Williams Alaska Petroleum,Inc. North Pole Refinery - Executive Summary |
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Executive Summary for Williams Alaska Petroleum, Inc. North Pole Refinery Accidental Release Prevention and Response Policies The Williams Alaska Petroleum, Inc. North Pole 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 the design, installation, operation and maintenance of the refinery processes. Our policy is to implement reasonable controls to prevent releases of regulated substances. This policy has resulted in no offsite affects for the life of the facility. However, if a release does occur, our trained personnel will respond to control and contain the release. Description of Williams Alaska Petroleum, Inc. North Pole Refinery The refinery is located in North Pole, Alaska. It has three crude units (Crude Unit 1, Crude Unit 2, Crude Unit 3), an Extraction Unit, a Tank Farm and Utilities. Crude Unit 1 processes about 5 0,000 B/D Alaskan Crude, Crude Unit 2 about 70,000 B/D and Crude Unit 3 about 70,000 B/D. The Extraction Unit processes about 15,000 B/D of naphtha and 10,000 B/D of kerosene. The primary products produced are motor gasoline, jet fuel and diesel. These products are made from the naturally occurring hydrocarbon compounds in crude oil. The refinery does not modify the compounds as most refineries do, it distills and extracts desired compounds from the crude and blends them appropriately to make the desired products. The result of the Williams Alaska Petroleum, Inc. North Pole Refinery processing scheme, when compared to a typical refinery, is an easier to operate and safer plant. It does not have any process units that are specifically designed to modify the hydrocarbon compounds in crude oil such as cracking units (FCC's, Hydrocrackers, etc.) or reformer units. It does not have any units that operate at high pressure and/or temperature, which is typically required to modify hyd rocarbon molecules. This results in significantly less flammable (light hydrocarbons like propane, butane and pentanes) and toxic materials (like hydrogen sulfide, H2S) being produced and fewer chemicals and catalyst being used. Even though the North Pole Refinery processing scheme is different than most refineries, each crude unit, the extraction unit and the tank farm does contain regulated flammables such as propane, butane and pentanes above the threshold quantity. Hazard Assessment Results The refinery does not contain any toxic materials above the threshold quantity; therefore, no hazard assessment for toxics was completed. Worst Case Scenarios associated with the release of flammable substances from each crude unit, extraction unit and the tank farm were analyzed. The vessel in each unit that could potentially contain the most regulated flammables was assumed to be liquid full, the vessel inventory released instantaneously, completely vaporized and ignited resulting in a v apor cloud explosion. The possibility of any of these scenarios occurring is extremely remote. We have numerous controls to prevent such releases and to manage their consequences but no credit for any control measures was taken into account in evaluating these worst case scenarios. If these unlikely scenarios did ever occur, the only worst case scenario that could affect the general public would be the release of the hydrocarbon in Crude Unit 3 overhead receiver vessel when it was liquid full. The maximum distance to a 1 psi endpoint for this worst case scenario is about 1200 feet. This scenario would affect 4 homes East of the refinery along Old Richardson Highway. These homes are 840 feet to 1050 feet from Crude Unit 3 overhead receiver. The Worst Case Scenario for Crude Unit 2 assumes the instantaneous release of all the contents of the overhead receiver when it is liquid full and results in a vapor cloud explosion. This scenario would have an affect on the Petrostar Refine ry South of the Williams Alaska Petroleum, Inc. North Pole Refinery. The 1 psi endpoint is near the North boundary of the Petrostar Refinery. Worst Case Scenarios for Crude Unit 1, Extraction Unit and the Tank Farm were also analyzed. None of these scenarios had any impact on any public receptors. The Alternative Release Scenario for flammables at the refinery is a vapor cloud explosion resulting from the rupture of Crude Unit 3 overhead receiver vessel while containing a normal liquid level (one-half full). This scenario would also affect the four homes East of the refinery along Old Richardson Highway. With the controls and accident prevention program in place it is highly unlikely that this scenario would ever occur. A more practical scenario for the Alternative Release Scenario is the release of hydrocarbon from a section of pipe that does not have flow through it (dead leg), freezes, cracks and then thaws out releasing hydrocarbon through the crack. If this occurre d in a 3" line, the resulting crack was 1 foot long and the leak continued for 30 minutes the distance to a 1 psi endpoint would be 364 feet. No public receptors would be affected. It is unlikely the crack would be one foot long and the leak would continue for 30 minutes. These are very conservative estimates used to indicate the type of leak that could occur without affecting any public receptors. Five Year Accident History The Williams Alaska Petroleum, Inc. North Pole Refinery has an outstanding record of accident prevention. Over the past five years there has been only one release from an RMP covered process that resulted in a minor injury to a contractor. The individual did not lose any work as a result of the injury. There have been no on site deaths, major injuries or significant property damage on any RMP covered process. There was an injury in Utilities, a non-RMP covered process, in 1998. A contractor performing maintenance on a heater was burned when some fuel was inadvertently released to the atmosphere and it flashed. There have been no offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damages for the life of the facility. General Accidental Release Prevention Program The following is a summary of the accident prevention program in place at the Williams Alaska Petroleum, Inc. North Pole Refinery. Refinery processes covered by the RMP regulation are also subject to the OSHA PSM standard. This summary addresses each of the accident prevention elements. As noted above, under Five Year Accident History, the refinery accident prevention program has been highly successful. Employee Participation The Williams Alaska Petroleum, Inc. North Pole Refinery encourages employees to participate in all facets of Process Safety Management and accident prevention. Examples of employee participation range from participation in updating operating procedures to participating as a member of a process hazar d analysis (PHA) team. Employees have access to all information created as part of the refinery accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an Employee Participation plan that is maintained at the refinery. In addition, the refinery has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process and personnel safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. Process Safety Information The Williams Alaska Petroleum, Inc. North Pole Refinery keeps a variety of technical documents that are used to help maintain safe operation of the processes. The Unit Operating Manuals are the primary source of the Process Safety Information the employees need to operate the facility in a safe and environmentally sound manner. The Ope rating Manuals contain information on chemical properties and associated hazards, process chemistry, limits for key process parameters and specific chemical inventories and equipment design basis/configuration information. They also contain safety-related limits for specific process parameters (e.g., temperature, level, composition) for each specific process unit. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The Operating Manuals are readily available to employees on the computer network or in hard copy in the control room. The Operating Department is assigned responsibility for maintaining up-to-date process safety information in the manuals. The manuals do reference other documents that contain additional process safety information, including Material Safety Data Sheets. The Material Safety Data Sheets con tain chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations. 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 pressure and temperature ratings, electrical rating of equipment, etc. The process safety 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 Williams Alaska Petroleum, Inc. North Pole 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 ade quate controls are in place to manage these hazards. The refinery 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. The analyses are conducted using a team of people who have operating, maintenance and safety 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 suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being i mplemented in response to PHA team findings are tracked on a computerized system until they are complete. The final resolution of each finding 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 refinery periodically updates and revalidates the hazard analysis 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 findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, tracked on the computerized system until they are complete and the final resolution of the findings is documented and retained. Operating Procedures The Williams Alaska Petroleum, Inc. North Pole Refinery maintains written procedures that address various modes of process operations, such as (1) unit startu p, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. The procedures and sections of the Unit Operating Manuals provides information and guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters, safety and health considerations and safety systems and their functions. The procedures and operating manuals can be used as a reference by experienced operators and provide a basis for consistent training of new operators. This information is readily available in hard copy or the computer network to operators in the process units and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, the Williams Alaska Petroleum, Inc. North Pole Refinery has a comprehensive training program for all employees involved in operating a process. New employees receive basic operator t raining in refinery operations. After successfully completing this training, the operator trainee will receive unit specific operator training to learn process-specific duties and tasks. After operators demonstrate (e.g., through written tests, skills demonstration) they have adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. All of this training is documented for each operator when completed, including the means used to verify that the operator understood the training. Contractors The Williams Alaska Petroleum, Inc. North Pole Refinery uses contractors to supplement their work force on routine maintenance and construction activities. These contractors are required to perform their activities in the covered process units of the refinery. As a result of this contractor activity, the refinery has established procedures to ensure that contractors (1) perform work in a safe manner, (2) have the appropriate knowledge and skil ls, (3) are aware of hazards in the workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow 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 before they begin their work. In addition, the refinery evaluates contractor safety programs and performance during the selection process. Refinery personnel continually monitor contractor performance to ensure compliance with PSM standards. Pre-startup Safety Reviews (PSSRs) The Williams Alaska Petroleum, Inc. North Pole Refinery conducts a PSSR for most new facility or facility modifications that requires a change in the process safety information. The purpose of the PSSR is to ensure safety features, procedures, personnel, and the equipment are appropr iately 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 that supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR 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 Williams Alaska Petroleum, Inc. North Pole Refinery has not officially published their Mechanical Integrity policy although it is available on the local computer network. The document covers the majority of necessary elements of the PSM regulation. Written Preventative Maintenance Procedures (PMP's) and Standard Maintenance Procedures (SMP's) are also being developed. Equipment inspections and tests are carried out per applicable industry standards. Qualit y assurance is accomplished by document verification of materials upon receipt in the warehouse or jobsite. The refinery has established practices to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems. The basic aspect of this program includes performing inspections and tests and correcting identified deficiencies. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible). These activities have historically maintained the mechanical integrity of the process equipment. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) emergency response plans, (4) applicable safe work practices and (5) task specific training to help ensure that they can perform their job in a safe manner. Safe Work Practices The Williams Alaska Petroleum, Inc. North Pole Refinery has long-standing safe work practices in place to help ensure worker and process safety. Examples of these practices 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 ensure that adequate precautions are in place before entry into confined space and (5) a permit system to control work in the refinery, both cold and hot work. A hot work permit is required for any type of work that could provide a source of ignition - i.e. spark producing activities. The hot work permit procedure requires that, (1) no combustible or flammable materials be in the area (2) fire protection be in place prior to beginning hot work operations, (3) dates be in place indicating when hot work is authorized, (4) the object being worked on is identified, and (5) that the permit is kept until the job is complete. The above safe work practices (and others), along with the training of personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Williams Alaska Petroleum, Inc. North Pole Refinery 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 maintenance personnel are provided any necessary trai ning on the change. Incident Investigation The Williams Alaska Petroleum, Inc. North Pole 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 recurrence, and forwards these results to refinery 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 reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Emergency Planning and Response Program Information The Emergency Response Plan is an element of the refinery PSM program but it is discussed below under the Emergency Response Plan Section since it is a separate section of the Risk Management Plan. Trade Secrets The Williams Alaska Petroleum, Inc. North Pole Refinery does not maintain any trade secrets. All necessary information is available through various refinery systems to help ensure the employees can perform their jobs in a safe and environmentally safe manner. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Williams Alaska Petroleum, Inc. North Pole 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 three years. The audit findings are forward ed to management for resolution. Corrective actions taken in response to the audit team findings are tracked until they are complete. The final resolution of each finding is documented and the two most recent audits are retained. Specific Prevention Steps Processes at the Williams Alaska Petroleum, Inc. North Pole Refinery have hazards that must be managed to ensure a continued safe operation. The accident prevention program summarized previously applies to the entire refinery. This program helps prevent accident scenarios that could be caused by equipment failures and human errors. In addition to the accident prevention program, the Williams Alaska Petroleum, Inc. North Pole Refinery also has many safety features on the process units to help contain/control a release, quickly detect a release, and reduce the consequences of a release. The following types of safety features are used in various process units: Release Detection 1. Hydrocarbon detectors with alarms 2. Low pressu re alarms 3. Low flow alarms Release Containment/Control 1. Relief valves that discharge to a flare to capture and incinerate possible releases. 2. Valves to permit isolation of the process. 3. Automated shutdown systems for specific process parameters 4. Redundant equipment and instrumentation Release Mitigation 1. Fire suppression and extinguishing systems 2. Trained emergency response personnel 3. Personal protective equipment 4. Location of process units control building out of the process area to help protect control equipment and personnel Emergency Response Program Information The Williams Alaska Petroleum, Inc. North Pole 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 aspect s 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 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 refinery has an onsite emergency response team qualified to respond to refinery emergencies. It is composed of refinery employees that volunteer for the team. Members are provided classroom, event simulation and hands-on training for eme rgency situations. Annual fire fighting training is provided to team members at a reputable offsite fire fighting school. The overall emergency response program for the Williams Alaska Petroleum, Inc. North Pole Refinery is coordinated with the City of North Pole Fire Department and the North Star Fire Department. This coordination includes periodic meetings with local emergency response officials, local government officials, and industry representatives. The refinery also conducts emergency drills that include the local emergency response organizations. Around-the-clock communications capability exists with appropriate emergency response organizations (e.g., North Pole Fire and Police Departments and the North Star Fire Department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. The refinery Process Safety Manager is a member of the Fairbanks, Alaska Local Emergency Planning Committee (LEPC). He regularly attends the LEPC meetings to ensure an open line of communication between the committee and the refinery. Planned Changes to Improve Safety We have an excellent record managing safety risks associated with the physical conditions in the plant but we are continually striving to improve. In our efforts to improve safety we recently contracted with a safety expert to assist us in establishing a behavioral-based safety system. An employee Safety Steering Committee is in the process of designing a safety system that addresses the individual and corporate management of risks associated with both physical conditions and peoples behavior. We believe this program will improve our efforts to protect people, property and the environment. NOTES: In Section 1(Registration Information), question 1.12, we supplied one Title V air operating permit number (9531-AA004). We also currently have another permit covering Crude Unit 3, permit number 9831-AC005. Space was not available t o enter both permit numbers. These permits are currently being revised and we should have only one permit in the future. |