ARCO Cherry Point Refinery - Executive Summary |
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EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The ARCO Cherry Point Refinery has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The ARCO Cherry Point Refinery, located in Blaine, WA, operates a variety of processes to produce petroleum products from crude oil. The refinery has several regulated flammables: isobutane, pentane, propane and a flammable mixture. In addition, the refinery uses ammonia, which is a regulated toxic substance. Other toxic substances common to refineries were evaluated. Hydrogen sulfide, sulfur dioxide and mercaptans do not exceed the T/Qs and therefore are not reported. The regulated processes consist of the following units: Crude/Vacuum Unit The Crude/Vacuum Unit consists of two processes. The Crude Unit consists of two basic processes, thermal fractionation and vacuum fractionation. The Crude Unit is the initial process unit in the refinery. It is designed to take raw crude oil, remove salt and sediment, then heat and fractionate the crude into finished and intermediate products. The Vacuum Unit is designed to process crude tower bottoms in the vacuum diesel fractionator (VDF) tower and the vacuum tower. Negative pressure, a vacuum, is required to fractionate this heavy material without forming coke. The Crude Unit is program 3 because of regulated flammable mixtures. #1 Reformer/Naphtha HDS Unit The #1 Reformer/Naphtha HDS Unit consists of two processes. The purpose of the #1 Reformer/Naphtha HDS Unit is to convert the low octane ga soline feed fractions from the Naphtha HDS and Hydrocracker units into a stabilized high octane blending stock. This is accomplished through the use of catalyst under high temperatures and a hydrogen atmosphere. The Naphtha Hydrosulfurization (HDS) Unit is designed to treat the feedstock for the #1 Reformer. Treatment is necessary to prevent contamination and plugging of the Reformer catalyst. The #1 Reformer/Naphtha HDS Unit is program 3 because of regulated flammable mixtures. Coker The Coker is a thermal cracking unit designed to receive and process vacuum residuum from the Crude unit which is separated into sweet dry gas, debutanized or depropanized gasoline, coker stove oil, light coker gas oil, heavy coker gas oil and coke. The Coker is program 3 because of regulated flammable mixtures. Diesel Hydro-Desulfurization Unit (DHDS) The Diesel Hydro-Desulfurization Unit (DHDS) is designed to remove impurities from coker stove oil and gas oil and to produce finished stove oil and dies el. The Diesel Hydro-Desulfurization Unit (DHDS) is program 3 because of regulated flammable mixtures. Hydrocracker The Hydrocracker is a combined hydrogenation and catalytic cracking process designed to convert low-grade gas oils to high quality gasoline and middle distillate products with a net consumption of hydrogen. The Hydrocracker is program 3 because of regulated flammable mixtures and toxic (ammonia). Light Ends Unit The Light Ends Unit is designed to process feed streams containing C5's and lighter hydrocarbons (pentane C5, butane C4, propane C3, ethane C2, and methane C1) and produce pentane, isobutane, normal butane and mixed butane for Storage and Handling. It also produces fuel gas, Hydrogen Plant feed or LPG feed for Unit 22. The Light Ends Unit is program 3 because of regulated flammable mixtures. #2 Reformer The purpose of the #2 Reformer is to convert the low octane gasoline feed fractions from the Naphtha HDS and Hydrocracking units into stabilized high octane blending stock. This is accomplished through the use of catalyst under high temperatures and a hydrogen atmosphere. The #2 Reformer is program 3 because of regulated flammable mixtures. Liquefied Petroleum Gas (LPG) Unit The Liquefied Petroleum Gas (LPG) Unit processes light end absorber release gas and produces fuel gas and propane. The Liquefied Petroleum Gas (LPG) Unit is program 3 because of regulated flammable mixtures. Storage and Handling The Storage and Handling area involves storing unit feeds and intermediates (Tank Farm-Unit 33), blending finished fuels and shipping to the Olympic Pipeline (Blender-Unit 36), receiving and shipping of unfinished products across the dock (Dock-Unit 34/35), and the storage and shipment of liquefied petroleum gas by rail and truck (Propane/Butane Loading -Unit 37). Storage and Handling is program 3 because of regulated flammable liquids. HAZARD ASSESSMENT RESULTS The worst-case scenario associated with toxic substances in Program 3 processes at the Cherry point Refinery is a catastrophic failure in the Hydrocracker, resulting in a release of 59,200 lb. of anhydrous ammonia over a 10 minute period. Although we have numerous controls to prevent such releases and to manage their consequences, no credit was taken for administrative controls or passive mitigation measures was taken into account evaluating this scenario. The maximum distance to the toxic endpoint of 200-ppm (0.14 milligrams per liter) for this worst case scenario is 2.8 miles. None of the other toxics at the Cherry Point Refinery exceed their T/Qs. The alternative case scenario for anhydrous ammonia is failure of a transfer hose line during transfer from a supply truck to our storage tank. This failure results in a release of 1,450 lb of anhydrous ammonia over a 10-minute period for a total release of 14,500 lb. The release period of 10 minutes might seem too little at first glance, however, the tank truck and discharge lines have excess flow valves, chec k valves and block valves. More likely these safety features would come into play before 10 minutes had elapsed. We also have 3 fire monitors that can be directed into the area for further mitigation. No credit was taken for this mitigation in calculating the alternate case scenario distance of 1.1 miles. The worst case scenario for a release of flammable substances in program 3 processes at the refinery is a vapor cloud explosion involving the full inventory of the largest storage tank containing isobutane. No administrative controls are in place to limit the storage inventory in the tank, therefore, the full tank inventory of 6,000,000 lb is assumed to release, completely vaporize, and ignite resulting in a vapor cloud explosion. The maximum distance to the 1-psi endpoint for this worst case scenario is 1.46 miles. Although we have controls to prevent such releases and to manage their consequences, no credit for mitigation measures was taken into account in evaluating this wor st case scenario. The alternate release scenario for flammable substances at the Cherry Point Refinery is a vapor cloud explosion resulting from the release of propane from a rail car damaged in an accident while being moved inside the refinery. Even though unlikely, the entire contents, 150,000 lb, of the rail car are lost over a 10-minute period. The maximum distance to the 1-psi endpoint for this event is 0.29 miles. This event was selected as being a more practical scenario for the Cherry Point Refinery. GENERAL ACCIDENT RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the ARCO Cherry Point Refinery. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. EMPLOYEE PARTICIPATION ARCO Cherry Point employ ees have always been encouraged to be involved in all aspects of operating this facility. Through the years, an open working relationship has developed between employer and employee. This relationship is evident in the employee involvement in many areas, such as the following: 1. Operations and Maintenance Procedures 2. Operations Manuals and Simplified Flow Diagrams 3. Training Programs 4. Process Hazards Analysis 5. Safety Committee 6. Emergency Response Team 7. Turnaround Planning 8. Contractors Safety Council 9. Prestart-up safety review 10. Incident Investigation 11. Safety Standards and Policies PROCESS SAFETY INFORMATION The Cherry Point Refinery keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments withi n the refinery are assigned responsibility for maintaining up-to-date process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in materials safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns. For specific process areas, the refinery has documented safety-related limits for specific process parameters. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems. The refinery also maintains numerous technical documents that provide information about 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 per sonnel, 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 The Cherry Point Refinery has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. Process Hazard Analysis performed at Cherry Point will be either HAZOPs (hazard and operability studies) or What if-Checklist studies. The HAZOP and What if-Checklist process is based on the principle that a team approach to hazard analysis will identify more problems than when individuals working separately combine results. The PHA team is made up of individuals with varying backgrounds and expertise who are brought together and, through collective brainstorming, make a thorough review of the hazards of the process. The team's findings are forwarded to local management for resolution. Implementation of mitigation options are tracked until they're complete. The final resolution of each finding is documented, tracked to completion and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the refinery periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted every 5 years. The results and findings from these updates are documented and retained. OPERATING PROCEDURES The Cherry Point Refinery maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienc ed operators and provide a basis for consistent training of new operators. These procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. This information is readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks. TRAINING To compliment the written procedures for process operations, the refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the 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. All of this training is documented for each operator, including the means used to verify that the operator understood the training. A modern, up to date, fully programable computer driven simulator is also available for Crude Unit employees to practice unit operation. The simulator is fully functional and can duplicate all unit characteristics. The display panels, which are identical to those used in our control room are very realistic. It can also be used to simulate proposed changes to determine if safety parameters could be violated. CONTRACTORS The Cherry Point Refinery uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the refinery has procedures in place to ensure that contractors (1) perform their work in a safe man ner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow the site safety rules, and (6) inform refinery 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, and (4) safe work practices prior to their beginning work. In addition, the refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. PRE-STARTUP SAFETY REVIEWS The Cherry Point Refinery conducts a process startup safety review for any new facility or facility modifications that requires a change in the process safety information. The purpose of the safety re view is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment in 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. A safety review involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. MECHANICAL INTEGRITY The refinery 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 assuranc e 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, (5) applicable safe work practices to 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. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service, or a 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. The Cherry Point Refinery 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 The Cherry Point Refinery 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 energy sources for equipment undergoing maintenance, (4) a permit and procedure to control "hot work" 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 The Cherry Point Refinery has a comprehensive system t o manage changes to the process. This system requires that changes to items such as process equipment, chemicals, technology, 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 operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. INCIDENT INVESTIGATION The refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, 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 documents its findings, develops recommendations to prevent a reoccurrence, and forwards these results to refinery management for resolution. Corrective action taken in response to the investigation teams' findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees 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, the refinery periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and management personnel p articipate as audit team members. The audit team develops findings that are forwarded to refinery 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 the2 most recent audit reports are retained. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all program EPA RMP-covered processes at the refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. In addition to the accident prevention program activities, the refinery has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safet y features are used in various processes: RELEASE DETECTION 7 Hydrocarbon detectors and hydrogen sulfide detectors with alarms. RELEASE CONTAINMENT/CONTROLS 7 Process relief valves that discharge to a flare to capture and incinerate episodic releases 7 Scrubber to neutralize chemical releases 7 Valves to permit isolation of the process 7 Automated shutdown systems for specific process parameters 7 Curbing or diking to contain liquid releases 7 Redundant equipment and instrumentation 7 Relief devices RELEASE MITIGATION 7 Automatic fire suppression and extinguishing systems 7 Deluge system for specific equipment 7 Trained emergency response personnel 7 Personal protective equipment 7 Blast-resistant control room FIVE-YEAR ACCIDENT HISTORY The Cherry Point Refinery has an excellent record of accident prevention over the past 5 years; the frequency of accidental releases is very low. We have not had any release that has gone outside of the refinery boundaries. We did have 1 OSHA recordable injury resulting from an exposure to ammonia. We investigate every incident carefully and have instituted changes to prevent this exposure form happening again. EMERGENCY RESPONSE PROGRAM INFORMATION The refinery maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the refinery has procedures that address maintenance, inspection, and testing of emergency response equipment , as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to refinery processes or other refinery facilities. The overall emergency response program for the Cherry Point Refinery is coordinated with the Whatcom county Local Emergency Planning Committee. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The refinery has emergency response organizations. This provides a means of notifying the public of an incident, if necessary as well as facilitating quick response to emergency drills that involve the emergency response organizations. PLANNED CHANGES TO IMPROVE SAFETY The Cherry Point Refinery resolves all findings from PHAs, some of which result i n modifications to the process. The following types of changes are planned: 7 Replace the ammonia tank with an improved smaller tank. Upgrade the ammonia handling system. Decrease the ammonia inventory. 7 Revisions to personnel training programs 7 Revisions to operating procedures Y2K EVALUATION The Cherry Point Refinery like many of the newer more modern facilities is mostly computer controlled and subject to the effects of Y2K. Our ITS department has throughly reviewed all process related software and verified that we are Y2K compliant. |