Ultramar Inc., Wilmington Refinery - Executive Summary |
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This report documents Ultramar Inc. risk management program and Risk Management Plan (RMP) for its Wilmington California Refinery. The RMP document was prepared according to the requirements of 40 CFR Part 68 of the EPA RMP Rule [1], "Accidental Prevention Requirements, Risk Management Programs Under the Clear Air Act, Section 112(r)(7)," June 20, 1996. [CAA 112(r)(7)]. The Refinery operates a variety of processes to produce petroleum products, such as gasoline, natural gas, propane and butane, from raw crude oil. The Refinery is located in a heavy industrial area in Wilmington between the Ports of Los Angeles and Long Beach, approximately two miles north of Terminal Island; it employs 414 full time staff. The Refinery is comprised of forty-two processes, fourteen of which are subject to the Federal RMP Program Level 3 rules. It must submit a single RMP for the entire refinery, because it handles several listed regulated substances that exceed RMP listed threshold quantities (TQ) . In complying with OSHA PSM and EPA RMP Program Level 3 requirements, the Refinery developed a Process Safety Risk Management System to address Accident Prevention and Emergency Response. Refinery managers and supervisors in process engineering, project design engineering, operations, maintenance, and safety have primary responsibility for implementation and maintaining element compliance. Mr. Steve Faichney has the designated authority for integration and continuous audit of all RMP elements. For the past 5-years, the Refinery has had no accidents with offsite impacts. Several minor accidental releases of hydrocarbons and toxic materials did occur. However, neither injuries nor significant property damage occurred (on-site and off-site) due to the effectiveness of the Company's emergency response procedures. The EPA regulated toxic materials handled are anhydrous ammonia, aqueous ammonia, hydrogen fluoride and hydrogen sulfide, which are stored in quantities that exceed TQs. The SLAB dispersion model (a recognized public domain code) was used to determine which toxic releases would yield the greatest offsite distance and whether a release could impact a unique population group. Based on these analyses, worst case toxic releases due to complete rupture of an HF surge drum produced the greatest offsite consequences, which encompassed potential worst case releases of the other toxic materials. Administrative control limits the vessel quantity to less than 87.5% of its maximum; this was considered in the evaluation. Four toxic "alternative release scenarios" were analyzed. After a review of the Refinery's 5-year accident history and prior relevant California's Risk Management and Prevention Program (RMPP) studies, the alternative toxic release scenarios selected, which are considered more likely to occur than the worst case scenario) are: 1. Rupture of a gasket in one of the lines from the ammonia storage vessel (V-9004) to the vaporizer, resulting in a release of anhydrous ammonia from a 1/64" valve seal opening (valve seat diameter = 2 inches). The resulting ERPG-2 (200 ppm or 0.14 mg/L) endpoint distance, 0.13 miles using the SLAB model, barely impacts offsite receptors. 2. Release of hydrogen fluoride from a flexible hose between a truck and an HF storage drum, and spill of liquefied HF to grade. Water curtains will reduce the quantity of HF vapor released to the air by at least 90%. The ERPG-2 (20 ppm or 0.016 mg/L) endpoint distance using the SLAB model is 0.38 miles, which wil have a minor impact to about 50 residents to the north and south-east of the facility. 3. Release of hydrogen sulfide from a pipe between a vessel and vessel valve. It was conservatively assumed that the total contents of hydrogen sulfide in the process would be released before termination measures could be implemented. The ERPG-2 (30 ppm or 0.042 mg/L) endpoint distance for this alternative scenario using the SLAB model is 0.2 miles, which resu lts in minor offsite impact to the north-west side of the facility. 4. Failure of a feed pump gasket in an ammonia storage vessel, resulting in release of aqueous ammonia (30% concentration) from a 1/32" valve seal opening to a diked area. The resulting ERPG-2 (200 ppm or 0.14 mg/L) endpoint distance using the SLAB model is 0.05 miles, which has no offsite impacts. The refinery handles regulated flammable materials in several processes. Two co-located tanks containing liquid n-butane store the largest inventories of flammable materials. The n-butane tank located closest to the fence-line was selected as the only candidate worst case scenario for flammable substances. All other inventories of flammable materials stored at the Refinery would, if released catastrophically, produce a 1-psi overpressure endpoint that is encompassed by a release from the selected tank containing n-butane. There are no administrative controls and passive mitigation measures were not considered. Theref ore, the full n-butane inventory was assumed to release, completely vaporize and explode, resulting in a VCE. Using the RMP worst-case assumption, the maximum distance to the 1-psi overpressure endpoint for this vapor cloud explosion is 0.78 miles, which would affect about 1200 residents surrounding the plant. Based on a review of the Refinery's 5-year accident history and California's RMPP studies, the most likely alternative scenario is a leak in the 2-inch discharge line of a butane vessel. A trained operator will likely isolate the leak within 10 minutes. Such a release could result in a pool fire, a flash fire, a BLEVE, or a VCE. A BLEVE was considered unlikely, but the others were analyzed to determine which produced the greatest flammable endpoint. Of these, radiant heat from a pool fire yields the greatest endpoint distance of 1,256 feet. The effects of this pool fire were determined using the methods published in the RMP OCA Guidance Document, Appendix D. The Refinery maintains a Process Safety and Risk Management System (PSRM), which was developed during the implementation of OSHA Process Safety Management (PSM). It is focused on preventing and minimizing the consequences of releases of toxic, flammable and explosive chemicals. Manager and Supervisor level responsibility for the PSRM system is divided into specific RMP Prevention Program element assignments. The following is a summary of the Process Safety and Risk Management System in place at the Refinery. Employee Participation Employees participate in all areas of process safety management and accident prevention. Employee involvement is detailed in the Refinery's "Employee Participation and Information Accessibility Plan". Employee participation in RMP prevention program elements occurs through involvement, consultation and access to information. In addition to participation in PHA's, procedure development and audits, employees participate in Area Production Teams and the Health & Safet y Committee process to monitor, evaluate and improve, process safety. Proposed changes that impact process safety are routinely reviewed. Employees have access to all information created as part of the refinery process safety management and accident prevention program through manuals and electronic media. Process Safety Information The Refinery maintains a variety of technical documents to ensure safe operation of each process. They address chemical properties and associated hazards, key process parameter limits and specific chemical inventories, and equipment design basis/configuration information. Hazardous chemical information, including exposure hazards, emergency response and exposure treatment, is provided in material safety data sheets (MSDSs). This information is supplemented by reports that address corrosion and hazards of inadvertent chemical mixing. Employees are trained annually in the procedures of the "Wilmington Hazard Communication Instructional Plan", which pr ovides information on processing and handling hazardous material. Process technology information, including process flow diagrams, descriptions of process chemistry, maximum intended inventories and safe operating limits is available to all process personnel, electronically and in manuals. Safety-related limits for specific process parameters (e.g., temperature, level, and composition) is documented and used in process hazard reviews to evaluate the consequences of process deviations. The Refinery maintains numerous technical documents that provide materials of construction, design pressure and temperature ratings, electrical rating of equipment and other information. 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 process safety features are not compromised. Process Hazard Analysis The Refine ry maintains a comprehensive program to ensure that process hazards are identified and controlled. Each process is systematically examined to identify hazards and ensure that adequate controls are in place. The hazard and operability (HAZOP) analysis technique is primarily used to perform these evaluations. It is conducted by a team of people with operating and engineering expertise to identify and evaluate process hazards and mitigation measures. PHA findings and recommendations are prioritized, recorded and tracked to resolution. Production teams are responsible for addressing recommendations through procedural, hardware, software, and administrative control improvements. The final resolution is documented and retained. To ensure that process controls and/or process hazards do not deviate significantly from the original design safety features, the Refinery periodically updates and revalidates hazard analysis results. These periodic reviews are conducted at least every 5 year s and will be conducted at this frequency until the process is permanently shut down. Operating Procedures The Refinery maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures are used as a reference by experienced operators and provide a basis for consistent training of new operators. They are periodically reviewed and revised to reflect changes made through the "Management of Change Process" and annually certified as current and accurate. In addition, Operating Limit and Consequences of Deviation documents are maintained, which specify response to exceeding upper or lower limits of process or equipment parameters. Training The Refinery has implemented a comprehensive training program for all process employees.. The program is described in the Refinery's "Training and Promotion Policy". New employees receive orientation and basic process hazards overview training in refinery operations. On successful completion of training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After demonstrating the ability to perform the duties and tasks in a safe manner (e.g., through test, skills demonstration), an operator is allowed to work independently. All operators periodically receive refresher training, at least every 3 years. Contractors Refinery procedures ensure contractors perform work in a safe manner, have appropriate knowledge and skills, are aware of workplace hazards, understand what to do in an emergency, follow safety rules, and inform refinery personnel of hazards encountered during their work. This is accomplished by providing contractors with (1) a process overview, (2) information on safety and health hazards, (3) emergency response plan requirements, (4) safe work practices prior to beginning work and (5) testing to ensure training is understood. Each contractor's safety program and performance are routinely evaluated to ensure they fulfill safety obligations. Pre-startup Safety Reviews (PSSRs) The Refinery conducts a PSSR for each facility modification that requires a significant change in process safety information. The purpose is to ensure safety features, procedures, personnel and equipment are appropriately prepared for startup prior to placing equipment into service. This review provides a final check to ensure construction according to design specifications, procedures are in place, a hazard review was performed, recommendations resolved, training of process unit employees completed and operational readiness of all supporting systems. The Refinery PSSR procedure requires participation from employees with expertise in process operations, engineering and safety. Mechanical Integrity The mechanical integrity program includes well-established practices and procedures to ma intain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) training, (2) written procedures, (3) inspections and test, (4) correcting identified deficiencies, and (5) applying quality assurance measures Training of maintenance personnel includes (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. Written procedures ensure work is performed consistently and provide a basis for training. Inspections and tests ensure equipment functions as intended and verify acceptable limits. Proactive service and data collection is performed by the Maintenance Equipment Reliability Department to ensure safe operation and high efficiency of process equipment. Quality assurance measures are incorporated into equipment purchases an d repairs to ensure suitability for intended use and proper materials and spare parts are used. Safe Work Practices The Refinery has long-standing safe work practices, permits and procedures to ensure worker safety. Examples include control of the entry, presence and exit of support personnel; lockout-tagout to ensure isolation of energy sources during maintenance; safe removal of hazardous materials before opening process piping or equipment; control of spark-producing activities (i.e., hot work permit); and adequate precautions before confined space entry. Management of Change (MOC) The Refinery MOC system requires that changes to items such as process equipment, chemicals, technology, procedures, and other facility changes be properly reviewed and authorized by production teams before implementation. Changes are reviewed to (1) ensure a sound technical basis, (2) consider potential impacts to safety & health, 3) verify that existing controls will not be compromised, 4) affect ed chemical hazard information, process operating limits, equipment information and procedures are updated and 5) operating and maintenance personnel are provided necessary training. Incident Investigation All incidents that result, or could result, in a fire/explosion, toxic gas release, major property damage, environmental loss or personal injury are investigated within 48 hours. Facts are determined and corrective actions developed to prevent recurrence. The investigation team develops recommendations for resolution by area production teams and Refinery Management. Corrective actions in response to a team's recommendations are tracked to completion by the Refinery Safety Department. Investigation results are reviewed with relevant employees and contractors; reports are retained for at least 5 years for use during PHA revalidation. Compliance Audits The Refinery periodically conducts audits of the Process Safety and Risk Management System to ensure maintenance of procedures and practices required by the Accident Prevention Program. They are conducted at least every 3 years (PSM Tri-Annual audits). The audit team's develops findings, which are resolved by area production teams and Refinery Management. Corrective actions are tracked until completion; final resolution of each finding is documented and the two most recent audit reports retained. Chemical-Specific Prevention Steps Prevention program activities address equipment failures, human errors and PSRM system deficiencies. In addition to these activities, the Refinery has safety features on many units to (1) contain and control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The specific safety features used are detailed in Section 7 if the RMP Data Elements. Five-Year Accident History The Refinery has an good record of accident prevention. In the past five years, no release has resulted in adverse impacts to the plant or offsite. Emergency Response Program In formation The Refinery maintains a written emergency response program to protect workers, the public and the environment. The program consists of procedures for responding to a regulated substance release. It addresses all aspects of emergency response, including first-aid and medical treatment, evacuation plans and accounting for personnel, notification of local emergency response agencies and the public and post incident cleanup and decontamination. In addition, the Refinery has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address their use. Employees receive training in these procedures as necessary to perform emergency response duties. The emergency response program is reviewed annually and updated based on modifications made to refinery processes or other refinery facilities. The emergency response program is coordinated with the Los Angeles City Fire Department (L.A.F.D). This provides a means of notifying the public, as well as facilitating quick response. The L.A.F.D. periodically participates in drills with the Refinery's emergency response team and are familiar with the Refinery and the hazardous materials in each process unit. In addition, the Refinery is a member of the "Mutual Aid Response Group" that consists of other local refinery emergency response teams, which would provide additional support if needed. The Refinery conducts quarterly emergency drills that involve refinery emergency response personnel. Periodic refresher sessions are conducted for the L.A.F.D. emergency responders regarding the hazards of regulated substances in the refinery. Planned Changes to Improve Safety The Refinery addresses all findings from PHAs that provide opportunities to improve safety. The Refinery is committed to accident prevention and loss control through personnel training programs, considering safety in design, installation, operation and maintenance of processes and implem entation of controls to prevent releases of regulated substances. However, if a release does occur, trained personnel will respond to control and contain the release in coordination with the City of Los Angeles Fire Department. |