United Refining Company - Executive Summary |
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United Refining Company Risk Management Plan Executive Summary I. Accidental Release Prevention and Emergency Response Policies United Refining Company (URC) has a long-standing commitment to worker and public safety. This commitment is embodied in Company Policies and Procedures and demonstrated by the resources invested in accident prevention, such as training personnel and incorporating safety in the design, installation, operation, and maintenance of processes. URC policy is to implement controls to prevent accidental releases of regulated substances. However, if a release does occur, trained personnel respond to control and contain the release in accordance with procedures in the Company's Off-site Response Plan; Facility Response Plan; Preparedness, Prevention, and Contingency Plan; Spill Prevention Response Plan; Spill Prevention Control and Countermeasures Plan; and Air Contingency Plan. United coordinates emergency response with the Warren County Local Emergency Planni ng Committee and the Warren City Fire Department for mutual aid in responding to plant emergencies. II. Stationary Source and Regulated Substances Handled United Refining Company, located in Warren, Pennsylvania, operates petroleum refinery processes to produce gasoline, distillate fuels, asphalt, sulfur, and liquefied petroleum gases (LPG) from crude oil. Regulated substances handled at the site are flammable mixtures including pentanes and butanes. None of the regulated toxic substances used, extracted, or processed at the refinery are held above their respective threshold quantities. III. Hazard Assessment Results Under EPA's risk management regulation one worst case scenario (WCS) and one alternative release scenario (ARS) are required to be assessed for regulated flammable substances. WCS means the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance affected by the release. This assessment i s required regardless of its likelihood. EPA has also required companies to assess ARSs. URC's Risk Management Plan (RMP) assessed an ARS and two WCSs for regulated flammables. The refinery is a long, narrow facility and therefore a second WCS was required to incorporate all potentially effected offsite receptors. URC utilized the EPA provided RMP*COMP to perform all release scenario analyses. One WCS for regulated substances at the refinery is a vapor cloud explosion (VCE) involving a release of flammable substances from Tank 431. This tank contains a flammable mixture of pentanes, small quantities of butanes, and non-regulated substances. An administrative limit of 35 feet is established as the maximum fill height for the tank. In addition, the tank is in a 12,000 square foot containment area. The WCS assumes the tank fails and fills the dike with the flammable liquid. EPA's Risk Management Program Guidance for Offsite Consequence Analysis (April 1999) was used to determine an evaporation rate of 5,000 pounds per minute from the diked area. For a WCS, this rate is assumed to occur for 10 minutes. Consequently, 50,000 pounds of flammable liquid (as pentane) is assumed to release, completely vaporize, and ignite, resulting in a VCE. EPA's computer model, RMP*Comp was used to determine that the maximum distance affected by this release is 0.3 miles. Controls exist to prevent such a release and manage consequences making this scenario extremely unlikely, but no credit for active mitigation measures is permitted in evaluating this WCS according to EPA's regulations. A second WCS for regulated substances is a VCE involving a release of flammable substances from a butane storage tank. An administrative limit of 85 percent full is established as the maximum fill height for the tank. Taking this limit into account the maximum inventory of 137,000 pounds is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance affect ed by this release is 0.4 miles. Controls exist to prevent such a release and manage consequences making this scenario extremely unlikely, but no credit for active mitigation measures is permitted in evaluating this WCS according to EPA's regulations. One ARS for flammable substances is a VCE resulting from a transfer line release of LPG occurring at a central location in the refinery. This scenario is based on releasing 1460 pounds per minute for thirty minutes. The anticipated time for operators to isolate the release is within thirty minutes. The maximum distance affected by this release is 0.1 (one tenth) mile. This event depicts a practical scenario for use in emergency planning and response. IV. General Accidental Release Prevention Program URC utilizes a Process Safety Management (PSM) program which complies with Occupational Safety and Health Administration (OSHA) regulations. The elements of this accidental release prevention program are described below: Employee Pa rticipation United encourages employees to participate in all facets of PSM and accident prevention. Employees verify/evaluate procedures and assist in technical accuracy of Process Hazard Analyses (PHA). Employees have access to all information developed and maintained as part of the accident prevention program. Process Safety Information (PSI) United Refining maintains technical documents that are used for safe operation of each process. These documents have been developed in conjunction with the PHA. The documents contain information on hazards of chemicals and their properties, flow description, process chemistry, maximum intended inventories, operating parameters, consequences of deviations, and information on equipment data. United's management of change for each process and periodic audits ensure accurate PSI. PSI for each process is available to employees at the process site. In addition to PSI and related technical documents, United ensures each process is operated within safe operating parameters by using process controls, monitoring instruments, trained personnel, and protective devices. Process Hazard Analysis United's PHA is a comprehensive program to ensure hazards associated with each process are identified and controlled. Each process has been studied to systematically identify potential hazards and operability problems and ensure adequate controls are in place to manage these hazards. United uses the Hazard and Operability (HAZOP) study technique to perform these evaluations. HAZOP is a systematic and organized approach to evaluate processes using a team of individuals with pertinent expertise. The team identifies potential hazards and operability problems within each process, as well as applicable safeguards for these hazards. PHA findings and recommendations are assigned a ranking to ensure that attention is given to items deemed most significant by the HAZOP team, and resolution of items is tracked to completion. United has completed all PHAs as well as several revalidations, which are completed once every five years or more frequently if significant process changes occur. Operating Procedures United maintains written operating procedures which address various modes of operation for each process, and separate generalized procedures applicable to all processes. Procedures are available in the control room where the process is located. Procedures are periodically reviewed to ensure accuracy and completeness. Training A new operator receives on the job training from an experienced operator or supervisor until such time as he/she is confident to take a three part qualification test. In addition to new operator training, all operators receive refresher training on procedures and applicable job skills via supervisor instruction, quizzing, and group discussion sessions. Contractors United utilizes contract employees to supplement its workforce in times of increased work activity and for specialized services. United has implemented a pre-qualification system to determine if a contractor's safety record and programs are adequate to perform work in the refinery. All contract employees are given safety orientation prior to plant entry to familiarize them with URC safety procedures. Pre-startup Safety Review (PSSR) United conducts a PSSR on any new process or a significantly modified facility prior to its start-up. This review is performed by appropriate personnel to ensure all work has been completed, safety measures are in place, and construction is in accordance with design specification. Mechanical Integrity United has established practices and procedures to maintain the on-going integrity of process equipment. United's program includes employee training, written procedures for maintenance of equipment, inspection and testing of equipment, correcting identified deficiencies, and utilizing quality assurance measures. Maintenance employees receive training on an overview of the processes including hazards, applicable procedures, safe work practices, and emergency plans and duties. Written procedures on maintenance job tasks are available and provide guidance for employees. Inspection and testing procedures are provided to ensure equipment is functioning as intended and is applicable for current usage. URC incorporates quality assurance measures into equipment purchases and repairs to ensure that new equipment is suitable for intended use and that proper materials and spare parts are used for repairs. Safe Work Practices United maintains Company Policies and Procedures to ensure worker and process safety. Examples of these practices include (1) control of the entry/presence/exit of support personnel, (2) lockout/tagout procedure to ensure isolation of energy sources, (3) permit and procedure to control hot work activities, (4) confined space entry procedure and permit to ensure safe atmosphere prior to entry. These procedures coupled with traine d personnel ensure maintenance and operations activities are performed in a safe and consistent manner. Management of Change (MOC) United utilizes a comprehensive system to manage changes within processes. The MOC procedure ensures safety measures exist to avoid creating hazards and verifies that existing safety features are not compromised by the change. Before a change is made it is reviewed and authorized by appropriate personnel. All affected employees are notified of the change, and any revisions to written documents are incorporated as needed. Incident Investigations United promptly investigates all incidents that resulted in or could have reasonably resulted in a release of a hazardous substance, caused major property damage, or caused injury. The investigation is conducted by a team of qualified individuals to determine the cause and circumstances responsible for the incident. Recommendations are made to implement changes or correct deficiencies and communicated to a ppropriate personnel. Compliance Audits URC utilizes compliance audits to ensure the integrity of its PSM program. All aspects of PSM are evaluated and an audit report is generated. Recommendations for improvement are made and assigned to appropriate personnel. Audits are conducted a minimum of every three years and recommendations are tracked to ensure resolution. Specific Prevention Steps In addition to the previously detailed accident prevention program, URC utilizes safety features to prevent releases, quickly detect a release, and control/contain a release. The following types of safety features are used in refinery processes: Release Detection * Twenty-four hour security for the plant * Continuous operator surveillance of all processes * Radio communications for operators and security personnel Release Containment/Control * Safety relief valves that discharge vapor to the flare system to capture and incinerate releases * Valving to permit manual or automatic isola tion of equipment/processes * Automated shutdown systems and interlocks for specific parameters such as temperatures and liquid levels * Vessels to permit partial removal of process inventory in the event of a release * Curbing and dikes to contain liquid releases * Redundant equipment and instrumentation * Drain system to remove liquid releases from process areas for treatment V. Five-Year Accident History United Refining Company has an excellent record of accident prevention with no reportable incidents occurring during the five year accident history period. VI. Emergency Response Program Information United Refining Company maintains an emergency response program to protect employee and public safety and the environment. The comprehensive program contains procedures for responding to fires, explosions, and releases of regulated substances. The plan provides for all aspects of emergency response including: * Proper first-aid and medical treatment for exposures, * Evacuation p lans, * Accounting for personnel after an incident, * Notification of local emergency planners and the public, and * Post-incident cleanup and decontamination procedures. United also utilizes the following specific mitigation devices to aid in responding to plant emergencies: * Fire suppression and extinguishing systems in process units and tanks * Deluge system for specific equipment * Trained on-site emergency response personnel (Fire Brigade and HAZMAT Team) * Personal protective equipment (i.e. protective clothing, self contained breathing apparatus) * Automated emergency call-out system (activated by laboratory employees who are present 24 hours/day) to secure personnel in the event of an emergency during off-hours The emergency response program is coordinated with the Warren County Local Emergency Planning Committee (LEPC). URC's Fire Brigade is trained at least monthly and occasionally performs coordinated drills with Warren City Fire Department and the Warren County LEPC. VI I. Planned Changes To Improve Safety Safety is an activity which undergoes continuous improvement at United Refining Company through three venues: 1. Employee Training Planned change: Improved safety training for employees with the installation of interactive computer software. 2. Process Hazard Analysis Planned change: Continuous safety improvement from implementation of PHA recommendations. 3. Safety Committees Planned change: Continuous safety improvement by identifying and correcting potential hazards through employee discussion at regularly scheduled safety meetings. |