MI Refining Division, Woodhaven Cavern Facility - Executive Summary |
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MARATHON ASHLAND PIPE LINE LLC WOODHAVEN CAVERN FACILITY 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 pounds. 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 hazards. 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 retained. 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 tasks. Training 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. Contractors 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 pment 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 used: 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 hydrants); Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus); and A system capable of shutting down all products movement and alerting personnel. 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 requested . 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. |