Marathon Ashland Petroleum Texas Refining - Executive Summary

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See the enclosed DOS text file for the executive summary. 
Risk Management Program Plan Executive Summary 
1.1    Accidental Release Prevention and Emergency Response Policies 
At Marathon Ashland Petroleum (MAP) LLC's Texas Refining Division, we are committed to operating and maintaining all of our processes in a safe and responsible manner.  We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees, contractors, and the public as well as protection of the environment.  This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 
    A description of our facility and use of substances regulated by EPA's RMP regulation 
    A summary of results from our assessment of the potential offsite consequences from accidental chemical releases 
    An overview of our accidental release prevention programs 
    A f 
ive-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 
    An overview of our emergency response program 
 An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, contractors, the public, and the environment 
1.2    Texas City Refinery Regulated Substances 
Our facility produces automotive fuels and chemical feedstocks from petroleum using a variety of processing operations.  In our processes, we handle ten RMP-regulated flammable substances and a variety of regulated flammable mixtures in our 11 RMP-covered process units. 
We handle only one RMP-regulated toxic substance above the EPA threshold quantity;  hydrofluoric (HF) acid is used as a catalyst in our HF Acid Alkylation Unit to produce high-quality gasoline blending components.  All 11 of our RMP-covered processes are classified as Program 3 processes, so we implement a complete accident prevention prog 
ram (see Section 1.4). 
1.3  Offsite Consequence Analysis 
MAP LLC Texas City Refinery performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated flammable or toxic substance that could affect the public or the environment. The offsite consequence analysis consisted of evaluating both worst-case scenarios and alternative release scenarios. MAP LLC Texas City Refinery does not expect a worst-case release scenario to ever occur. An alternative release scenario represents a release that might occur during the lifetime of a facility like MAP LLC Texas City Refinery.  Alternative release scenarios can be used to help the local emergency planning committee (LEPC) improve the community emergency response plan. 
We have submitted release scenario analyses 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.  For some of t 
hese events, we have emergency mitigation systems that should help reduce the consequences of the events if they occurred. In all cases, if such events occurred, we would activate our emergency response plan to respond to the event, notify local authorities, and take appropriate actions to protect our employees, contractors, and people in the community.  The paragraphs below briefly describe the scenarios we have included in our risk management plan. 
   Worst-case Release Scenarios 
The worst-case scenario associated with toxic substances in RMP-covered processes at the refinery is a failure of the hydrofluoric (HF) acid storage tank in our HF Acid Alkylation Unit. If such a failure released the maximum inventory of the tank (350,000 pounds), the HF acid would vaporize, resulting in a toxic exposure hazard in the downwind area that would extend outside of the boundary of the refinery. As specified by EPA, this analysis assumes that all of the HF acid is released to the air and no credit 
is taken for operation of our HF acid vapor mitigation system (i.e., a water spray system to reduce the amount of vapor that leaves the unit if released). 
The worst-case scenario associated with a release of flammable substances in RMP-covered processes at the refinery is a vapor cloud explosion, involving the full inventory of the Tank 187, which contains a flammable mixture comprised predominately of butane, isobutane, and isopentane. The analysis assumes that the maximum possible inventory of 3,800,000 pounds is released, completely vaporizes, and ignites, resulting in a vapor cloud explosion. Because there are some public receptor locations just outside the refinery property, this event could affect members of the public at those closest locations. 
       Alternative Release Scenarios 
Our alternative release scenario for toxics involves a release of HF acid from a truck unloading hose. This would result in a release of 950 pounds of HF acid in the 10 seconds required to isolate the  
hose, thereby stopping the release.  Our analysis showed that the resulting HF vapor cloud would reach only slightly beyond the refinery property boundary, and would be unlikely to result in toxic exposures to more than a few people. 
The alternative release scenario in our risk management plan for flammable substances at the refinery is a vapor cloud explosion resulting from a failure of a propylene/butylene railcar unloading hose. The line failure would release about 35,000 pounds of flammable material in the 20 minutes time required to isolate the release. The analysis assumed that all of this material would be involved in a vapor cloud explosion and showed that the resulting overpressure from the explosion would barely reach across the refinery property boundary; few public receptor locations would be affected. 
As stated previously, we have included details regarding these scenarios in the additional information submitted to EPA with this executive summary, and have shared that in 
formation 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 MAP LLC Texas City Refinery RMP coordinator at (409) 945-2331. 
1.4    Accidental Release Prevention Program 
The following is a summary of the general accident prevention program in place at the MAP LLC Texas City Refinery.  Our RMP-regulated processes are also subject to the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, and because the OSHA PSM requirements are very similar to the EPA RMP requirements for refineries, this summary addresses each of the OSHA PSM elements.  We have extended the PSM program at this facility, where necessary, to satisfy EPA's Program Level 3 accident prevention program requirements. 
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, con 
tractors, the public, and the environment by our use of these chemicals.  We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases.  We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals.  The following paragraphs briefly describe the key features of our prevention program. 
Employee Participation 
The Texas Refining Division 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 process hazard analysis (PHA), incident investigations, and audits. Employees have access to all information created as part of the Texas Refining Division accident prevention program.  Specific ways that employees can be involved in the accident prevention program ar 
e documented in an employee participation plan that is maintained at the Texas Refining Division and addresses each accident prevention program element.  In addition, the Texas Refining Division has a number of initiatives under way to address process safety and employee safety issues. 
Process Safety Information 
The Texas Refining Division 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 within the Texas Refining Division 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 material safety data sheets (MSDSs). This information is supplemented by documents that spe 
cifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals.  For specific process areas, the Texas Refining Division has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in facility information documents.  The Texas Refining Division ensures that the process is maintained within these limits by using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).  
The Texas Refining Division 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 
The Texas Refining Division has a comprehensive PHA 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 those hazards. 
The Texas Refining Division primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations.  HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques available.  The analyses are 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 accident prevention and mitigation measures, and makes recommendations for additional preve 
ntion and/or mitigation measures when the team believes such measures are necessary.  
The PHA team recommendations are forwarded to management for resolution. All approved safety improvements being implemented in response to PHA team recommendations are tracked until they are complete.  The final resolution of each recommendation is documented 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 Texas Refining Division periodically updates and revalidates the PHA results.  These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. 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 
The Texas  
Refining Division 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 experienced operators and provide a basis for consistent training of new operators.  Procedures are periodically reviewed and annually certified as current and accurate.  Procedures are maintained current by revising them as necessary to reflect changes made to the process.  In addition, the Texas Refining Division 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 operators in the process units and for other personnel to use as necessary to safely perform their job tasks. 
To complement the written procedures f 
or process operations, the Texas Refining Division has implemented a training program for all employees involved in operating a process.  New employees receive basic training in Texas Refining Division 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 (i.e., through tests, skills demonstrations, etc.) 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. 
The Texas Refining Division uses contractors to supplement its wo 
rk force during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the Texas Refining Division 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) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Texas Refining Division 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 Texas Refining Division evaluates contractor safety programs and performance during the selection of a contractor.  Texas Refining Division personnel periodically monitor/audit contractor perf 
ormance to ensure that contractors are fulfilling their safety obligations. 
Pre-startup Safety Reviews 
The Texas Refining Division conducts a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information.  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 all supporting systems are operationally ready.  The review team uses checklists to verify all aspects of readiness. 
Mechanical Integrity 
The Texas Refining Division 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 includ 
e: (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 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 Texas Refining Division incorporates quality assurance measures into equipment purchases and repairs.  This helps ensure that new equipment is suitable for its intended use and proper materials and spare parts are used when repairs are made.  
Safe Work Practices 
The Texas Refining Division has long-standing safe work practices in place to help ensure worker and process safety.  Examples 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 control 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 
The Texas Refining Division 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 operating limits, and equipment information, as well as procedures, are updated to incorporate these changes.  In addition, operating and maint 
enance personnel are provided with any necessary training on the change. 
Incident Investigation 
The Texas Refining Division 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 recurrence, and forwards these results to Texas Refining Division 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 recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation r 
eports 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 Texas Refining Division periodically conducts audits 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 participate in the audit.  The audit team develops findings that are forwarded to Texas Refining Division 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. 
In addition to the accident prevention program activities, the Texas City Refinery has safety features on many units to help (1) contain/control a release, (2) quickly det 
ect a release, and (3) reduce the consequences of a release.  As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: 
Release Detection 
(    Hydrocarbon detectors with alarms in the LPG Storage Area, HF Acid Alkylation Unit, Gas Concentration  Unit, #5 Topper Unit, and Platformer Unit 
Release Containment/Control 
* Process relief valves that discharge to a flare to capture and incinerate process materials to prevent overpressure damage to equipment 
* Manual and automatic valves to permit isolation of the processes 
* Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 
* Rapid HF de-inventory system to permit removal of the process inventory in the event of an imminent HF release 
* Curbing or diking to contain liquid releases 
* Redundant equipment and instrumentation where needed (e.g., uninterruptible power supply for process control system, redundant firewater pumps) 
* Fire suppressio 
n and extinguishing systems  
* Deluge systems for LPG spheres and bullets, #5 Topper Unit, Gas Concentration Unit, and the HF Acid Alkylation Unit 
* Trained emergency response personnel 
* Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 
* Blast-resistant central control building to help protect control systems and personnel 
The individual elements of our prevention program work together along with the chemical-specific prevention measures to prevent accidental chemical releases.  Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 
1.5    Five-year Accident History 
We keep records for accidental chemical releases that occur at our facility.  For each of these incidents, we have conducted formal incident investigations to identify and correct 
the root causes of the events. 
Texas City Refinery has experienced NO accidents during the past five years involving regulated substances from RMP-covered processes that had any reportable onsite or offsite effects. 
1.6    Emergency Response Program 
The MAP LLC Texas City Refinery maintains an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning.  Our written program provides the essential planning and training for effectively protecting workers, contractors, the public, and the environment during emergency situations.  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, refinery evacuation plans and accounting for refinery personnel a 
fter an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. 
In addition, we have 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 to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to refinery processes or facilities  and affected personnel are informed of/trained on the changes. 
The overall emergency response program for the Texas City Refinery is coordinated with the Texas City-LaMarque-Hitchcock local emergency planning committee (LEPC) and with the Texas City emergency management officials. This coordination includes periodic meetings of the LEPC, which includes local emergency response officials, local government official 
s, and industry representatives.  We have around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.  In addition to participating in periodic LEPC meetings, we conduct periodic emergency drills that involve the LEPC and emergency response organizations, and the refinery provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.  Thus, our emergency response plan is fully coordinated with the community emergency response plan. 
1.7    Planned Changes to Improve Safety 
The MAP LLC Texas City Refinery constantly strives to improve the safety of its operations through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers. We resolve all findings from 
PHAs, some of which result in modifications to the process. The following is a list of improvements that we are planning to implement at the facility during the next five years to help prevent and/or better respond to accidental chemical releases: 
* Upgrade process plant building construction to enhance protection of operating personnel 
* Upgrade process area lighting to increase visibility at night 
* Continually upgrade engineering drawings of covered processes to ensure that accurate information is always available to plant personnel 
* Provide closed loop sampling system for process fluids to enhance operator safety 
* Continually upgrade process control schemes to improve reliability of covered processes 
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