Chevron Products - Hawaii Refinery - Executive Summary |
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Chevron Hawaii Refinery Risk Management Plan Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Chevron Hawaii Refinery and all of its employees utilize the best efforts to maintain safe and healthful working conditions. The Refinery Safety Policy includes the following guidelines for all employees. 7 Work is never so urgent or important that we cannot take time to do it safely and correctly. 7 All accidents are preventable. 7 All employees have a responsibility to work safely and to not endanger others by their acts or omissions. 7 Management and supervisors have overall accountability for the safety of all persons in the work place. 7 Safety is a condition of employment for all employees. All employees will be held accountable for their own safety performance. Chevron's Policy 530 - Protecting People and the Environment The Chevron Refinery is committed to protecting the safety and health of people and the environment. As such, business is c onducted in a socially responsible and ethical manner. The company's goal is to be the industry leader in safety and health performance, and to be recognized worldwide for environmental excellence. This goal is achieved through designing, operating, and maintaining facilities to prevent injury, illness, and accidents. Of equal importance in achieving this goal is open communication with the public regarding the possible impact of our business on them or the environment. The policy also states that the company shall be prepared for any emergency and shall mitigate any accident quickly. DESCRIPTION OF SOURCE AND REGULATED SUBSTANCES HANDLED The Chevron Hawaii Refinery is located on the island of Oahu, Hawaii. The Refinery receives crude oils via tanker for processing into various products. The process by which crude oil is manufactured into various saleable products (for example, gasoline, kerosene, propane, etc.) is known as refining. Petroleum refining involves the separation of crude oil into several components using distillation methods. Heavier hydrocarbon compounds are further processed by cracking and subsequent combining or rearranging. Many of the refining processes include the formation, combining, or rearranging of regulated flammable substances. Those regulated flammable substances on location at the Chevron Hawaii Refinery include: hydrogen, methane, ethane, ethylene, propane, propylene, propadiene, butane, butene, 1,3-butadiene, 2-methylpropylene, and pentane. These substances are generally handled as part of a flammable mixture. HAZARD ASSESSMENT RESULTS The worst-case scenario associated with a release of flammable substances from Program 3 processes at the Refinery is a vapor cloud explosion involving the largest storage tank containing liquefied petroleum gas (LPG). The worst case assumes that the full tank inventory (accounting for administrative controls that limit the volume to 47% full) is released, completely vaporized, and ignit es resulting in a vapor cloud explosion. This scenario would reach offsite and impact nearby public receptors. However, this scenario is very unlikely as the Refinery has controls in place to prevent this type of event that include pressure relief valves on the tank, the Refinery Emergency Response Team, and the physical location of the LPG area away from the process area ignition sources. For this case however, none of these mitigation measures were considered. The alternative release scenario for flammable substances in Program 3 processes at the Refinery is a large release (2-inch line break) from the Dimersol Plant reactor. If the resulting vapor cloud were to ignite, this scenario could also reach offsite and impact nearby public receptors. No active or passive mitigation measures that limit the endpoint distance were considered for this scenario. The Refinery has several programs in place to prevent accidents of this nature. A detailed explanation of these programs foll ows. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Chevron Hawaii Refinery. Because processes at the Refinery that are regulated by the EPA RMP (Risk Management Process) regulation are also subject to the OSHA PSM (Process Safety Management) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. The objective of the PSM system is to reduce the consequences of and potential for accidents in the Refinery. Accidents could include fires, explosions, toxic gas releases, spills, product quality problems, etc. Employee Participation Refinery teams that are specifically dedicated to safety and safe behaviors include the Refinery Safety, Fire, and Health, Council and the Chevron Accident Reduction Environment (CARE) group. The Refinery encourages participation in Process Safety Management through training and the development of cross-functional teams to perform process hazards analyses. The importance of Refinery safety is mentioned as part of every organizational meeting. Safety topic presentations are included as part of meeting agendas and responsibility for these presentations is rotated among employees to give everyone a chance to participate. Operations safety meetings are held on a routine basis and involve all operators as participants and/or presenters. Safety Audits Periodically the Refinery is subject to company internal audits. These audits include Industrial Hygiene surveys, Fire, Loss Prevention surveys, and Corporate Safety, Fire, and Health Compliance Reviews. These audits/surveys insure that the facility is in compliance with recommended practices, policies, and government laws and regulations. Safety Meetings Safety meetings are conducted daily for operators and weekly for maintenance and other technical personnel. Periodic reviews of operating sta ndards and safe work practices are conducted in formal one hour sessions. Management personnel coordinate the meetings or participate as observers to answer concerns of employees. Safety, Fire, and Health Council The Refinery Safety, Fire, and Health council is made up of members from all levels and work groups in the Refinery. The council addresses overall safety, fire and health programs and serves as a communications channel between work groups and the Refinery Management Team. The council helps and evaluates the effectiveness of the programs, and works towards addressing work force concerns. Chevron Accident Reduction Environment Chevron Accident Reduction Environment (CARE) is an employee led, behavioral and action-based way of approaching worker safety. Chevron uses BST, Inc. as the consultant for our process. CARE will highlight types of risks present in everyday jobs. Once these risks are highlighted, they are addressed. Once a month there is a problem-solving meet ing with the participants as a whole to discuss "at risk" behaviors/situations affecting the workgroup. The group decides the best way to handle highlighted problems. Refinery management and supervisory personnel support this practice by participating in meetings, using the data for problem solving and reinforcing the need to take time for observations. Process Safety Information Process Safety Information is one of several elements of the Refinery's Process Safety Management (PSM) system. Each Refinery plant or process area has a Process Safety Information manual that contains a compilation of safety and design related information. Its purpose is to train and inform employees and contractors of the hazards, safety precautions, and design related limits for the units. Process Hazard Analysis The Chevron 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 sys tematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. Process Hazard Analysis (continued) The primary technique used to perform these evaluations is known as the hazard and operability (HAZOP) analysis. A HAZOP study is a systematic review of existing or proposed new equipment Piping and Instrumentation Diagrams (P&IDs) or significant modifications to existing P&IDs for possible deviations from the normal design intent. A HAZOP is conducted by a team of people with expertise in engineering and process operations. The 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. A final list of action items is reviewed with the Refinery Management Team and after concurrence, is distributed for follow-up. This action item list is tracked to ensure tha t all follow-up items are completed in a timely manner. Completed items are documented, and a copy of this document is placed in the HAZOP study manual. HAZOPs are revalidated at least every five years. The revalidation includes a review of the changes (design, regulatory, etc.) that have taken place in the process since the last HAZOP and includes suggestions for additional prevention and/or mitigation measures as with the initial HAZOP. Operating Procedures The Refinery maintains written operating procedures that address each Plant's operational processes including start-up, normal operations, emergency shutdown, planned shutdown, and the initial start-up of a new plant or after a planned maintenance shutdown. These procedures are available to operations personnel and serve as a basis for training new operations personnel. These procedures are periodically reviewed and revised as necessary through the management of change process. Training The Refinery also has an active an d comprehensive training program for all operations personnel that serves to build on the operating procedures mentioned above. All new operations personnel must complete an initial four week training session before entering a plant for duty. Once in the Refinery, new operations personnel "piggy-back" with more experienced operators before taking on full responsibility for his or her duties. After a new operator demonstrates the skills necessary to operate on his or her own, they can work independently. In addition, operations personnel receive refresher training on operating procedures at least every 3 years to ensure that their skills and knowledge are maintained. All training is documented and kept on record in the Refinery's Training and Development Department. Contractors The Chevron Refinery uses contract personnel to supplement maintenance work and also during planned shutdowns and construction activities. Contractors are hired based on their past safety performance, saf ety attitude, present programs and practices, and most importantly their projected capability to achieve an acceptable safety performance and compliance with applicable environmental and safety regulations. All contractors are required to attend a Contractor Safety Orientation Program before being allowed to work within the Refinery. Training consists of the Refinery safety policy and rules, the emergency action plan, and the Refinery drug and alcohol policy. Process hazards and alarms are also covered as part of this training as well as an overview of environmental requirements. Contractors who will be in the Refinery for more than one week are required to attend weekly tailgate safety meetings. Weekly safety audits of contract personnel are also conducted either independently by the contractor or jointly with a Chevron representative to ensure that safety standards are being met. Pre-startup Safety Reviews (PSSRs) The Process Safety Management (PSM) regulation mandates that a pre-startup safety review must be conducted on new facilities and modified facilities when the modification is significant enough to require a change in the process safety information. The purpose of the pre-startup safety review (PSSR) is to insure that prior to startup, refinery equipment is reviewed to determine whether it is safe to operate, and meets all applicable requirements of Company standards, good engineering practices, industry codes and practices, and local, State, and Federal codes and statutes. The (PSSR) consists of several independent reviews which include a Plant Protection Review, an Environmental review, an Operational Readiness Review, and confirmation that training of all employees involved in the equipment operation or maintenance has been completed. Mechanical Integrity Mechanical Integrity includes all activities required to ensure proper design, construction, and ongoing integrity and reliability of equipment in order to prevent or minimize incidents for the life of the equipment. The Refinery has several written programs in place that detail well-established practices and procedures for the inspection, testing, monitoring, and maintenance of process equipment, tankage and utilities, and instrumentation and safety systems. Training is routinely conducted on these practices and procedures are periodically reviewed and updated. The Refinery also has an Integrated Mechanical Inspection (IMI) Department that is responsible for identifying machinery-related problems and promoting solutions concerning critical machinery. Members of the IMI department are consulted whenever buying new machinery or when a machine design change is being considered. Safe Work Practices The Chevron Refinery has safe work practices in place that help ensure worker and process safety. Examples of these include but are not limited to: 1) the control of personnel into confined spaces or other hazardous work areas, 2) a lockout/tagout procedure to ensure isolation of electrical sources for equipment undergoing maintenance, 3) procedures for the safe removal of substances that may be hazardous before equipment is opened for inspection and/or maintenance, 4) a permit procedure to control activities that may be a source of ignition (i.e. hot work), and 5) the controlled entry of personnel into plant areas. The Refinery safe work practices along with training of personnel who may be involved with these types of work form a system that aides in making sure that operations and maintenance activities are performed safely. Management of Change Management of Change (MOC) is one element of the Refinery's Process Safety Management (PSM) system. The purpose of MOC is 1) to anticipate incidents that could be created by a change, as well as health and safety issues, and 2) design the change in a way that reduces the likelihood of incidents. Management of Change applies to all changes to Refinery equipment, processes, feeds, chemicals, procedures or technology. The MOC process involves as applicable a review of equipment design, construction, and siting, fire protection, electrical classification, as well as a review of all associated documents and manuals for proper update of the change. The change passes through several phases of review with an emphasis placed on the type of change and the impact of that change. The MOC requests are tracked, and once all the required reviews are completed the MOC is given an "authorization to implement change" approval. A copy of the signed MOC documentation form accompanies all copies of the work request for Operator and Mechanic review. Completed MOC documentation is retained for a minimum of five years. Training about the change is provided to affected personnel. Incident Investigation The intent of the Chevron Refinery incident investigation program is to learn from the incident, prevent a recurrence, and help prevent similar incidents. An incident investigation addr esses the following: 1) the nature of the incident, 2) the factors that contributed to the incident, and 3) recommendations identified as a result of the investigations. The investigation determines the root cause of the incident and may include interviewing involved personnel, as well as reviewing process and equipment data, applicable procedures, operating conditions and training records. The Tap Root Incident Investigation technique is used as the guide for all investigations. All incidents that have the potential to impact personnel or the environment are investigated. Compliance Audits The Refinery Process Safety Management program is audited periodically to ensure that procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three years with an audit team comprised of management and operations personnel. The audit team develops findings that are forwarded to Refinery management for resolut ion. 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 kept on file in the Process Safety Management Coordinator's office. CHEMICAL-SPECIFIC PREVENTION STEPS Refinery processes have hazards associated with them that must be managed to ensure continued safe operation. The Process Safety Management program that has been discussed in this document applies to all RMP processes at the Refinery. The program activities as a whole reduce the likelihood of accident scenarios that could be due to equipment failure and/or human error. The Refinery also has safety features within the process units that are designed to quickly detect, contain and control, and reduce the consequences of the release. The following is a listing of various safety measures used in Refinery processes: Release Detection: Low/High Pressure Alarms, Low/High Level Alarms, Hydrocarbon Detection Alarms. Release Containment/Control: Process relief valves that are designed to relieve to the flare system for incineration, Automatic shutdown systems, Bermed areas to contain liquid releases, Spill containment equipment - absorbent pads and boom, Redundant equipment and instrumentation (continuous power supply for control systems, backup pumps, atmospheric relief devices, etc.) Release Mitigation: Fire Suppression and extinguishing systems, Deluge System for specific equipment, Emergency Response Team (ERT), Personal protective equipment, Blast-proof central control building to help protect control systems and personnel. FIVE YEAR ACCIDENT HISTORY The Chevron Refinery has an excellent record of accident prevention. Over the past five years. there have been no accidents involving RMP regulated substances. As previously mentioned every Refinery "near miss" or accident that does occur is thoroughly investigated and the root cause determined. Lessons lear ned from the investigation are documented and communicated throughout the Refinery to prevent similar accidents from occurring. Any recommendations resulting from the investigation that indicate a need for changes in operating procedures are implemented. EMERGENCY RESPONSE PROGRAM INFORMATION The Refinery maintains a written emergency response plan that describes procedures to protect worker safety and the environment. The plan 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 released accidentally. The plan includes procedures and information on all aspects of emergency response, including the incident command system which is the organizational structure used during emergency response, fire fighting equipment and procedures, internal and external assistance and equipment resources, first aid and medical attention procedures, evacuation plans, and notification procedures for gov ernment agencies in the event of an offsite or reportable release. There are also procedures in place for the testing and maintenance of emergency response equipment and procedures for equipment operation. Hypothetical drills are conducted on a regular basis. These drills create and sustain a high degree of accident response awareness by creating "what if" situations which stimulate thinking and improve readiness of personnel to cope with a variety of emergency situations. Hypothetical drills include plant drills and formal drills. During a plant drill different operating situations that may be a potential fire problem are presented and the group goes through the motion of putting out the fire. Others personnel in the Refinery may be asked to participate depending on the degree of the drill and apparatus required. Formal drills are on a larger scale and are scheduled at least biannually. These drills can include outside agencies, and participants are to treat this hypothetica l drill situation as if it is a real fire and respond. The overall emergency response program for the Chevron Refinery is coordinated with the Oahu, Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which has members from the local emergency response community, local government officials, and industry representatives. The Campbell Industrial Park (CIP) where the Refinery is located has collective emergency management available by way of the CIP Emergency Management Plan. This plan compliments Refinery resources and is used as a focal point for coordinating emergency response and management for the Park. This plan along with the Refinery plan is used as reference during drills for notifications to the appropriate agencies and neighboring businesses. Tabletop drills are conducted on a periodic basis using the Plan and a hypothetical release scenario. The LEPC is involved in conducting these drills and other response agencies, Honolulu Fire Department, Honolulu Police Department are active participants. The Refinery has around-the-clock communications capability with appropriate LEPC officials and the fire department. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. Planned Changes to Improve Safety The Chevron Refinery resolves all findings from Process Hazards Analyses, some of which involve modifications to the process. The following types of changes are planned: Revisions to truck driver training for the Asphalt loading area. Revised process instrumentation monitoring in the LPG area. Revised written alarm checklist for the Hydrogenation Plant. Plans are also to expand the Chevron Accident Reduction Environment (CARE) to the entire Refinery workforce. Currently, the program is active in the Operations and Maintenance organizations in the Refinery. CARE highlights types of risks present in everyday jobs. Once th ese risks are highlighted, they are addressed. There are routine problem-solving meetings with the CARE participants to discuss "at risk" behaviors/situations affecting the workgroup. The group then decides the best way to handle highlighted problems. |