BP Amoco Whiting Refinery - Executive Summary |
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BP Amoco Whiting Refinery (Whiting, Indiana) EPA Risk Management Plan - Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The BP Amoco Whiting Refinery, located in Whiting, Indiana, has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as considering safety in the design, installation, operation, and maintenance of our processes. Our refinery adheres to federal and state regulations, industry standards and practices, internal process safety policies and guidelines, and best practices that have been developed based on years of company and industry experience. Examples of specific resource material are: the Amoco Process Safety Booklets, the Amoco Refining Business Group Process Safety Standards and Guideline Manual, the Amoco Refining Business Group Implementation Guidelines for OSHA 1910.119, the Amoco Recommended Good Practices Manuals, and the Amoco Corporate Engine ering Specifications. Our policy is to implement controls to prevent foreseeable releases of regulated substances. If an accidental release does occur, our trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The BP Amoco Whiting Refinery processes 410,000 barrels of crude oil per day to produce petroleum products such as gasoline, diesel fuel, jet fuel, home heating oil, liquefied petroleum gas (LPG), chemical feedstocks, etc. The refinery has eighteen processes that contain materials above the Risk Management Program (RMP) threshold quantity and are, therefore, covered by the regulation. Of these processes, six qualify for Program 1 coverage and twelve qualify for Program 3 coverage. Each covered process contains regulated flammable mixtures above the threshold quantity of 10,000 pounds. The flammable mixtures typically contain various regulated substances such as hydrogen, methane, ethane, propane, butane, and pentane. There are no regulated toxic substances present above a threshold quantity in any process at the BP Amoco Whiting refinery. HAZARD ASSESSMENT RESULTS The RMP rule requires facilities to calculate worst case and alternative release scenarios for each regulated substance on-site. The purpose in calculating these types of scenarios is to encourage dialogue between industry and the surrounding community on chemical accident prevention and risk reduction. The BP Amoco Whiting Refinery has performed these calculations using the methodology given in the EPAs RMP Offsite Consequence Analysis Guidance document. The results have been provided to the EPA and the Lake County Local Emergency Planning Committee (LEPC), and shared with members of the local community and our employees. The BP Amoco Whiting Refinery employs many layers of safety to reduce risk and to prevent chemical accidents. Flammable Worst Case Scenarios The worst case scenario for flammable substa nces, as required by the RMP regulation, is a vapor cloud explosion with an overpressure endpoint of one pound per square inch. The worst case scenario endpoint is based on the instantaneous release, vaporization, and vapor cloud explosion of the entire contents of the largest vessel in a process filled to capacity. This event is highly unlikely to occur. Although numerous controls to prevent such releases are in place, no credit for administrative controls, passive mitigation systems, safety systems, or personnel intervention can be taken into account in developing the worst case scenarios. The EPAs RMP regulation requires that each facility develop and submit at least one worst case scenario for flammable chemicals on site, to represent all Program Level 3 processes. Additional scenarios must be reported if they can potentially impact a part of the community not impacted by other worst case scenarios. Due to the large geographic area covered by the BP Amoco Whiting Refinery, there are a total of five worst case scenarios to represent all Program Level 3 processes. Flammable Alternative Release Scenario The alternative release scenario for flammable substances at the refinery is a vapor cloud explosion resulting from a release of liquid propane from a two inch piping leak. Under this scenario, the release is isolated by operators within ten minutes. In evaluating the alternative release scenario, no credit was taken for administrative controls or mitigation systems. The maximum distance to the one psi endpoint would reach off-site, just beyond the refinery fenceline and extend into an industrial site. This release scenario was selected based on refinery history, and is therefore a practical scenario for use in emergency planning and response. ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS Following is a summary of the general accident prevention program in place at the BP Amoco Whiting Refinery. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject to the OSHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to carry out the accident prevention program. Employee Participation The BP Amoco Whiting 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 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 o ther operators, and in the work permitting process. In addition, the BP Amoco Whiting Refinery has a number of initiatives that address process safety and employee safety issues. These initiatives include standing teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. Process Safety Information The BP Amoco Whiting 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. Asset division personnel within the refinery are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the process safet y overview information for each process to help employees and visitors quickly locate any necessary process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). 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 operating limits for specific process parameters (e.g., temperature, level, composition) in a Safe Operating Limits Table. Process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems) help ensure the processes are maintained within these limits. In addition, tables summarizing the consequences of deviation from these limits and the corrective actions to take are readily avai lable. The BP Amoco Whiting Refinery also maintains technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, piping and instrument drawings, 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. Process Hazard Analysis (PHA) The BP Amoco Whiting 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 Whiting Refinery primarily uses the hazard and operability (HAZOP) analysis technique as the basis for these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The PHA 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 PHA team believes such measures are necessary. The PHA team recommendations are forwarded to management for resolution. Implementation of mitigation options in response to PHA recommendations 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 immediate attention. All approved mitigation options being implemented in response to PHA team recommendations are tracked until th ey are complete. The final resolution of each recommendation 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 Whiting Refinery periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency for the life of the process. The results and recommendations from these updates are documented and tracked. Once again, the team recommendations are forwarded to management for consideration and their final resolution is documented and retained. Operating Procedures The BP Amoco Whiting Refinery maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures are developed by experienced operators as needed and provide a basis for consistent training of new operators. These procedures are periodically reviewed and revised as necessary to reflect changes made through the Management of Change process. These procedures are certified annually as current and accurate. In addition, the BP Amoco Whiting Refinery maintains a Safe Operating Limit Document that provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, the BP Amoco Whiting Refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery operations. After successfully compl eting this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through written and/or oral tests and skills demonstration) adequate knowledge to perform the duties and tasks in a safe manner, they can work independently. In addition, all operators periodically 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 three years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The BP Amoco Whiting Refinery uses contractors to supplement its workforce generally during periods of increased maintenance or construction activities and to perform unique tasks. Because some contractors work on or near process equipment, the refinery has procedures in place to ensure that contracto rs: (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, the BP Amoco Whiting Refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Review (PSSR) The BP Amoco Whiting Refinery conducts a PSSR for any new facility or facility modification that requires a change in the process safet y 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 provides the quality assurance that accident prevention program requirements are properly implemented. Mechanical Integrity The BP Amoco Whiting 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 and plans, (3) perfor ming inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. 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 is performed in a consistent manner and provide a basis for training. 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 team will review th e 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 Whiting 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 Whiting Refinery has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) control of the entry/presence/exit of support personnel, (2) a lockout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process 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 ens ure that adequate precautions are in place before entering a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The BP Amoco Whiting refinery has a comprehensive system to manage changes to 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 being 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 an d maintenance personnel are provided any necessary training on the change. The Management of Change system requires that all documentation is updated and training completed prior to the commissioning of the change. Incident Investigation The BP Amoco Whiting Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire or explosion, toxic gas release, 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. Major incidents are investigated by a cross-functional team lead by an independent leader, while less serious incidents are investigated by the appropriate supervisor and employees involved. The investigation team documents its findings, develops recommendations to prevent recurrence, and forwards these results to refinery management for resolution. Correctiv e actions taken in response to the investigation team's findings and recommendations are tracked in a database 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 PHAs and PHA revalidations. The incident investigation data elements for BP Amoco Whiting Refinerys processes contain dates for incidents which were designated major incidents. Major incidents include, but are not limited to, those that resulted in, or could reasonably have resulted in, a catastrophic release of a regulated substance, a fatality, a lost work day or serious bodily injury, a fire/explosion or other event resulting in damage/loss in excess of $500,000, or a significant negative impact on the community. Compliance Audits To hel p ensure that the accident prevention program is functioning properly, the BP Amoco Whiting Refinery periodically conducts a process safety self-audit to determine whether the procedures and practices required by the accident prevention program are being properly implemented. Compliance audits are conducted at least every three 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 until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the BP Amoco Whiting Refinery have potential hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously, while written for Program Level 3 EPA RMP-covered pr ocesses, is generally applied to all processes. 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 Whiting Refinery has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release Detection 1. Hydrocarbon detectors with alarms 2. Remotely monitored surveillance cameras 3. Established operating personnel field visits Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases 2. Valves to isolate the process (manual or automated) 3. Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 4. Offsite vessels to permit partial remov al of the process inventory in the event of a release 5. Curbing or diking to contain liquid releases 6. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 7. Atmospheric relief devices Release Mitigation 1. Fire suppression and extinguishing systems 2. Deluge systems for specific equipment 3. Remote monitoring equipment 4. Trained emergency response personnel 5. Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 6. State-of-the-art mobile fire fighting equipment 7. Properly designed buildings to help protect control systems and personnel FIVE YEAR ACCIDENT HISTORY The BP Amoco Whiting Refinery has an excellent record of accident prevention over the past 5 years. The two RMP-covered incidents that have occurred did not result in offsite effects and on-site impact was confined to property damage. Every incident is investigated very carefully to determine ways to prevent similar incidents from occurring, and these findings are implemented and shared with all employees. The following table is a summary of the number of incidents covered by the RMP rule that have occurred during the past 5 years. Number of RMP Events Number of RMP Events Year with On-site Impacts with Offsite Impacts 1994 0 0 1995 0 0 1996 0 0 1997 0 0 1998 1 0 1999 1 0 EMERGENCY RESPONSE PROGRAM INFORMATION The BP Amoco Whiting 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 Whiting Refinery maintains a written emergency response program, which is in place to protect wo rker 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 exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the BP Amoco Whiting Refinery has procedures that address the ongoing maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency 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 modifi cations made to refinery processes or other refinery facilities. The emergency response program changes are administered through the Management of Change process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the BP Amoco Whiting Refinery is coordinated with the Lake County Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The BP Amoco Whiting Refinery has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire departments). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the BP Amoco Whiting Refinery conducts periodic emergency drills that involve the LEPC an d emergency response organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery. CHANGES TO IMPROVE SAFETY The BP Amoco Whiting 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 environmental improvements, which, in many instances, go beyond compliance and are entirely voluntary. At the time of submitting this Risk Management Plan, the following activities have been or will be implemented, or are under active consideration: 7 Relief valve containment system for the Coker to eliminate off-site releases 7 Interlocking control system on the Coker to insure correct sequencing of valve movements 7 Underground line raising projects to enhance integrity of piping 7 Installation of geodesic domes on tanks to reduce em issions 7 Implementation of distributed control systems to enhance monitoring of operating parameters 7 Addition of a process safety standard for the safe start-up of process furnaces 7 Addition of a process safety procedure for a refinery-wide consistent policy regarding entering operating units 7 Enhancement of refinery equipment inspection plans 7 Installation of additional fire water hydrants 7 Reliability analysis of the refinery instrument air systems 7 Evaluation of new and safer carbon canister technology |