Sunoco, Inc. (R&M) - Philadelphia Refinery - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Sunoco, Inc. (R&M), hereafter referred to as Sunoco, we believe that excellent performance in health, environmental and safety goes hand in hand with operating reliability, and that outstanding performance in both areas is required to achieve financial success. Our company adheres to the guidelines of the Coalition for Environmentally Responsible Economies (CERES)--a comprehensive environmental code of conduct for corporations. The Sunoco Philadelphia Refinery plays a major role in supporting this environmental commitment. The refinery is designed, operated and maintained in a manner that protects the environment, as well as the health and safety of its employees and the community. We promote health, environment and safety through programs of awareness, compliance, prevention and protection. These programs include a combination of accidental release prevention programs and emergency response planning programs. Thi s document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: A description of our facility and the use of substances regulated by EPA's RMP rule A summary of results from our assessment of the potential off-site consequences from accidental chemical releases An overview of our accidental release prevention programs A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule An overview of our emergency response program The certifications that EPA's RMP rule requires us to provide The detailed information (data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES The Sunoco Philadelphia Refinery is located on approximately 1000 acres on the east bank of the Schuylkill River in Philadelphia. The facility consists of two general areas: the first, referred to as Point Breeze is the former ARCO-Atlantic refinery acquired by Suno co in 1988; the second, Girard Point, is the former Gulf-Chevron refinery acquired in 1994. Today, it is operated as a fully integrated petroleum refining complex capable of processing 330,000 barrels per day of crude oil into various petroleum products including: gasoline, home and industrial heating fuels, jet fuel, liquefied petroleum gases (LPG), residual fuel and a number of petrochemicals such as benzene, propylene, and cumene. The types of processing units in operation at the refinery include: atmospheric and vacuum crude distillation, fluid catalytic cracking, catalytic reforming, distillate desulfurization, alkylation, sulfur recovery, petrochemical recovery, and gasoline treating and blending. In support of these processes, the refinery also operates steam generation, water treating, wastewater treatment, tank car and truck loading facilities and numerous intermediate and finished product storage tanks. Sunoco also owns and operates the 211 acre Schuylkill River Tank F arm (SRTF) located on the west bank of the Schuylkill River, opposite the refinery property. The facility functions only as a product storage and shipping area and contains no refining units. On-site are numerous intermediate and finished product storage tanks, an API-type separator, gasoline blending facilities, and an LPG tank car and truck loading area. Our refining processes use the following chemicals that EPA has identified as having the potential to cause significant off-site consequences in the event of a major accidental release: Hydrogen fluoride - 396,000 lbs* - used as Alkylation Unit catalyst Propane - 2,880,000 lbs - stored for commercial fuel sales Butane - 32,200,000 lbs - used as a gasoline blending component Isobutane - 7,200,000 lbs - used as a gasoline blending component and intermediate feedstock Flammable mixture (contains: propane and propylene) - 1,320,000 lbs - used as a petrochemical feedstock Flammable mixture (may contain: 1-butene, 2-bute ne, 2-butene-cis, 2-butene-trans, 1-pentene, butane, butene, ethane, ethylene, hydrogen, isobutane, isopentane, methane, pentane, propane, propylene) - 6,700,000 lbs - used as intermediate feedstocks for refinery processing * All numbers reported in the executive summary are calculated values. Numerical results of the RMP*SUBMIT database may differ because of EPA rounding rules. These chemicals are used in one or more of our fourteen (14) refinery processes covered by the RMP rule. Our accidental release prevention programs and emergency planning and response programs help us effectively manage the hazards posed by these chemicals to our employees, the public, and the environment. OFFSITE CONSEQUENCE ANALYSIS SCENARIOS The RMP rule requires that we provide information on the worst-case release scenarios and alternative release scenarios for our facility. The following are summaries of these scenarios, including information about the key administrativ e controls and mitigation measures employed to limit exposure distances for each case. Worst-case Release Scenario - Regulated Toxic Chemicals This highly improbable scenario involves the catastrophic rupture of a storage drum containing 396,000 lbs (47,124 gallons) of hydrogen fluoride. This quantity is the maximum amount of hydrogen fluoride held in the Hydrogen Fluoride Alkylation Unit (HFAU) storage drum during a Plant Maintenance Turnaround. These planned Turnarounds occur approximately once every three years for a six week period; they involve transferring the unit's entire acid inventory into one vessel, so that extensive maintenance may be performed on the operating vessels. The acid drum is a 1 5/8 inch thick high grade steel vessel equipped with indicating instruments and pressure safety relief valves. EPA's "Offsite Consequence Analysis (OCA) Guidance" was utilized to predict the release consequences. The OCA guidance is formatted in "Look-up tables," that predict the distance to a 20 ppm (ERPG-2) toxic concentration after releasing the drum's maximum liquid inventory as a vapor over a 10 minute period. The release occurs during the worst possible weather conditions (low wind speed, low humidity). As an absolute worst case release, this event would have offsite consequences, reaching a 20 ppm toxic concentration at a significant offsite distance. The OCA guidance does not permit the use of active mitigation systems to minimize the release. Though no accident prevention or mitigation measures were applied to our worst-case scenario, prevention programs do exist to minimize the impacts. Our HFAU acid equipment is designed, maintained and tested per American Petroleum Institute Recommended Practice 751 (API RP-751). API RP-751 recommends design, maintenance and testing criteria that, in general, exceeds that applied to other refinery processing units. The HFAU is also equipped with a multitude of mitigation systems including: HF sensing det ectors, emergency isolation valves, water cannons, television surveillance cameras, spill containment and a rapid de-inventory system. A combination of these prevention programs and our emergency planning and response programs would significantly decrease the probability and impacts of a release. Alternative Release Scenario - Regulated Toxic Chemicals This more likely scenario involves a hydrogen fluoride leak in the piping between two acid vessels in the HFAU. Facility Engineers and Operators developed the hypothetical scenario after lengthy discussions, and a review of the unit's mechanical integrity, operating and accident history. The technical team postulated, that as a result of corrosion, a small leak could develop in the miter joint of a 1/2 inch thick acid pipe between two acid vessels. This release scenario was simulated using a commercially available and industry recognized computer model called PHAST (Process Hazard Analysis Software Tool). PHAST is a software too l that calculates the consequences of accidental or emergency atmospheric releases of toxic or flammable chemicals. It uses mathematical models of discharge, dispersion, fire and explosion to predict toxic and flammable effects. When site specific factors are known and understood, as in our case, PHAST results in a better understanding of the release effects. Where site specific factors are not well understood, assumptions built into the OCA Guidance compensates for these unknowns and result in a reasonable, although conservative, reporting of the release effects. For the past few years our facility has used PHAST to model dispersion data for prevention and emergency response planning. PHAST modeled the alternative release scenario as an 873 lb release to a 20 ppm toxic concentration endpoint. The release was modeled using typical operating and meteorological data collected at the refinery. The following accident prevention and mitigation measures were applied to the scenario to minimize consequences of the release. The unit's HF sensing detectors and television surveillance cameras would immediately alert operating personnel that a release had occurred. At this time, the emergency isolation valves and the rapid de-inventory system would be activated to evacuate the acid out of the leaking pipe to a storage drum, this procedure would limit the release to a 24 minute period. During the de-inventory the water cannons would be activated to knockdown approximately 90% of the released vapor. The combined actions of our trained personnel and activation of our prevention systems would limit the release consequences to a nine minute 20 ppm toxic concentration just outside the facility fenceline. Worst-case Release Scenario - Regulated Flammable Chemicals Butane storage spheres are operated at several locations throughout our facility. A release and subsequent ignition of the material from any one of these spheres could impact different sectors of our s urrounding community. For this reason, our flammable worst case scenario could involve the catastrophic rupture of any one of four butane storage spheres containing inventories of 1.5 to 9.5 million lbs of butane. EPA's "Offsite Consequence Analysis (OCA) Guidance" was utilized to predict the release consequences. The OCA guidance is formatted in "Look-up tables" that predict the distance to a 1 psig explosion overpressure after the instantaneous vaporization and ignition of the entire liquid inventory of the sphere. This instantaneous vaporization of these large liquid quantities of butane make these scenarios highly improbable. The release occurs during the worst possible weather conditions (low wind speed, low humidity). As absolute worst case releases, these events would have offsite consequences, reaching a 1 psig explosion overpressure at significant distances. The OCA guidance does not permit the use of active mitigation systems to minimize the release. Though, no acci dent prevention or mitigation measures were applied to the worst-case scenarios; prevention programs do exist to minimize the impacts. These storage spheres are built to a national code (American Society of Mechanical Engineers) and are routinely inspected, tested and maintained by trained personnel. All of the storage spheres are equipped with redundant pressure safety relief valves, level and pressure indications and alarms, and automatic or manual water spray systems. Three of the spheres have automatically activated emergency shutdown valves and hydrocarbon sensing detectors. Plans are under review to install these systems on the fourth sphere. These prevention programs and our emergency planning and response programs would significantly decrease the probability and impacts of release and ignition. Alternative Release Scenario - Regulated Flammable Chemicals The flammable more likely scenario is modeled after an actual incident that occurred in September of 1992. The incid ent investigation revealed that several butane tankcars were mistakenly offloaded into the wrong storage sphere. The storage sphere overfilled, and high pressure in the vessel lifted the pressure safety relief valve (PSV) releasing 40,000 lbs of butane to atmosphere. This release scenario was simulated using a commercially available and industry recognized computer model called PHAST (Process Hazard Analysis Software Tool). PHAST is a software tool that calculates the consequences of accidental or emergency atmospheric releases of toxic or flammable chemicals. It uses mathematical models of discharge, dispersion, fire and explosion to predict toxic and flammable effects. When site specific factors are known and understood, as in our case, PHAST results in a better understanding of the release effects. Where site specific factors are not well understood, assumptions built into the OCA Guidance compensates for these unknowns and result in a reasonable, although conservative, report ing of the release effects. For the past few years our facility has used PHAST to model dispersion data for prevention and emergency response planning. PHAST modeled the alternative release scenario to determine consequence distances to the lower flammability limit, a 1 psig explosion overpressure, and a 5 kW/sq.m radiant heat exposure for a 40 second period. The release was modeled using operating data from the incident investigation, and typical meteorological data collected at the refinery. Other than the activation of the PSV, no other accident prevention or mitigation measures were simulated in the computer model. Today, this overfill scenario would be unlikely due to improvements in the prevention program. These include: improved operating procedures, multiple level and pressure indications and alarms on the sphere, and automatically activated valves that stop flow to the vessel if a high level is reached. If this scenario were to occur, the combined actions of our train ed personnel and activation of our prevention systems would limit the consequences of an explosion overpressure and radiant heat exposure to just outside the facility fenceline. GENERAL ACCIDENTAL RELEASE PEVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION MEASURES The centerpiece of our release prevention program is Process Safety Management (PSM). A management system assigns PSM responsibilities to specific individuals. The fourteen elements of the PSM program listed below constitute the framework by which process safety and accident prevention are managed in the refinery. PSM Prevention Program Elements Process Safety Information A Process Safety Information (PSI) manual is produced for each PSM-covered process and is made available to all personnel involved with or affected by that process. The manual lists the hazards of the chemicals used or produced by the process and provides information on the technology and equipment in the unit. Process Hazards Analysis Process Hazards Analyses (PHA's) are performed by experienced employee teams for each process covered by PSM. These comprehensive studies are used to identify and assess hazards in the design or operation of the process units. Additional controls are recommended for any unmitigated hazards that are identified. Results of the PHA's are documented in manuals that are maintained onsite for the life of the processes. The manuals are duplicated and made available to personnel. Operating Procedures Written operating procedures are developed and implemented for all refinery processes. The procedures, written by experienced operating personnel and reviewed by a technical committee, provide clear step-by-step instructions on the safe and environmentally sound operation of each process unit. Procedures exist for operating duties during normal modes of operation as well as for emergency response and shutdown scenarios. Training The Training Department provides classroom and on-the- job training for all personnel responsible for the operation of the process units. Classroom training covers information on the process, equipment and operating procedures. On-the-job training provides an opportunity for the employee to practice actual duties and responsibilities. Written, verbal and hands-on testing is performed to validate that training requirements have been met. Mechanical Integrity The mechanical integrity of PSM equipment is routinely monitored, inspected and tested to make sure that the potential for spills and releases is minimized. The Mechanical Integrity Department employs both industry and company standards to evaluate equipment condition. PSM equipment is also maintained according to written maintenance procedures by a trained maintenance staff. Management of Change Written procedures have been established and implemented to manage changes to process chemicals, technology, equipment, procedures or facilities that affect a covered process. Th e Management of Change procedure provides guidance, designates responsibilities and establishes steps to implement the program. Results of the Management of Change process are documented, maintained and made available to all personnel. Pre-startup Safety Review Pre-startup Safety Reviews are performed by experienced teams in order to confirm that new or modified process facilities are safe to operate. The unit's construction specifications, emergency plans, and employee training and procedure requirements are reviewed and documented before placing the unit in operation. Compliance Audits A formal evaluation and certification of the PSM system is conducted at least every three years by a Corporate audit team. In the refinery, the Process Safety Coordinator is responsible to ensure that the procedures and practices developed under the PSM system are being followed. Incident Investigation Incidents that result in, or could reasonably have caused, catastrophic release, fire or injury are promptly investigated by an experienced team. A systematic investigation process is used to determine the root cause of an event. The investigation team then recommends and implements additional controls in order to mitigate hazards associated with the incident. Incident causes are tracked, trended and published by the Safety Department. The published reports are shared with employees. Employee Participation Employee participation is based on the principle that employee involvement in various areas of PSM is key to maintaining a Process Safety system that has an "our" attitude. Employees are involved in: Health and Safety committee activities, safety meetings, Process Hazard Analysis studies, pre-startup safety reviews, incident investigations, and the development of operating and maintenance training and procedures. Hot Work Permit Hot work permits are issued for any work that could create a source of ignition on or near a PSM-covered process unit. The permit describes work being performed, authorized dates and all fire prevention and protection requirements. Contractors The refinery employs contractors to supplement its work force during periods of increased maintenance or construction activities. Contractor safety procedures are coordinated and implemented by the Refinery Contractor Representative. Safety regulations are sent with all bid packages, and an evaluation of the contractors safety record and training program is used in selecting the successful contracting company. The safety regulations require contractors to train their employees in the safe work practices and safety rules of the refinery. Contractors are also required to report any safety hazards that the contract work may cause for the facility or any hazards found by the contract employees. Emergency Response The Philadelphia Refinery Emergency Response Plan assures the readiness of employees to respond appropriately and safely to emergencies invo lving highly hazardous chemicals. The Emergency Response Plan is an integrated set of actions that start at the incident source, and initiates actions throughout the facility as appropriate. Additional details about our Emergency Response Program are presented later in this document. Trade Secrets Sunoco openly provides all information necessary to comply with the above PSM elements to those persons responsible for compiling the information. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standards required by these management systems. In addition to the above prevention program elements, we also have specific prevention measures that are employed as part of our operating procedures and administrative controls. These are briefly summarized as follows: GENERAL RISK REDUCTION AND SAFETY MEASURES Engineering and construction in accordance with recognized industry a nd company standards Equipment designed with pressure safety relief valves Updated technical drawings, Piping & Instrument Diagrams and Process Flow Diagrams Operating systems monitored and controlled 24 hrs a day by trained Operators Computerized monitoring and control of process operation Television surveillance capabilities Redundant control systems with battery back-ups System of automatic and manual shutdown devices for critical systems Scheduled inspection and testing of instruments, analyzers, and safety interlocks Testing and inspection of all boilers by state inspectors on a scheduled basis Quality control laboratory to ensure accurate unit operation Vehicular traffic prohibited from critical areas Limited facility access and 24 hr security force Radio communication system Regular safety meetings and safety awareness programs Routinely scheduled safety inspections Safety showers and eyewash stations located in process units Self contained brea thing apparatus located in process units Substance abuse program and random drug testing On-site medical facility staffed with full-time doctor and nurses GENERAL RELEASE MITIGATION Minimization of toxic chemical inventories Dikes and curbing to minimize the spread of released material Automatic and remotely operated shut-offs to limit release quantity Strategically located valves to isolate leaks Hydrocarbon and toxic gas detectors at key areas to warn of a chemical release Water sprays to contain vapor clouds and cool high temperature equipment Flame detectors and heat sensors in critical fire hazard areas Automated water sprays and fixed fire monitors for fire control Sophisticated chemical release dispersion modeling capabilities at the facility GENERAL EMERGENCY RESPONSE Emergency Management System to manage and coordinate emergencies Emergency Response Team specializing in fire control, spill control, medical emergency response, r escue and HAZMAT Periodic emergency training for employees Emergency alert system Communication systems with local emergency responders and regulatory agencies Emergency drills with plant personnel and community emergency responders Fleet of emergency response apparatus specially designed for industrial fire protection Mutual Aid agreement with other refineries Participation with the Philadelphia Local Emergency Planning Committee (LEPC) FIVE YEAR ACCIDENT HISTORY The Sunoco Philadelphia Refinery keeps records for all significant accidental chemical releases that occur at our facility. During the past five years, we have had four accidents resulting from the chemical release of materials covered under EPA's RMP rule. All the accidents occurred in the Hydrogen Fluoride Alkylation Unit and involved the release of small quantities of hydrogen fluoride (H F) during maintenance activities. The accidents are deemed RMP-reportable because the releases resulted in onsite personnel injuries that required medical treatment. The most recent accident occurred on March 13, 1997, to an Operator who was cleaning a filter in a non-acid flush system. A small amount of HF was entrained in the system and upon release burned the Operator on the neck and arm. The second accident occurred on December 15, 1996, while a mechanic was opening a flange on a plugged line. A small quantity of HF unexpectedly drained out and burned the mechanic on the knee. Another accident occurred on October 06, 1996. During Turnaround maintenance activities, a temporary plug blew out of a leaking exchanger that was pressured up with nitrogen. The nitrogen was entrained with some HF left in the vessel after the cleaning procedure. A mechanic standing in front of the plug was burned on the neck by the released acid vapors. The final accident occurred on October 14, 1995, to an Operator who was checking the pH of a condensate (water) vessel. As the Operator reached up to test the sample stream, hot condensate with entrained acid dripped on his arm. In all four cases the employee was not wearing adequate HF protective gear. Today, safety meetings and awareness programs stress the necessity of wearing acid protective gear while working on any equipment that may contain HF. Fortunately, the injured employees involved in these accidents required a minimum level of medical treatment (all employees were treated and returned to work for their next scheduled shift). EMERGENCY RESPONSE PROGRAM We maintain an integrated emergency response program, that consolidates all of the various federal, state, and local regulatory requirements into a single consolidated plan. The plan is reviewed and updated on an annual basis, or more often if required. Our Emergency Response Plan provides the essential planning and training for protecting workers, the publi c, and the environment during emergency situations. Contained in the Plan are written procedures that outline the actions to be taken for various types of emergencies that could occur in the refinery. These emergencies include: airborne releases of chemical substances, spills to the water or ground, fires, explosions, personnel rescue incidents and medical emergencies. The Plan addresses all aspects of emergency response including: Information on the plant emergency organization (Incident Command System) Information on the roles and responsibilities of personnel responding to the incident Procedures for notifying employees that a release has occurred Procedures for plant evacuation and accounting of personnel Procedures to notify local emergency response organizations and other appropriate authorities that a release has occurred Guidance on proper first aid and medical treatment for exposures Procedures for post incident cleanup and decontamination Several metho ds are available to report an emergency in the refinery including telephones, fire pull boxes and radios. When an emergency call is received by telephone or radio, the dispatcher at Security Headquarters has the ability to activate alarms that signal various refinery personnel to take action. An alarm received by fire pull box is a general area alarm and first responders normally communicate by radio the details of the emergency upon arrival on the scene. The level of response to the emergency is then adjusted as appropriate to the incident. The dispatcher at Security Headquarters has the ability to pick up a direct dial telephone with the City of Philadelphia Fire Department to request assistance or advise on the status of an emergency in progress. This information would be used by the Fire Department and the Police Department to make decisions on advising the public to evacuate or shelter in place. A vitally important part of the plant emergency organization is the Emergency Response Team (ERT). The ERT is made up of full-time emergency response employees, as well as employee volunteers from various refinery departments. The ERT provides the personnel resources for a rapid and effective emergency response. While most refinery employees receive an "incipient responder" level of emergency response training, ERT members train and drill on a monthly basis. Training and drill sessions include instruction and practice in the use of fire extinguishers, advanced interior and exterior fire fighting techniques, hazardous material response, confined space and high angle rescue, emergency medical response, the Emergency Response Plan and implementation of the Incident Command System. The refinery also maintains its own dedicated emergency response equipment. This equipment includes portable fire extinguishers, breathing apparatus, encapsulated chemical protective suits, rescue and medical equipment, spill response boats and fire fighting apparatus capable of delivering high volumes of water and fire fighting foam. An inspection, testing and maintenance program is in place for emergency response equipment. Examples of equipment and systems included in the program are as follows; Fire extinguishers - Inspected monthly and receive annual maintenance per the fire code, Class A chemical suits - Inspected before and after each use, pressure tested quarterly (or more frequently if required, Fire hose - Inspected and pressure tested each year per the fire code, Stationary fire water pumps - Inspected weekly and performance tested each year per the fire code, Fire apparatus - Inspected weekly and performance tested each year, Water spray systems - Inspected and flow tested annually per the fire code. Inspection reports for emergency response equipment are filed with the City of Philadelphia. While we rely on incipient responders and the ERT to respond to both minor and significant events in the refinery, we also maintain a close relationship with the City of Philadelphia and neighboring municipal fire departments. Tours and drills with members of these emergency response organizations are held routinely. These tours and drills enable the public emergency responders to become familiar with the hazards, equipment, resources and personnel in the refinery. The Philadelphia Refinery belongs to the Tri-State Industrial Mutual Aid Organization (TSIMAO). The main purpose of TSIMAO is to commit equipment, fire fighting foam, and expertise to other members during an emergency. The refinery also has a representative on the Philadelphia Local Emergency Planning Committee. PLANNED CHANGES TO IMPROVE SAFETY We are continually striving to make the Sunoco Philadelphia Refinery a safe workplace for our employees, our neighbors and our community. Our focus is on the proactive management of our health, environmental and safety issues. For example, we revalidate the Process Hazard Analyses for approximately four process units each year. These analyses generate additional prevention and mitigation recommendations that result in ongoing modifications to the facility. In addition to the Process Hazard Analyses recommendations, the following list of improvements are being considered to help prevent and/or better respond to accidental chemical releases: HF Technical Review Team meets bimonthly to study, promote and initiate HF prevention and mitigation improvements Installation of a neighborhood emergency alert system Installation of emergency isolation valves on all LPG storage vessels Installation of additional water spray systems Automation of manually activated water spray systems Upgrades to emergency response apparatus The goal of the Sunoco Philadelphia Refinery is to demonstrate continuous improvement in our health, environmental and safety performance. In addition, we will work cooperatively with the community to address any concerns. Should there be any questions o r comments on the contents of our Risk Management Plan, please contact our Public Relations Manager, John McCann at (215) 339-7061. |