Conoco Inc., Denver Refinery - Executive Summary |
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The executive summary for the Conoco Denver Refinery includes a brief summary of the following items: - The policies for accidental release prevention and emergency response. - A description of this stationary source and the regulated substances handled. - The RMP regulatory defined worst case scenario and the alternative release scenario. - The general accidental release prevention program and chemical specific prevention steps. - The five year accident history. - The emergency response program. - Planned changes to improve safety. THE POLICIES FOR ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE. The goals for the Conoco Denver Refinery include 'No One Gets Hurt', and that we are a welcome business in the community. Preventing accidental releases is a key component to achieve these goals. The Conoco Denver Refinery utilizes a variety of activities, as described below in the accident prevention program, to systematically reduce the chances of an accidental release. In t he unlikely event of an accidental release, employees are trained to promptly respond to minimize the release, and a group of volunteer employees are trained in emergency response techniques, including fire fighting with the refinery's own fire trucks and other equipment. The Conoco Denver Refinery's policy is to be able to respond to any emergencies within the refinery, and to train with the local Fire Department to be prepared in the event of an emergency beyond the refinery's capabilities. A DESCRIPTION OF THIS STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED. Conoco Inc. is a major integrated energy company, and began marketing operations in Denver in 1876 as the Continental Oil Company. Conoco's Denver Refinery is actually in Commerce City, Colorado, northeast of downtown Denver. The refinery started small in 1931 with 16 employees, and was the country's first continuous-processing crude oil refinery. The refinery has expanded and now employs more than 200 people, and p rocesses about 60 percent of the crude oil, sweet and sour, refined in Colorado. The refinery's products include three grades of gasoline, jet fuel, diesel fuel, propane, butane, paving asphalt, and sulphur. The refinery has a number of processes to take the crude oil, which is actually a mixture of materials, and refine them into the variety of products. These processes have been evaluated to determine the Risk Management Program (RMP) regulated substances used or present in the processes. Due to its nature as a petroleum refinery, the refinery has a number of regulated flammable substances as products, intermediates, and as materials used in the various processes. The refinery also has several of the RMP listed toxic substances, but none at the quantity or concentration specified in the regulation. Practices are in place to protect employees, and therefore the community and the environment, from the flammables and the toxics. THE RMP REGULATORY DEFINED WORST CASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIO. Conoco's Denver Refinery followed the EPA guidelines to estimate a "Worst Case Scenario" and an "Alternative Release Scenario," or what kinds of events could possibly occur that could impact the community. Following the EPA requirements, the Conoco Denver Refinery has evaluated its processes to identify these scenarios. There are no scenarios to report for any toxics, and there is one 'Worst Case Scenario' to report for all of the flammables. This scenario is the estimate of the release of the contents in the largest single vessel containing propane in a mixture (1,400,000 pounds), an explosion, and estimating the distance to the 1 psi endpoint. If that release occurred following the EPA guidance for weather and other conditions, it is estimated the resulting 1 psi endpoint would be approximately 0.9 miles from the refinery. This pressure wave could shatter windows and damage some buildings outside the refinery. No credit was taken for the admi nistrative controls that are used to keep a lesser quantity in the vessel than the quantity used in estimating the scenario. This worst case scenario is very unlikely because of the measures taken to safely operate this vessel, including the location and maintenance of the vessel, and the training and procedures followed by employees while operating and maintaining this vessel. The 'Alternative Release Scenario' is an estimate of an accidental release of a smaller amount of the same flammable material, with the pressure wave endpoint about 0.3 miles away from the refinery. The event used to estimate the Alternative Release Scenario was a break in a line carrying the propane mixture, and took into consideration the ability of employees to detect and stop the release within approximately 15 minutes. THE FIVE YEAR ACCIDENT HISTORY The RMP also requires the Conoco Denver Refinery to report certain accidents that had specific on-site, community, or environmental impacts in the past 5 years. The people that work at the Conoco Denver Refinery are proud of their safety record. There are no accidents to report based on the results of interviews of employees and a review of safety and environmental records from June 1, 1999, back to June 1, 1994. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS. The following is a summary of the general accidental release prevention program in place at the Conoco Denver Refinery. Eleven processes at the Refinery are regulated by the EPA RMP regulation and are also subject to the OSHA Process Safety Management (PSM) standard, which took effect in 1992. The accidental release prevention program requirements in the RMP are almost identical to the OSHA PSM standards, with the PSM requirements focused on worker safety and the EPA RMP focused on the community and the environment. This is a summary of how these requirements are addressed and describes how the system is implemented to help prevent acci dents. Management Commitment Conoco's Denver Refinery management recognizes the value of active, widespread employee participation in the effective application of Process Safety Management (PSM) and accident prevention for the Risk Management Program (RMP). Effective Process Safety Management is dependent on the knowledge and contribution of every employee involved with the operation and maintenance of the processes. Refinery employees have been and will continue to be involved with the implementation and ongoing practice of Process Safety Management and accident prevention. Refinery Management understands their role, which includes the commitment of resources to implement site PSM and RMP policies and procedures and to sustain and continually improve safety. As part of their role, each element of the PSM regulation, and the corresponding RMP accidental release prevention element, has been assigned to a member of the Denver Refinery Leadership Team to monitor the status of the ele ment. Employee Participation There is a written Employee Participation Plan that describes how employees participate in PSM and the RMP accidental release prevention program development and implementation, and how employees have access to the information they need to do their jobs safely. Examples of employee participation include updating and compiling procedures, conducting inspections and tests on equipment, participating as a member of a process hazard analysis (PHA) team, and actively participating in management of change, pre-start-up safety reviews, contractor evaluations, compliance audits and incident investigations. This intensive and widespread involvement of a variety of employees is considered key to the effectiveness and sustainability of the accident prevention efforts. There are also two standing teams for employee consultation on the development and implementation of all elements of PSM and the accident prevention requirements of RMP. There is a Joint Health and Safety Committee to involve employees at various levels of the organization, including union represented employees, Refinery Leadership, and safety and health management, in a variety of traditional safety issues. There is a sub-team of the Joint Health and Safety Committee, known as the Process Safety Management Coordination Team that includes union represented employees and salaried members of operating, mechanical, and management groups. This team is primarily responsible for sustaining and continually improving PSM and the accident prevention requirements of RMP in the long term within the refinery. Process Safety Information As part of compliance with PSM and RMP, the refinery maintains current information on the chemicals, technology, and equipment in its processes covered by the PSM and RMP regulations. Material Safety Data Sheets (MSDS) provide the information about the chemicals in the process. This chemical-specific information includes exposure hazards and emerg ency response/exposure treatment considerations. This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For the technology and equipment of the process, written information is collected and validated by a variety of employees. The technology information includes the processes' chemistry, intended inventories, safe upper and lower limits for such items as temperatures, pressures, flows or compositions, and the consequences of deviation from the limits. The refinery maintains the process within these limits using process controls and monitoring instruments, highly trained personnel, procedures, and protective instrument systems, such as automated shutdown systems. The refinery also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design p ressure and temperature ratings, electrical rating of equipment, and design codes and standards. 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 The process hazards analysis is a systematic approach to help ensure that hazards associated with the various processes are identified, evaluated, and controlled. The Conoco Denver Refinery uses recognized methodologies to conduct the analysis, including the hazard and operability (HAZOP) analysis technique and a What-If/Checklist. These analyses have been conducted on each process covered by RMP as part of the PSM program, and the analyses will be updated and revalidated at least once every five years. Each analysis is done by a team with expertise in engineering and process operati ons for the process being evaluated. This team identifies and evaluates hazards of the process as well as previous incidents and accident prevention and mitigation measures. The team then makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The Team's findings and recommendations are reviewed by Refinery management and an appropriate response is determined, documented and an action plan developed. Progress on the action plan is tracked until complete. The final resolution of each finding is documented and retained. All refinery employees are advised of the analyses in advance for the opportunity to provide input, and employees who may be affected by the recommendations or actions are advised. Operating Procedures For each process covered by the RMP or PSM regulations, the Conoco Denver Refinery maintains and has implemented written operating procedures that address various modes of process operations, such a s (1) startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures are used by experienced operators and provide a basis for consistent training of new operators. These procedures are routinely reviewed through usage or training, and there is a separate process to review and annually certify the procedures are current and accurate. The written operating procedures are readily available to operators in the control rooms and for other personnel to use as necessary to safely perform their job tasks. Training for Operators To complement the written procedures for process operations, there is training program for all employees involved in operating a process. New employees receive basic training in refinery operations, including classroom work and field observations, if they are not already familiar with such operations. After successfully completing this training, a new operator is pa ired with an experienced operator to learn process-specific duties and tasks. After operators demonstrate (through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. Operators are also trained before operating a newly assigned process. Affected operators are informed of and/or trained on any changes to the procedures. All operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained and assure they understand and follow the current procedures. 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. Contractors Contractors work at Conoco' Denver Refinery to supplement the employee workforce during periods of increased maintenance or construction activities. For the contractors that work near or in the processes, there is a comprehensive program to evaluate the contractor's safety performance and programs prior to selecting the contractors. The refinery has a program to inform the contractors of the site-specific information, including the hazards of the process, the emergency response plan, and applicable safety procedures. This helps ensure that these contractors perform their work in a safe manner, are aware of the hazards, understand what they should do in the event of an emergency, and understand and follow the refinery's safety rules. The contractors are expected to inform refinery personnel of any hazards that they find during their work. Refinery personnel periodically evaluate contractor performance to ensure that contractors are fulfilling their safety obligations. Management of Change and Pre-startup Safety Reviews The Conoco Denver Refinery has a comprehensive system to manage changes to the processes' equipment, chemicals, technology (inc luding process-operating conditions), and procedures. The Management of Change system includes written procedures that provide for the changes to be reviewed and authorized before being implemented, and checklists to assist the various employees in a thorough review. The proposed change is reviewed by employees to understand the technical basis of the change and any possible impact on safety and health. Once the change is authorized, any affected chemical hazard information, process operating limits, equipment information, or procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary information or training on the change. If a new process is constructed or if there is a change that requires a change in the process safety information, there is also a review prior to start-up. The purpose of this Pre-Startup Safety Review is to ensure that safety features, procedures, personnel, and the equipment are appropriate ly prepared for startup prior to placing the equipment into service. There are checklists to assist the employees' verification of all aspects of readiness, including field verification of the construction and verification that accident prevention program requirements are properly implemented. 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. Mechanical Integrity Mechanical Integrity is the name given to the group of requirements to properly maintain and repair equipment in the PSM and RMP covered processes. Conoco's Denver Refinery has a comprehensive system to identify equipment to include in the program, written and implemented maintenance procedures with training on the procedures, inspections and tests, correcting identified deficiencies, and quality assurance for new and replacement equipment and parts. In combination, these practices and procedures help assure pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems are maintained in a safe operating condition. The refinery's Mechanical Integrity program provides for training for Maintenance personnel on an overview of the processes where they work, safety and health hazards, applicable maintenance procedures, the emergency response plan, and applicable safe work practices and procedures to help ensure that they can perform their job in a safe manner. The written procedures help ensure that work is performed in a safe, consistent manner and provide a basis for training. Inspections and tests procedures follow recognized and generally accepted good engineering practices. The inspections and tests are performed by properly qualified and trained employees or contractors. The inspections and tests are done at a certain frequency to help ensure that equipment functions as intended, and to verify that equipment is wit hin acceptable limits, such as 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 take the necessary actions to continue to operate safely until repairs can be made. Another integral part of the mechanical integrity program is quality assurance for the purchase and use of new, spare or replacement parts or equipment. Along with the management of change and pre-startup safety review processes, this helps assure that new or replacement equipment is installed correctly and safe for the conditions in the process. Safe Work Practices/Hot Work Conoco's Denver Refinery has numerous safety procedures to help assure the safety of employees, contractors and visitors to the refinery. These include the Safe Work Practices and Hot Work Permit requirements listed in the PSM and RMP regulations. Examples of these include (1) control of the access of personnel to the facility and the processes, (2) a procedure to ensure isolation/removal of energy sources for equipment undergoing maintenance, (3) a procedure for safely opening process piping or equipment, (4) a permit and procedure to control spark-producing activities (i.e., hot work, welding, grinding), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), are written, implemented through training of affected personnel, and routinely reviewed and audited through Joint Health & Safety Committee programs involving a large number of employees and contractors. Incident Investigation The Joint Health & Safety Committee at Conoco's Denver Refinery oversees the majority of incident investigations at the refinery. This includes reviewing incidents that may need to be investigated to comply with the requirements of PSM and/or RMP. This helps assure that 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 are promptly investigated. 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 investigations are done by a team, which includes salaried and union represented employees, and a contractor representative if the incident involved the work of the contractor. The team has a written report with its findings and recommendations to prevent a recurrence, and forwards these results to refinery management for resolution. A corrective action plan is developed, documented, and tracked until complete. The investigation team's report is also provided to all employees and the contractors regularly on site. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during the next Process Hazard Analysis update/revalidation. Compliance A udits The RMP regulations require an audit of the accidental release prevention program at least once ever 3 years. To comply with this requirement and help ensure that the RMP accidental release prevention program is implemented, Conoco's Denver Refinery plans to periodically conduct audits of the required procedures, practices and documentation. It is planned that union represented and management employees will participate in the audit process, and the actual audit team members will come from other Conoco refineries to help with an objective assessment of the program. The audit team is expected to document any findings that refinery management will review to develop a corrective action plan. Corrective actions taken in response to the audit team's findings will be tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports will be retained. CHEMICAL SPECIFIC PREVENTION STEPS The processes at Conoco's Denver Refine ry must be managed to ensure continued safe operation. The accidental release prevention program is applied to all RMP covered processes. Collectively, these prevention program activities help prevent potential accidents and releases. In addition to the activities already described, the refinery has safety features on many processes to help contain or control a release, quickly detect a release, and reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release detection - Hydrocarbon detectors with alarms There are also various detectors for some of the toxics, such as SO2 and H2S, that are not RMP regulated, but are managed for employee safety. Release Containment/Control 7 Process relief valves that discharge to a flare to safely capture and incinerate releases 7 Scrubber to neutralize chemical releases 7 Valves to permit isolation of all or part of the process (manually operated or automated) 7 Automatic shutdown systems for specific process parameters (such as high level or high temperature) 7 Vessel to permit partial removal of the inventory in the event of a release (a 'dump tank') 7 Curbing or diking to contain liquid releases 7 Redundant equipment and instrumentation (includes such things as uninterruptible power supply for process control system, backup firewater pump) 7 Atmospheric relief devices to allow vessels to vent rather than rupture. Release Mitigation 7 Fire suppression and extinguishing systems throughout the refinery 7 Deluge systems for specific equipment 7 Trained emergency response personnel and operators trained in specific emergency procedures 7 Personal protective equipment (protective clothing, self-contained breathing apparatus) 7 Blast-resistant buildings to help protect personnel and control systems EMERGENCY RESPONSE PROGRAM INFORMATION Conoco's Denver Refinery has a written emergency response plan and a program that is in place to protect worker and public safe ty as well as the environment. The program 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 emergency response agencies if a release occurs, and post incident cleanup and decontamination requirements. The program includes the refinery's plans for responding to the possibility of a fire or explosion if a flammable substance is accidentally released. In addition, the refinery has procedures that address the use, maintenance, inspection, and testing of emergency response equipment, like the refinery's own fire trucks and the system to deliver water or foam for fire fighting. Changes to the refinery that might require changes to the emergency response program are identified through the Management of Change system. Employees receive training in the emergency response procedures as necessary to perform their specific emergency response duties, and they are informed and/or trained in any changes that effect their duties. For example, all employees are trained in the emergency alarm and evacuation procedures, and many employees are trained in the use of portable fire extinguishers. There is also a small group of highly trained employees who are volunteers to make up the refinery's Emergency Response Team, which includes a fire brigade and rescue team. This group of employees is trained to fight fires and respond to other emergencies in the refinery. The emergency response program for the refinery is coordinated with the South Adams County Fire Protection District and the Adams County Local Emergency Planning Committee (LEPC), and there is a mutual aid agreement with the neighboring refinery. For example, the Conoco Refinery Fire Brigade trains with the South Adams County Fire Protection District fire fighters at the Refinery's fire training grounds. The LEPC coordination includes periodic meetings of the committee, whi ch includes local emergency response officials, local government officials, and industry representatives. PLANNED CHANGES TO IMPROVE SAFETY On an ongoing basis, the techniques most used to generate ideas to improve safety are the Process Hazards Analyses and learning from Incident Investigations and real or staged emergency responses. For example, these may identify needed improvements in equipment or procedures. These techniques identify needed changes before an accident, or help identify needed changes to prevent the possibility of more serious accidents. As of the time of this filing, there are approximately 125 issues or items for improvement identified during the PHA for 9 of the 11 RMP covered processes that are currently being worked (two of the processes do not have any pending items). The types of changes from these items include adding instruments and alarms, working on procedures, rerating certain vessels and further evaluating existing information for possible change s. There are also plans to improve the Conoco Denver Refinery's emergency response capabilities through expanding the number of local fire departments with which we train. Also, a new system to account for employees and contractors in the refinery in the event of an emergency is under construction and should be working by the end of 1999. |