
      performing inspections and tests, (4) 
correcting identified deficiencies, and (5) 
      applying quality assurance measures. In combination, these activities form a system 
      that maintains the mechanical integrity of the process equipment.  
      Maintenance personnel receive training on (1) an overview of the process, (2) safety 
      and health hazards, (3) applicable maintenance procedures, (4) emergency response 
      plans, and (5) applicable safe work practices to help ensure that they can perform 
      their job in a safe manner. Written procedures help ensure that work is performed in 
      a consistent manner and provide a basis for training. Inspections and tests are 
      performed to help ensure that equipment functions as intended, and to verify that 
      equipment is within acceptable limits (e.g., adequate wall thickness for pressure 
      vessels).  If a deficiency is identified, employees will correct the deficiency before 
      placing the equipment back into service (if possible), or a  
management of change 
      team will review the use of the equipment and determine what actions are necessary 
      to ensure the safe operation of the equipment. 
      Another integral part of the mechanical integrity program is quality assurance. WCF 
      incorporates quality assurance measures into equipment purchases and repairs.  This 
      helps ensure that new equipment is suitable for its intended use and that proper 
      materials and spare parts are used when repairs are made. 
      Safe Work Practices 
      WCF has long-standing safe work practices in place to help ensure worker and 
      process safety. Examples of these include (1) control of the entry/presence/exit of 
      support personnel, (2) a lockout/tagout procedure to ensure isolation of energy 
      sources for equipment undergoing maintenance, (3) a procedure for safe removal of 
      hazardous materials before process piping or equipment is opened, (4) a permit and 
      procedure to co 
ntrol welding and other spark-producing activities, and (5) a permit 
      and procedure to ensure that adequate precautions are in place before entry into a 
      confined space.  These procedures (and others), along with training of affected 
      personnel, form a system to help ensure that operations and maintenance activities 
      are performed safely. 
      Management of Change 
      WCF 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 (1) ensure that adequate controls are in place to manage any new hazards and (2) 
      verify that existing controls have not been compromised by the change.  Affected 
      chemical hazard information, process technology information, and equi 
      information, as well as procedures are updated to incorporate these changes.  In 
      addition, operating and maintenance personnel are provided with any necessary 
      training on the change. 
      Incident Investigation 
      WCF promptly investigates all incidents that resulted in, or reasonably could have 
      resulted in, a fire/explosion, major property damage, environmental loss, or personal 
      injury.  The goal of each investigation is to determine the facts and develop 
      corrective actions to prevent a recurrence of the incident or a similar incident.  The 
      investigation team, which may include contractors, documents its findings, develops 
      recommendations to prevent a recurrence, and forwards these results to WCF 
      management for resolution. Corrective actions taken in response to the investigation 
      team's findings and recommendations are tracked until they are complete.  The final 
      resolution of each finding or rec 
ommendation is documented, and the investigation 
      results are reviewed with all employees (including contractors) who could be affected 
      by the findings.  Incident investigation reports are retained for at least 5 years so that 
      the reports can be reviewed during future PHAs and PHA revalidations. 
      Compliance Audits 
      To help ensure that the accident prevention program is functioning properly, WCF 
      periodically conducts audits to confirm the procedures and practices required by the 
      accident prevention program are being implemented. Compliance audits are 
      conducted at least every 3 years.  These audits may be led by a third party contractor 
      with assistance by WCF employees as required.  The findings are forwarded to WCF 
      management for resolution.  Corrective actions taken in response to the audit team's 
      findings are tracked until they are complete.  The final resolution of each finding is 
      documented, and the  
two most recent audit reports are retained. 
1.5    Chemical-specific Prevention Steps 
      The process at WCF has hazards that must be managed to ensure continued safe 
      operation. The accident prevention program summarized previously is applied to all 
      EPA RMP-covered processes at the WCF.  Collectively, these prevention program 
      activities help prevent potential accident scenarios of flammable substances caused 
      by equipment failures or human errors. 
      In addition to the accident prevention program activities, WCF has safety features in 
      many areas to help (1) contain/control a release, (2) quickly detect a release, and (3) 
      reduce the consequences of a release.  The following types of safety features are 
           Release Detection 
           Hazardous atmosphere detectors at the cavern wellheads, brine tank dike, 
           above ground vessel area, manifold area, dryer area and brine pump sump. 
           Pressure s 
witches on truck loading systems that alarm when pressure 
           decreases to a pre-set amount. 
           Release Containment/Control 
           Process relief valves that discharge to the brine tank's LPG ignition system 
           to capture and incinerate process materials to prevent over pressure damage 
           to equipment 
           Manual and automatic valves to permit isolation of the process; 
           Automated shutdown systems for specific process parameters (e.g., high 
           level, high temperature); 
           Redundant equipment and instrumentation where needed (e.g., 
           uninterruptible power supply for some critical process control system, 
           redundant firewater pumps, electric and diesel); 
           Fire suppression and extinguishing systems (deluge system, fire monitors and 
           Personal protective equipment (e.g., protective clothing, self-contained 
           breathing apparatus); and 
           A system capable of shutting down all products movement and alerting 
 1.6  Five-year Accident History 
      One release of a regulated substance has occurred from the WCF in the last 5 years 
      that resulted in an on-site injury.  There have been no known deaths, injuries, 
      evacuations, sheltering-in-place, property damage, or environmental damage off site. 
 1.7  Emergency Response Program Information 
      As a non-responding facility, the Woodhaven Fire Department provides and 
      coordinates emergency response  for releases of RMP regulated substances for WCF.  
      WCF handles incidental releases with their own personnel.  WFC's emergency action 
      plan contains procedures for notifying the Woodhaven Fire Department of a release. 
      To keep the emergency action plan current, WCF provides the Woodhaven Fire 
      Department a facility tour and update briefing, typically on an annual basis, or when 

 1.8  Planned Changes to Improve Safety 
      WCF constantly strives to improve the safety of its operations through periodic 
      safety reviews, the incident investigation program, and soliciting safety suggestions 
      from employees.  WCF resolves all findings from PHAs, some of which result in 
      modifications to the process.  The following types of changes are planned during the 
      next 5 years: 
      Evaluation of process instrumentation at the propane dryer; 
      Re-evaluation of fire hydrant/monitor location; and 
      Continuous improvements of personnel training programs.
Click to return to beginning