Martinez Refining Company, Equilon Enterprises LLC - Executive Summary
The following is the Executive Summary for Martinez Refining Company's (MRC) Risk Management Plan (RMP) as required by the Risk Management Program Regulations. MRC's RMP is composed of three elements. These elements are: 1. Identification and Assessment of Hazards, 2. Prevention and Preparedness, and 3. Emergency Response. These three elements are summarized below. |
IDENTIFICATION AND ASSESSMENT OF HAZARDS
The MRC facility was reviewed for the storage/usage of chemicals from the list of covered chemicals. Through the review process, it was determined that MRC has both Aqueous Ammonia and Oleum in certain processes with sufficient quantities such that the processes containing these toxic chemicals would be covered by the RMP regulations. In addition, MRC has many processes that contain sufficient quantities of flammables to be covered by the regulations.
Both worst case scenarios (WCS) and alternative release scenarios (ARS) were developed for the Oleum and flammables. Likew
ise, an ARS was developed for the Aqueous Ammonia. The results of the scenario modeling are summarized below.
Worst Case Scenario (Oleum). Our WCS for a toxic is failure of an Oleum storage tank containing 372,000 pounds of 28% weight percent sulfur trioxide in Oleum. The Oleum is spilled into a 30 x 100 foot dike, which mitigates the release. Since MRC is located in a populated area, the toxic cloud formed by the evaporating sulfur trioxide would reach offsite endpoints and nearby public receptors.
Alternative Release Scenario (Oleum). Our ARS for Oleum is a failure of a loading hose while offloading Oleum. The Oleum is modeled as being contained by the truck loading berm. 57 gpm of Oleum is spilled over 20 minutes. The toxic cloud formed by the sulfur trioxide was modeled as reaching offsite endpoints and nearby public receptors.
Alternative Release Scenario (Aqueous Ammonia). Our ARS for Aqueous Ammonia is a failure of a loading hose while offloading Aqueous Ammonia.
The Aqueous Ammonia is modeled as being contained by the truck loading berm and sump. 110 gpm of Aqueous Ammonia is spilled over five minutes. The toxic cloud formed by the Ammonia was modeled and did not reach offsite endpoints.
Worst Case Scenario (Flammables). Our WCS for Flammables is failure of one pentane storage tank containing 10,000,000 pounds of pentane when filled to the greatest amount allowed, resulting in a vapor cloud explosion. Since MRC is located in a populated area, the pressure wave would reach offsite endpoints and nearby public receptors.
Alternative Release Scenario (Flammables). Our ARS for Flammables is a failure of a four inch pipe in a gasoline separation plant. The scenario is modeled as Flammables being released at a rate of 37,000 pounds per minute for less than five minutes. Since MRC is located in a populated area, the pressure wave would reach offsite endpoints and nearby public receptors.
ACCIDENT PREVENTION AND PREPAREDNESS PROGRAM
process units at MRC have hazards that are continually managed to ensure safe operation. The Martinez Refining Company's first objective is prevention of all accidents. Recognizing the possibility of an accident despite prevention efforts, the refinery places a high value on preparedness. Safety features are designed into or placed on many units to help control, detect, and minimize the impacts of a release. Some of these features are:
1. Elimination of Risk - The following changes have been implemented at MRC. In all of these cases, the changes have resulted in significant reduction of chemical risk. This risk reduction has greatly minimized the chance of an accident that could have public impact, as well as reducing the risk to our workforce and the environment. These include:
* Elimination of chlorine use at our cooling water towers and one processing unit. Chlorine was replaced with much less hazardous chemicals in those processes.
* Elimination of a process which used
pure sulfur dioxide. This process was shut down which significantly reduced risk by both eliminating the processing facility as well as storage facilities required for the process.
* Anhydrous Ammonia use has been minimized by the inherently safer use of Aqueous Ammonia in several processes. Aqueous Ammonia represents much less chemical risk than the purer Anhydrous Ammonia.
2. Release Detection - chemical detectors with alarms.
3. Release Mitigation:
* Fire suppression and extinguishing systems
* Deluge system for specific equipment
* Trained emergency response personnel
* Personal protective clothing and equipment
* Blast-resistant buildings to help protect control systems and personnel
* Locating new process units away from residential areas
The accident prevention program summarized below is applied to all process units at MRC. Collectively, these prevention program activities minimize the likelihood and/or severity of an accidental release.
PREVENTION PROGRAM ELEME
Below is an overview of those accident prevention programs at MRC that are required by both the Risk Management Program and Process Safety Management program regulations.
1. Process Safety Information - MRC maintains a variety of technical documents that guide employees and help ensure safe operation of the processes. These documents address chemical properties and associated hazards, limits for operating parameters, specific chemical inventories, and equipment design information.
2. Process Hazard Analysis - MRC conducts a process hazard analyses (PHA) on qualifying units every five years to ensure that hazards associated with process units are identified and controlled. Under this program, each process is systematically examined by a multi-disciplinary team to identify hazards that could result in an accidental release of a regulated substance and ensure that adequate control is in place to manage those hazards.
Seismic Review - The location of MRC is approximately two m
iles southwest of the Concord fault and about 12.5 miles northeast of the Hayward fault. These two faults, particularly the Concord fault, create most of the earthquake concern at the refinery site. As part of technical studies, MRC conducted a seismic review for each RMP process unit that handles regulated substances above specified quantities. The objective of seismic assessments was to provide reasonable assurance that a release of regulated substance having off-site consequence would not occur as a result of a major earthquake.
3. Operating Procedures - MRC has developed and implemented written procedures that provide clear instructions for safely operating each process unit. Written operating procedures address the various modes of process operations, such as unit startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and initial startup of a new process.
4. Training - The careful selection and training of qualified and safety oriented employ
significantly reduces the number and severity of accidents at MRC. MRC is fortunate to attract large numbers of high quality prospective employees to select from when hiring. Both formal class room and on-the-job mentored training is provided at MRC.
5. Management of Change - Because of the inherent complexity of refinery process units and their interconnections, special care must be taken to understand the full implications of revisions made to the facilities. The Management of Change (MOC) process is intended to assess the impact of proposed changes on process safety, the environment, operability, reliability, and product quality in process units. A Management of Change review is required for modifications to facilities or changes to process unit operating conditions.
6. Pre-Startup Safety Reviews - MRC conducts a Pre-Startup Safety Review for any new facility or facility modification that requires a change in the process safety information. The purpose of the Pre-Start
up Safety Review is to ensure safety features, procedures, personnel, and the equipment are appropriately 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 all systems are operationally ready. The Pre-Startup Safety Review team uses checklists to verify all aspects of readiness. A Pre-Startup Safety Review involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
7. Mechanical Integrity - MRC has a well established Preventative Maintenance program. The objective of the program is to identify and mitigate potential equipment problems through daily monitoring by operators and condition-based testing programs by equipment inspectors. The Preventative Maintenance program includes procedures for handling of needed ident
ified repairs in a timely fashion by the maintenance department. Inspection documentation is kept for the life of the equipment. Mechanical integrity includes:
* A Pressure Equipment Preventative Maintenance Program
* A Corrosion Control Program
* An External Steel Support Inspections Program
* A Relief Valve Inspection & Maintenance Program
* A Rotating Equipment Preventive/Predictive Maintenance Program
* A Preventive Maintenance on Control Systems and Alarms Program
8. Internal Compliance Audits - Compliance is audited periodically by MRC hourly and management personnel knowledgeable in the various aspects of the prevention program elements. These are in addition to agency inspections/audits which also occur.
9. Incident Investigation - Incident investigation is important to the overall prevention program effort. The goal of an investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident.
ployee Participation - It is the policy and practice of MRC to actively encourage employee participation in all aspects of the Process Safety Management and Risk Management Plan accident prevention elements. Employee involvement ensures that all relevant perspectives are considered, and that the best ideas are implemented. In addition, all employees have the right to participate in the development and conduct of process safety management activities as stated in the Risk Management and Process Safety Management rules.
11. Hot Work Procedure - An internally approved hot work permit is required before a source of ignition may be created on refinery property. Sources of ignition include welding, burning, portable internal combustion engines, electrical power tools, chipping or breaking concrete, sandblasting, grinding, drilling, soldering, lead burning and any other work or operation which by its nature may produce flame, sparks or sufficient heat to ignite flammable vapors.
tractor Safety - Contractors at MRC are selected based on their past safety performance and their current safety programs. MRC maintains contractor injury/illness records for all contractors on a monthly basis. Copies of separate contractor injury logs are maintained by the Health and Safety Supervisor. Weekly and monthly reports of contractor performance are issued by the Health and Safety Department. Contractors are evaluated on these performance reports. MRC maintains a leadership position in the Bay Area Training Corporation (BATC) where applicable contractor employees are trained. Bay Area Training Corporation training is audited by periodically inspecting individual contractor certification cards.
MRC has established a comprehensive Emergency Response Program. The purpose of the program is to protect workers, the public, and the environment from harm due to MRC emergencies. The program includes procedures for responding to accidental releases, fires,
and explosions and reporting those events to agencies.
A private, direct-line communication system has been installed that permits MRC to make immediate contact at any time with the communications centers of the Consolidated Fire District, County Sheriffs Department, the Martinez Police Department, and the County Health Services Department. The system is closed and unlisted, with no other access to it at either end.
MRC uses the Incident Command System to work with local agencies to manage emergencies. MRC is a member of the Petrochemical Mutual Aid which is comprised of Bay Area petroleum refineries, chemical plants, and related industries who provide assistance to one another in the form of fire-fighting equipment, materials and manpower in the event of a major fire or similar emergency at one of their locations.
COMMUNITY WARNING SYSTEM
If there is an accident with the potential to affect the public the Community Warning System (CWS) will be activated. CWS activation includ
es: safety sirens sounding in the immediate vicinity of the accident; radio and TV announcements sent to the media for broadcast to the public; telephone calls to homes and businesses in the path of the accident; and alert receivers to individually notify schools, day care centers, hospitals, nursing homes, senior centers and other sensitive populations.