Chevron Pascagoula Refinery - Executive Summary
Chevron Pascagoula Refinery Risk Management Plan |
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Chevron Pascagoula Refinery and all of its employees utilize their best efforts to maintain safe and healthful working conditions. The Refinery Safety Policy includes the following guidelines for all employees.
7 We will operate in compliance with all applicable laws and regulations without regard to the degree of enforcement by regulatory agencies.
7 All incidents are preventable.
7 All employees have a responsibility to work safely and to not endanger others by their acts or omissions.
7 Safety is a condition of employment for all employees. All employees are held accountable for their own safety performance.
Additionally, employees understand that work is never so urgent or important that we cannot take time to do it safely and correctly. Two guiding principles at this Refinery are; "Don't think it is safe, know it is safe" and "There's always
time to do it right."
Chevron's Corporate Policy 530 - Protecting People and the Environment
It is the policy of Chevron Corporation to conduct its business in a socially responsible and ethical manner that protects the safety and health of people and the environment. The Chevron Refinery is committed to upholding this policy. 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 Pascagoula Refinery is located in Pascagoula, MS. The Refi
nery receives crude oil by tanker for processing into various products. The process by which crude oil is manufactured into various saleable products (for example, gasoline, 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. Regulated flammable substances are present at the Refinery as flammable mixtures. Primary components of the mixtures are propane, butane, pentane and propylene. Secondary components of the mixtures can include: hydrogen, methane, ethane, ethylene, butene, isobutane, isobutene, 2-butene-cis, 2-butene-trans, 1,3-butadiene, and isopentane.
The only regulated toxic substance that the refinery has above threshold quantities is anhydrous ammonia. Ammonia i
s an impurity in the crude and as the crude is distilled the ammonia is removed and sold as a product.
HAZARD ASSESSMENT RESULTS
A 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 specifically pentane). The worst case assumes that 25,000 barrels (5.6 million lbs) of pentane (the largest tank inventory) is released, completely vaporized, and ignites resulting in a vapor cloud explosion. This scenario would reach offsite and impact nearby public receptors. The worst case analysis does not consider the possible causes of the release or the probability that such a release might occur; the release is simply assumed to take place. It also assumes nothing is done to minimize the release.
Another worst case scenario that impacts different public receptors involves a shipping vessel for LPG at the product wharf. This worst
case assumes that a fully loaded tank of 10,000 barrels in the largest LPG shipping vessel fails. 1.8 million lbs of LPG (propylene, propane or butane) is released, completely vaporized, and ignites resulting in a vapor cloud explosion. This scenario would reach offsite and impact nearby public receptors. Again this worst case analysis does not consider the possible causes of the release or the probability that such a release might occur; the release is simply assumed to take place. It also assumes nothing is done to minimize the release.
The alternative release scenario for flammable substances in Program 3 processes at the Refinery is the failure of a loading hose while loading a vessel with LPG (specifically propane/propylene). If the resulting vapor cloud of 156,000 lbs (300 barrels) were to ignite, this scenario could reach offsite and impact nearby public receptors. If a release like this occurred our loading operator and contractor would immediately respond to stop the leak
by shutting down loading.
A worst case scenario associated with a release of a toxic substance from Program 3 processes at the Refinery is the total failure of a 150 ton anhydrous ammonia drum. The worst case assumes that the drum is full and the entire contents are released. This would result in a cloud of ammonia that would reach offsite and impact public receptors. Again this worst case analysis does not consider the possible causes of the release or the probability that such a release might occur; the release is simply assumed to take place. It also assumes nothing is done to minimize the release.
The alternative release scenario for ammonia is the development of a crack in a weld at the joint of the pipe and the drum shell. This would result in the release of 3300 lbs. of ammonia that would reach offsite but would not reach any public receptors. The Emergency Response Team would be notified and unit operators would route the drum to the relief system and help in setting up wa
ter sprays. Ammonia is very soluble in water and the release would be absorbed. Water sprays would be maintained until the drum was empty or the hole itself was plugged by our trained Hazmat team.
Worst case scenarios associated with the release of flammable mixtures from 22 Program 1 processes at the Refinery were also developed. Each scenario is a vapor cloud explosion from the largest vessel and piping system in that process. Modeling showed that these scenarios did not impact any public receptors. As before each of these worst case analysis's do not consider the possible causes of the release or the probability that such a release might occur; the release is simply assumed to take place. It also assumes nothing is done to minimize the release. Details for each Program 1 process follows;
Worst Case lbs Vessel System Process 1 Plant
55,000 C2440 Aromax
200,000 D1101 Crude I
24,000 D2920 Ethylbenzene
160,000 C1000 Olefin Splitter
260,000 C1605 FCC
530,000 D1701 A,B,C,D,E Alkylation I
100,000 C4020 Light Ends Recovery II
150,000 C210 MTBE
170,000 D2055 Light Ends Recovery I
110,000 D1305 Isomax I
39,000 D1503 Rheniformer I and HDS 1
170,000 C6101 Crude II
95,000 C6300 Reformate Distillation Unit II
100,000 C6590 Rheniformer II and HDS II
63,000 D6820 Distillate Treaters II
100,000 C6990 Rheniformer III
0 C7001 AFP & LSR Splitter
110,000 D6231 Isomax II
100,000 C6610 Gas Recovery Unit
120,000 C8330 Coker
80,000 R8510 Coker Hydrodenitrification
760,000 C8730 Alkylation II
All of these scenarios are very unlikely to occur. Controls in place to prevent these types of events include pressure relief valves on LPG tanks and other vessels, the physical location of the LPG area away from the process area ignition sources, design and inspection techniques of the ammonia system, high and low level vessel alarms, high and low level pressure alarms, highly trained operators, mechanics, inspectors, engineers and emergency response personnel.
Refinery programs are also in place to prevent accidents of this nature. A discussion of these programs follows.
RAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The section is a summary of the general accident prevention program in place at the Chevron Pascagoula 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.
The Refinery encourages participation in Process Safety Management through training and the development of cross-functional teams to perform process hazards analyses. Every organizational meeting is started with a short safety discussion. Safety topic presentations are includ
ed as part of meeting agendas and responsibility for these presentations is rotated among employees to give everyone a chance to participate.
Behavioral Accident Prevention Process BAPP (BST)
Employee safety participation is built upon the Behavioral Accident Prevention Process (BAPP) developed by Behavioral Science Technology, Inc. In this process, employees observe each other while performing their daily work for behaviors which might put them at risk for causing an accident. The employee being observed receives immediate feedback during the observation regarding their performance. The data from each observation is also collected on a checklist and input into a database. The data is then used on group and refinery levels to develop action plans to improve behaviors, procedures, and equipment. Each field employee receives initial and annual refresher training in this process. Approximately 1000 observations are performed per month.
This process is managed by organization
al employee steering committees that also provide input on other refinery safety initiatives related to work process improvements and regulatory compliance issues.
Refinery groups and their group names include;
1. Maintenance with S=AFE (Safe Equals Accident Free Environment)
2. Maintenance Contractor Administration with GATOR (Generating Awareness Through Observations Randomly)
3. Operations with LIFE (Long Term Incident Free Environment)
4. Purchasing and Materials Management with NEWS (Notice Employees Working Safely) and
5. Technical with PRIDE (Positive Reduction of Incidents by Dedicated Employees)
Periodically the Refinery is subject to company internal audits. These audits include Fire Loss Prevention surveys, Corporate Safety, Fire, and Health Compliance Reviews and Process Safety Management Audit. These audits/surveys insure that the facility is in compliance with recommended practices, policies, and government laws and regulations.
afety meetings are held on a routine basis throughout the Refinery and involve all employees as participants and/or presenters. Refinery teams that are specifically dedicated to safety and safe behaviors include the Management Incident Prevention Committee (MIPC), and the Behavioral Safety groups (LIFE, SAFE, PRIDE, GATOR and NEWS).
Process Safety Information
Process Safety Information is compiled prior to the start of a Process Hazard Analysis study of a plant. It is updated before the PHA or as the PHA is occurring. Process Safety Information includes but is not limited to safety instruction sheets, operating procedures, piping and instrumentation drawings, loop drawings and material safety data sheets. Most of this information is available electronically for easy access. Its purpose is to train and inform employees of the hazards, safety precautions, and design related limits for the units.
The Refinery maintains written operating procedures that addre
ss 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.
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 systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.
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 mo
difications 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 that 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 mi
tigation measures as with the initial HAZOP.
The Refinery also has an active and 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 five week training session before entering a plant for duty. Once at the plant, new operations personnel attend a unit school and "piggy-back" with more experienced operators before taking on full responsibility for his or her duties. Only after a new operator demonstrates the skills necessary to operate on his or her own are they allowed to work independently. In addition, operations personnel receive refresher training on operating procedures to ensure that their skills and knowledge are maintained. All training is documented and kept on record in the Refinery's Development Department.
The Chevron Refinery uses contract personnel to supplement maintenance work and also during planned shutdowns a
nd construction activities. Contractors are hired based on their past safety performance, safety 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 response plan, the drug and alcohol policy, process hazards and alarms and an overview of environmental requirements. Safety audits of contract personnel are 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 mo
dification 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 Design, Construction and Standard Review, Safety in Design Review, Plant Protection Review, an Environmental review, an Operational Readiness Review, and a Process Hazard Analysis (for new construction).
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 wel
l-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 helps ensure worker and process safety. Examples of these include but are not limited to:
1) the control of the entry, presence, and exit of personnel into confined spaces or other hazardous work areas,
2) a lockout/tagout procedure to ensure isolation of hazardous energy sources for equipment und
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 maybe 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 maybe 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) to 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.
The Process Safety Management (PSM) regulation mandates that an incident investigation must be conducted for every incident that resulted in or could have resulted in a release or fire in the workplace. Since we are committed to preventi
ng incidents and thereby protecting employees and our surrounding community we actually investigate more incidents than are required under the OSHA PSM law. We do this in an effort to understand and stop smaller problems from becoming larger problems which might lead to an incident.
The TapRooT Incident Investigation technique developed by System Improvements, Inc. is used on all major investigations. This investigation process helps identify the primary root cause(s) and may include interviewing involved personnel, as well as reviewing process and equipment data, applicable procedures, operating conditions and training records. The intent of an investigation is to learn why the incident happened and prevent a recurrence of it or similar incidents. Incident recommendations are tracked to completion.
The Refinery Process Safety Management program is audited periodically to ensure that procedures and practices required by the accident prevention program are being i
mplemented. 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 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 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 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:
7 Low/High Pressure Alarms.
7 Low/High Level Alarms.
7 Detection Alarms.
7 Process relief valves that are designed to relieve to the flare system for incineration.
7 Automatic shutdown systems.
7 Diked or bermed areas to contain liquid releases.
7 Spill containment equipment - absorbent pads and boom.
7 Redundant equipment and instrumentation (continuous power supply for control systems, backup
pumps, atmospheric relief devices, etc.)
7 Fire Suppression and extinguishing systems.
7 Deluge System for specific equipment.
7 Emergency Response Team (ERT).
7 Personal protective equipment.
7 Blast-resistant control building(s) to help protect control systems and personnel.
FIVE YEAR ACCIDENT HISTORY
Over the past five years there have been two acc
idents involving RMP regulated substance releases which had significant onsite property damage. Both accidents were LPG releases which resulted in fires. Our Emergency Response Team responded and these fires were brought under control with no employee injuries. These releases did not impact our community or environment. As previously mentioned Refinery incidents are thoroughly investigated and the root causes for these accidents were found to be equipment related. Investigation reports are documented and communicated throughout the Refinery to prevent similar accidents from occurring. Additionally any findings or recommendations for changes are tracked through their completion.
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 government agencies and community officials 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.
The Emergency Response Team (ERT) is highly trained and skilled. Team members have monthly training meetings and routinely attend offsite training for rescue skills, Hazmat response, foam application etc. Hypothetical drills are also 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. Other personnel in the Refinery may be asked to participate depending on the degree of the drill and apparatus required. Formal drills are scheduled at least biannually and are on a larger scale. These drills include an outside Ambulance Service and participants treat this hypothetical drill situation as if it is a real fire and respond. Public Officials from the Local Fire Department, Navy base and Singing River Hospital have been invited to participate or critique the drills.
The Refinery has recently purchased a 95 ft aerial platform truck, a 3500 gpm foam pumper truck and a new ambulance. Upgrades are als
o occurring for fixed fire water systems in process plants and the tankfield.
The overall emergency response program for the Chevron Refinery is coordinated with the Jackson County 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 Refinery has around-the-clock communications capability with appropriate LEPC officials. 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 Pascagoula Refinery is currently undergoing organizational redesign. As a part of this redesign, more focused safety responsibilities at the field level will be implemented. Field employees, called "star points" will be given more specific safety roles and will also provide better input for work process developme
Both refinery facilities and operational procedures will continue to be improved as a part of the findings associated with process safety management.
The refinery will also implement a clarified system of individual and team accountability with regard to safety. This is intended to clearly define each employee's role and responsibilities in improving workplace safety and includes a safety improvement plan written into each employee's performance plan.