BP Amoco Toledo Refinery - Executive Summary

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BP Amoco Toledo Refinery 
Risk Management Plan: Executive Summary 
Description of the Stationary Source and Regulated Substances 
The BP Amoco Toledo Refinery, located in Oregon, Ohio operates a variety of processes to produce petroleum products (e.g. propane, butane, gasoline, diesel, jet fuel, asphalt, etc.) from raw crude oil.  The refinery has several regulated flammables, such as hydrogen, methane, propane, and butane.  In addition, the refinery uses and/or processes ammonia and hydrogen sulfide (H2S), which are also regulated substances, although the quantity of H2S in each RMP-covered process is less than the threshold quantity required by the rule. 
Accidental Release Prevention and Response Policies 
The BP Amoco Toledo Refinery has a long-standing commitment to worker and public safety, and to the environment.  This commitment is demonstrated by the resources invested in accident prevention, such as employee training and considering safety in the design, installation, operat 
ion, and maintenance of our processes.  Our goal is to implement reasonable controls to prevent foreseeable releases of regulated substances.  However, if a release does occur, our trained employees will immediately respond to control and contain the release. 
Safety Performance 
The BP Amoco Toledo Refinery has proven the dedication to "Safety First" in many ways recently.  The last lost time injury to a BP Amoco employee at Toledo occurred in 1995 and since then, Toledo employees have worked 4.5 million safe work hours without a lost time accident.   Injury frequency rates for employees have been reduced by 82% over the last ten years to the point where Toledo is now in the top quartile of the US refining industry for safety performance.   Industry recognition of this performance has resulted in Toledo receiving National Petroleum Refiners Association  (NPRA) Safety Awards every year for the last three years. 
BP Amoco Toledo Refinery contractors are also committed to "Safety First" 
in their work at the refinery and have experienced similar performance improvement over time.   A major construction project and a major maintenance overhaul project at the refinery have recently been completed with exemplary safety performance by the contractors.   There was only one lost time injury during the period of both projects, which started in September 1997 and ran through April 1999, and the injury frequency rate was significantly below the construction industry average.   Contractors at Toledo have now worked 2.1 million safe work hours since the last lost time accident. 
Environmental Performance 
BP Amoco Toledo Refinery is committed to the protection and respect of the environment within which the refinery operates.  We operate in such a manner as to minimize the refinery's impact on the environment while competitively producing quality petroleum products.  We strive to continually drive down our environmental impact by reducing waste, emissions and discharges, and us 
ing energy efficiently.  
Pollution Prevention 
BP Amoco Toledo Refinery is involved in a number of pollution prevention and waste minimization programs.  The company is proud to have volunteered to participate in the "Ohio Prevention First" pollution prevention initiative to reduce statewide emissions.  BP Amoco Toledo Refinery committed, by the year 2000, to reduce reported Toxic Release Inventory (TRI) emissions by 50%, compared with 1988.  The refinery exceeded that goal and has now reported a TRI emissions reduction of 68% in 1998. 
BP Amoco Toledo Refinery was also proud to have received the 1998 Ohio Governor's Award for Outstanding Achievement in Pollution Prevention for our "Flare Flowmeter Project".  This project is a state-of-the-art gas flow monitoring system that is uniquely applied to our flares and 16 flare feed lines.  The project has reduced emissions of carbon dioxide (CO2) and criteria air pollutants by approximately 5,000 tons per year.  BP Amoco Toledo Refinery al 
so received special recognition proclamations from the members of the Ohio Senate and House of Representatives of the 122nd General Assembly honoring the refinery for the Flare Flow Meter Project and outstanding achievement in Pollution Prevention. 
Environmental Improvements 
BP Amoco has invested $226 million since 1988 on environmental expenditures at its Toledo Refinery.  The refinery most recently invested another $75 million on specific environmental controls as part of the Toledo Repositioning Project.  Past investments have dramatically reduced emissions in many categories.  Volatile Organic Compound (VOC) emissions (i.e. benzene, xylene, and toluene) have been reduced 90% since 1990.  This VOC reduction was instrumental in allowing Lucas and Wood Counties in Ohio to be reclassified by the U.S. EPA as achieving attainment levels for ozone.  
ISO 14001 Certification 
In 1998, BP Amoco Toledo Refinery became one of only two petroleum refineries in the United States to have it's 
Environmental Management System (EMS) achieve ISO 14001 certification.  The Environmental Policy is the main ISO 14001 EMS element which describes the framework for a facility's overall commitment to the protection and respect of the environment.  Each Toledo Refinery employee must know and strive to achieve the refinery's environmental policy of: No Damage to the Environment, Comply with Regulations and Continual Improvement. 
With consideration for the above achievements, the employees of Toledo Refinery have demonstrated a true commitment to the protection of the environment.  Their efforts have allowed the refinery to go beyond compliance and to achieve continual improvement of  our environmental performance.  
Community Liaison 
BP Amoco Toledo Refinery places high priority on effective communication with its neighbors.  The Refinery has a philosophy of being open and honest and nurtures a proactive community outreach program. 
BP Amoco Toledo Refinery maintains two groups which 
help facilitate this two-way communication.  Since 1990, the Refinery has maintained the Community Advisory Board.  This group's members include officials from the City of Oregon such as the mayor, city councilmen, finance director, fire and police chiefs and school superintendent.  Representatives from the Lucas County Health Office, Toledo Division of Environmental Services, the Ohio EPA, and the Village of Harbor View also attend its quarterly meetings. 
Recognizing the need for dialogue with everyday citizens, the Refinery established the Citizens Advisory Panel in 1997.  This group is comprised of private citizens and small business owners and meets monthly.  Its meetings have been used not only to discuss issues peculiar to BP Amoco, but have served as a forum for broader community topics. 
Both groups have provided an excellent vehicle to address issues concerning the refinery as well as providing a conduit for questions, concerns, and comments from the community.  A great part 
of being a good neighbor is maintaining good communications.  To this end, the Community Advisory Board and Citizens Advisory Panel serve well. 
Public Risk Communication 
In line with the refinery's proactive community outreach policy, BP Amoco Toledo Refinery participated in a public roll-out of information concerning Risk Management Planning during May 1999.  The refinery was part of a nine member coalition of industrial and municipal facilities which operated under the aegis of the Lucas County Local Emergency Planning Committee (LEPC).  This coalition was supported by representatives of Ohio EPA, emergency response agencies, local government, and a public interest group (Ohio Citizen Action), and had been meeting since February 1998 with the aim of determining compliance with the RMP rule and communication to the public.   
The LEPC established two groups:  
* a Technical Work Group (led by BP Amoco) which addressed the compliance issues, risk assessments, and impact zones 
* a C 
ommunications Work Group which addressed the means and scope of the public communication 
Once the Technical Work Group had confirmed their data, the Communications Work Group was given the task to decide what, how much, and when to communicate this information to the public.  This process was challenged in that part way through the process, three key players left their positions with their companies and BP Amoco stepped in to direct and manage the project. 
The Communications Work Group decided to go beyond the RMP regulatory requirements of only filing Risk Management Plans with the US EPA and Ohio EPA.  A public survey was conducted by a professional pollster to determine the scope and format of the public communications plan.  It was decided that the LEPC coalition would be proactive in communicating accidental chemical release "risks" with the public prior to the June 21, 1999 RMP compliance deadline.  Among several key findings, the survey identified that Lucas County residents h 
ad a poor understanding of the local emergency responders' preferred concept of "shelter-in-place".  In line with the survey findings, the communication plan included: 
* Printing a LEPC general brochure and pocketed folder 
* Printing facility specific brochures 
* Producing refrigerator magnets with shelter-in-place information 
* Each facility mailing their brochures, magnet and a cover letter to their neighboring community 
* Briefing the editorial boards of the local media, local elected officials and safety and emergency response personnel 
* Each facility briefing their employees  
* Having informational booths at a local mall and community festival 
* Establishing an LEPC community telephone hot-line and internet website for more information 
Key messages were: 
* The facilities represented nine out of nearly 50 facilities in Lucas County which come under the rule 
* The "Worst Case Scenarios" were extreme situations, highly unlikely to occur 
* The "Alternate Release Scenarios" though  
more realistic, were, also unlikely to occur  
* All of this information, while new to the public, has been known to the County's emergency response personnel for years. 
* The facilities build their equipment to strict design criteria,  practice preventative maintenance, operate with highly trained personnel, have sophisticated control and alarm equipment, and have well trained emergency response teams to deal with incidents. 
At the public events, the facilities were joined by representatives of the American Red Cross, Ohio EPA, the Lucas County LEPC, and the Toledo and Oregon Fire Departments.  The approach adopted in the LEPC communication plan was successful in reaching the communities at potential risk close to the BP Amoco Toledo Refinery, and there was some genuine interest in, and appreciation of, the information provided.   
The LEPC, with the help of BP Amoco and the other eight facilities, has also begun a public education program aimed at raising understanding within the com 
munity about what to do in the unlikely event of an accidental chemical release incident.  Local emergency response agencies have undertaken to continue this "shelter-in-place" awareness program, as it also has application in the event of transportation incidents within the County. 
Risk Management Program 
The following is a summary of the Risk Management Program in place at the BP Amoco Toledo Refinery.   This Risk Management Program comprises : 
(i)  Hazard Assessment 
(ii)  Accidental Release Prevention Program 
(iii)  Five Year Accident History 
(iv)  Emergency Response Program 
Hazard Assessment 
The RMP rule requires facilities to calculate worst case and alternative release scenarios for each regulated substance on-site.  BP Amoco Toledo Refinery has performed these calculations using the methodology given in EPA's Risk Management Program Guidance for Offsite Consequence Analysis document. 
The worst-case scenario (WCS) associated with toxic substances in a Program Level 3 pro 
cess at the refinery involves a liquid ammonia release from a small storage tank.  This event is extremely unlikely and has never happened at BP Amoco Toledo Refinery.  Ammonia delivery truck drivers are trained in a written procedure whereby this storage tank is never filled greater than 85% full, and credit has been taken for this administrative control.  No credit has been taken for any mitigation systems in determining this worst case scenario, despite the refinery's numerous controls to prevent and mitigate such releases.  Under worst case meteorological conditions, the resulting vapor could just reach nearby public receptors if the wind were in that direction. 
The alternative release scenario (ARS) for ammonia involves a pipework leak,  resulting in a release of liquid ammonia over a 15-minute period.  This event is also very unlikely and has never occurred at BP Amoco Toledo Refinery.  The BP Amoco Toledo Refinery has a comprehensive mechanical integrity program to prevent pipe 
work failures resulting from corrosion and other means.  No mitigation measures were taken into account in evaluating this scenario, whereas the Refinery's operators and Hazmat team are trained to respond quickly to isolate leaks and mitigate their effects.  Under typical meteorological conditions, the resulting vapor could just reach the refinery fenceline if the wind were in that direction. 
No Program Level 1 or 2 processes containing regulated toxic substances were identified at the refinery. 
The WCS associated with a release of flammable substances in Program Level 3 processes at the refinery is a vapor cloud explosion (VCE) resulting from a release from a butane storage tank.  This event is extremely unlikely to occur and has never happened at BP Amoco Toledo Refinery.  Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating this WCS.  E 
PA's methodology assumes that the total tank contents vaporize within 10 minutes, whereas in reality, using a sound science approach, even if the tank could completely fail, then only a small fraction of the liquid butane contained within the diked area would vaporize, as the remaining liquid butane would auto refrigerate thereby significantly slowing the rate of vaporization.  Nevertheless, using EPA's methodology, the resulting VCE from 100% of the tank contents could effect nearby public receptors.  The sound science approach would have a much more limited range of effect from a VCE. 
The ARS for flammable substances at the refinery is a flash fire resulting from the release of propane from a flexible hose while loading a road tanker.  The release is expected to be isolated by the operator or truck driver activating the emergency shutdown system within 1 minute. This event has never happened at the BP Amoco Toledo Refinery, but was selected on the basis of a history of hose failures 
within the industry.  The BP Amoco Toledo Refinery has a comprehensive mechanical integrity program to prevent loading hose failures.  However, this event is considered as being a more credible occurrence than the WCS, and a practical scenario for use in emergency planning and response.  The resulting flash fire is determined from the dispersion distance to the 2% volume lower flammability limit (LFL) for propane and could just reach the refinery fenceline if the wind were in that direction. 
No Program Level 1 or 2 processes containing regulated flammable substances were identified at the refinery. 
Accidental Release Prevention Program 
The following is a summary of the general accident prevention program in place at the BP Amoco Toledo Refinery.  Because processes at the refinery that are regulated by the EPA RMP regulations are also subject to the OSHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management syste 
m in place to implement the accident prevention program. 
Management System 
The following list indicates the management system within BP Amoco Toledo Refinery for ensuring RMP compliance, and the roles and responsibilities of the key personnel. 
* RMP Program Certification:   Business Unit Leader 
To the best of the signer's knowledge, information, and belief formed after reasonable inquiry, certifies that the information submitted is true, accurate, and complete. 
* RMP Program Facilitation:  Regulatory Affairs Manager 
Assigns a qualified person that has overall responsibility of the development, implementation and integration of the RMP elements. 
* RMP Program Coordination:   Risk Management Consultant 
Develops and implements a management system to oversee the implementation and on-going maintenance of the risk management program elements.  Coordinates the development of each of these elements.  Submits state and federal registrations, RMPlan, and plan updates. Promotes and communi 
cates the regulation to the employees and contractors.  Networks with local industry and other BP Amoco sites. 
* Off-site Consequence Analysis:  Risk Management Consultant 
Defines off-site public and environmental receptors.  Performs modeling of worse case and alternative release scenarios for each toxic and flammables as a class. 
* Five Year Accident History:  Safety Specialist Team Leader 
Prepares a five-year accident history of all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. 
* Prevention Program:  PSM Coordinator 
Prepares and keeps updated the prevention plan for preventing accidental releases of highly hazardous chemicals.  Assures the inclusion of RMP off-site consequences in the process hazards analysis (PHA) for each covered process. 
* Emergency Planning: Safety Specialist Team Leader / Emerg 
ency Response Specialist 
Develops and implements an ER Program for the purpose of protecting public health and the environment.  Coordinates with the LEPC and other community and state responders and provide information upon request for inclusion in other community emergency response plans. 
* Risk Communications:  PR Specialist 
Makes the RMPlan available to the public. Coordinates efforts to educate/communicate the release scenarios and prevention measures to the public. 
* Risk Management Plan:  Risk Management Consultant 
Develops and submits a RMPlan that contains all requested information such as source registration, off-site consequences analyses, the five-year accident history, prevention program, emergency response program, and RMP program certification.  Updates plan as required. 
Employee Participation 
The BP Amoco Toledo Refinery encourages employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation range  
from updating and compiling technical documents and chemical information to participating as a member of a process hazard 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 and addresses each accident prevention program element.  In particular, employees are involved in accident investigations, writing procedures, training other operators, and in the work permitting process. 
In addition, the refinery has a number of initiatives under way that address process safety and employee safety issues.  These initiatives include the refinery Health & Safety Committee to promote both process and personal safety.  The H & S Committee typically has members from various areas of the plant, including operations, maintenance, engineering, and refinery management.  
Process Safety Information 
The BP Amoco Toledo Refinery keeps a variety of technical documents that are used to help maintain safe operation of the processes.  These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.  Specific departments within the refinery are assigned responsibility for maintaining up-to-date process safety information (PSI). 
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS's).  This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals.  For specific process areas, the refinery has documented safety-related limits for specific process parameters (e.g., temperature, level, composition).  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 refinery also maintains numerous technical documents that provide information about the design and construction of process equipment.  This information also includes materials of construction, design pressure and temperature ratings, and the electrical rating of equipment, etc.  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 safety features in the process are not compromised.  
In the case of Coker No.3 Unit, which was commissioned in May 1999, the process safety information is currently being reviewed and brought up to "as-built" status.  Once this as-built work is complete, the Coker PSI will be maint 
ained up-to-date by the management of change procedure used for other BP Amoco Toledo Refinery process plant. 
Process Hazard Analysis (PHA) 
The BP Amoco Toledo 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 BP Amoco Toledo 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.  This technique is variously supplemented by the use of What If, Checklist and Quantified Risk Assessment (QRA) methodologies. The analyses are conducted using a team of people who have maintenance and operating experience as well as engineering expertise.  This team identifies and evaluates hazards of the process a 
s 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 local management for resolution.  Implementation of prevention and 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 prompt attention.  All approved options being implemented in response to PHA team findings are tracked 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 BP Amoco Toledo 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, and the final resolution of the findings is documented and retained.  The Reformer No.2 Unit PHA revalidation is currently in progress at the time of filing this Risk Management Plan, and the previous PHA dated June 1994 has been recorded in the attached Data Elements. 
Operating Procedures 
The BP Amoco Toledo Refinery maintains written procedures that address various modes of process operations, such as (1) unit start-up, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process.  These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators.  These procedures are periodically reviewed and annually certified as current  
and accurate by revising them as necessary to reflect changes made through the management of change process.  In addition, training manuals are available that describe how the process units operate.   This information is readily available to operators in the process units and for other personnel to use as necessary to safely perform their jobs. 
BP Amoco Toledo Refinery has developed  Preventative Maintenance and Malfunction Abatement Plans for key areas of the refinery.  The purpose of these plans is to prevent, detect, and correct malfunctions or equipment failures which could result in excess emissions.  To supplement these plans, the refinery has developed procedures which identify how to keep certain process unit streams within design tolerances to avoid adversely impacting the Sulfur Recovery Units.  Personnel involved in the operation or supervision of these units receive training on these procedures. 
To complement the written procedures for process operations, the B 
P Amoco Toledo Refinery maintains a comprehensive training program for all employees involved in operating a process.  New employees receive basic training in refinery operations if they are not already familiar with such operations.  After successfully completing this training, a new operator is paired with an experienced operator to learn process-specific duties and tasks.  After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently.  In addition, all operators specifically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level.  This refresher training is conducted at least every 3 years.  All of this training is documented for each operator, including the means used to verify that the operator understood the training. 
The BP Amoco Toledo Refinery uses contractor 
s to supplement its work force during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the refinery has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their 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 prior to their beginning work.  In addition, BP Amoco Toledo Refinery evaluates contractor safety programs and performance during the selection of a contractor.  Refinery personnel regularly monitor and periodically audit contractor performance to ens 
ure that contractors are fulfilling their safety obligations. 
Pre-startup Safety Reviews (PSSRs) 
The BP Amoco Toledo Refinery conducts a PSSR for any new facility or facility modification that requires a change in the process safety information.  The purpose of the PSSR is to ensure that 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 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.  
The BP Amoco Toledo Refinery also has a well established BP corporate Project Safety Review (PSR) procedure, which is appl 
ied to major projects, such as the recent Toledo Repositioning Project (TRP).  This comprehensive six-stage PSR procedure is carried out at discrete periods during the development of the project to ensure that potential hazards have been identified and assessed, and that appropriate measures have been taken to prevent their occurrence, and minimize and mitigate their consequences.  The newly commissioned Coker No.3 Unit was an integral part of the TRP and has been audited using this PSR procedure. 
Mechanical Integrity 
The BP Amoco Toledo Refinery has well established practices and procedures to maintain 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) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures.  In c 
ombination, these activities form a system that maintains the mechanical integrity of the process equipment.  The refinery has also developed  Preventative Maintenance and Malfunction Abatement Plans for key processes to prevent, detect, and correct malfunctions or equipment failures which could result in excess emissions.   
Maintenance personnel receive training on (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 to help ensure that they can perform their job in a safe manner.  Written procedures help ensure that work performed is in a consistent manner and provides a basis for training.  Safe work practice procedures, developed by BP Amoco Toledo Refinery, are supplemented by original equipment manufacturers (OEM) manuals, which provide detailed instructions for maintenance, inspection and testing of all refinery plant and equipment.   
Inspections and tests are  
performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels).  If a deficiency is identified, employees will correct the deficiency before placing  the equipment back into service (if possible), or a Management of Change (MoC) team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. 
Another integral part of the mechanical integrity program is quality assurance.  The BP Amoco Toledo Refinery incorporates quality assurance measures into equipment purchases and repairs.  This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. 
Safe Work Practices 
The BP Amoco Toledo Refinery has long-standing safe work practices in place to help ensure worker and process safety.  Examples of these include (1) control of 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 the safe removal of hazardous materials before process or piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e. hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space.  These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance are performed safely. 
Management of Change 
The BP Amoco Toledo Refinery has a comprehensive system to manage changes that will impact the covered processes.  This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions outside the original equipment design range), procedures and other facility changes be properly reviewed and authorized before be 
ing 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 training on the change. 
Incident Investigation 
The BP Amoco Toledo 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, identify root causes and develop corrective actions to prevent a recurrence of the incident or a similar incident.  Serious incidents or "near-misses" are investigated by a team incorporating an independent leader and/or team member(s), while 
less serious incidents are investigated by the appropriate supervisor and employees involved. 
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 in a database (GIRS) 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 PHA's and PHA revalidations. 
Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the BP Amoco Toledo Refinery periodically conducts an audit to determine whether procedures and practices required by the accident prevention program 
are being implemented.  Compliance audits are conducted at least every 3 years.  Both hourly and management personnel participate as audit team members.  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 in a database (CARTS) until they are complete.  The final resolution of each finding is documented, and the two most recent audit reports are retained.  The last audit was conducted during April, 1998. 
The Coker No.3 Unit is a new process plant that was commissioned in May 1999, and therefore has not been subject to the three year compliance audit.  However, the Coker's prevention program was audited by both a pre-startup safety review (PSSR) and by Stage 5 of BP's Project Safety Review (PSR) procedure shortly before commissioning. 
Besides the compliance audits, BP Amoco Toledo Refinery has an ongoing program of "theme" audits to assure that a range of health, safe 
ty and environmental practices are being correctly implemented and to identify opportunities for improvement.  Corrective actions taken in response to the audit team's findings are also tracked in the CARTS database until they are complete. 
Chemical-Specific Prevention Steps 
The crude oil refining processes at the BP Amoco Toledo Refinery have hazards that must be managed to ensure continued safe operation.  The accident prevention program summarized previously is applied to all Program Level 3 RMP-covered processes at the refinery.  Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. 
In addition to the accident prevention program activities, the BP Amoco Toledo Refinery has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences (i.e. mitigate) of a release.  The following types of safety features ar 
e used in various processes: 
Release Detection 
 Hydrocarbon detectors with alarms 
 Toxic gas detectors with alarms 
Release Containment/Control 
 Process relief valves that discharge to a flare system to capture and incinerate episodic releases 
 Scrubbers to neutralize chemical releases 
 Valves to permit isolation of the process (manual or automated) 
 Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 
 Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank) 
 Curbing or diking to contain liquid releases 
 Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 
 Atmospheric relief devices 
Release Mitigation 
 Fire suppression and extinguishing systems 
 Deluge systems for specific equipment 
 Trained emergency response personnel 
 Personal protective equipment (e.g., protective clothing, self-contained breathing appara 
Five-Year Accident History 
The BP Amoco Toledo Refinery has an excellent record of accident prevention over the past five years as borne out by our safety performance mentioned earlier.  With a continually maturing process safety program in place at the refinery to prevent process related incidents, the refinery has significantly improved performance in reducing the frequency of even small accidental releases. 
BP Amoco Toledo Refinery has experienced five RMP reportable incidents over the past five years, but none of these incidents have resulted in any off-site impact to the community surrounding the refinery, including no injuries or property damage to refinery neighbors. 
Except for one of the five incidents, any impacts have been confined to on-site property damage to refinery plant and equipment.  One incident, involving a compressor explosion at the Isocracker 2 plant in May 1995, resulted in two operator injuries.  Every incident is investigated very carefully to determ 
ine ways to prevent similar incidents from occurring, and these findings are implemented and shared with all employees. 
These five incidents involved the release of flammable vapors to the atmosphere for very short periods of time, of the order of less than a minute or two, before the vapors ignited.  The subsequent fires sometimes burned for several hours while refinery operators and emergency responders contained the incidents to prevent escalation and allowed the fuel to burn out safely without impact to local communities.  During these periods, industrial hygienists carefully monitored the air downwind to ensure no harm from the vapors or combustion products to local neighbors.  These combustion products are not RMP regulated substances. 
The following table is a summary of the number of RMP covered incidents that have occurred during the past 5 years:  
                         Number of RMP Events                 Number of RMP Events 
                            with On-site Ef 
fects                         with Off-site Effects 
1994                                0                                                         0 
1995                                2                                                         0 
1996                                2                                                         0 
1997                                1                                                         0 
1998                                0                                                         0 
1999                                0                                                         0 
Emergency Response Program 
The BP Amoco Toledo Refinery has its own emergency response teams that cover Fire Response, Hazmat Response, and First Aid Response on a 24 hour basis.  Each of these emergency response teams train regularly every month to maintain their readiness and preparedness to tackle any incident involving flammable or toxic chemicals handled by the  
refinery, and other occupational incidents.  
The BP Amoco Toledo 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 all aspects of emergency response, including proper first-aid and medical treatment for on-site exposures, evacuation plans and accounting for personnel after an on-site evacuation, notification of local emergency responders (who in turn notify the public, if appropriate) if a release occurs, and post-incident cleanup and decontamination requirements.  
In addition, the BP Amoco Toledo Refinery has original equipment manufacturers (OEM) manuals that address maintenance, inspection and testing of emergency response equipment, as well as instructions that address the use of e 
mergency 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 emergency response program changes are administered through the MoC process, which includes informing and/or training affected personnel in the changes. 
The overall emergency response program for the BP Amoco Toledo Refinery is coordinated with the Oregon Fire Department and Lucas County Local Emergency Planning Committee (LEPC).  This coordination includes close liaison with refinery emergency response teams and periodic meetings between local emergency response officials, local government officials, and industry representatives.  The BP Amoco Toledo Refinery has 24 hour communications capability with appropriate officials and emergency response agencies.  This provides a means, through these agencies 
, of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.  BP Amoco Toledo Refinery conducts periodic emergency drills that involve the LEPC, emergency response agencies, and other mutual aid organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery. 
Future Safety and Environmental Improvements 
As publicly stated in our Health, Safety and Environmental (HSE) Policy, the BP Amoco Toledo Refinery will continue in the future to strive to achieve our HSE policy of:  
* No accidents  
* No harm to people  
* No damage to the environment 
* Comply with Regulations 
* Continual Improvement.   
In this respect, the refinery has an ongoing program which evaluates a range of projects, modifications and work practice improvements aimed at enhancing the efficiency of the refinery operation.  This program includes various health, safety and environ 
mental improvements, which, in many instances, go beyond compliance and are entirely voluntary. 
At the time of submitting this Risk Management Plan, the following activities are currently being implemented or under active consideration: 
* implementation of the Maximo preventative maintenance program to enhance process plant reliability 
* installation of steam purge to inert intermediate storage tanks for reduced emissions 
* work permit system audit to identify work practice improvements 
* feasibility evaluation of central control room for improved control and communication 
* continue to identify and evaluate opportunities to reduce odors generated from the refining process 
* identify and evaluate options to minimize the generation of solid waste. 
* identify and evaluate opportunities to reduce the amount of water used by the refinery 
* oil spill prevention focus program 
BP Amoco has assumed a leadership position among the world petroleum industry in its commitment on Climate Change. 
 BP Amoco has publicly committed to a 10 % reduction of emissions of Greenhouse Gases from among all BP Amoco sites by year 2010.  The base year for the 10% reduction is 1990.  The Toledo Refinery is an active participant in the BP Amoco Pilot Emissions Trading Program for carbon dioxide (CO2) and is projected to achieve its reduction commitments through 2003.  Achieving the CO2 reduction commitment of 10% by 2010 will certainly be a challenge for the Toledo refinery and the rest of the BP Amoco facilities.  New technologies may need to be implemented to meet this commitment but the refinery is confident that it will achieve the target for 10% CO2 reduction.  
As a further indication of BP Amoco's commitment to the environment, BP Amoco Group Chief Executive,  John Browne announced in a speech in Detroit, Michigan, on January 25, 1999 that BP Amoco is committed to providing fuels that contain reduced sulfur levels in more than 40 cities world-wide within 2 years.  Also, on March 30, 1 
999, General Motors and its Allison Transmission division, and BP Amoco, delivered to New York City Transit an advanced, environmentally compatible hybrid electric bus.  BP Amoco formulated the fuel for this bus, a prototype ultra low sulfur city diesel.  The low sulfur fuel, which will be refined at the BP Amoco Toledo Refinery, enables the bus to use state-of-the-art diesel engine technology to augment the electric power unit and achieve a 70% reduction in city bus emissions.
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