Tosco Refining Company - Executive Summary

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Ferndale Refinery RMP: Executive Summary 
The federal Risk Management Program requires Tosco Refining Co.  to submit a Risk Management Plan (RMP) for any processes containing regulated substances above threshold quantity (TQ) at the Ferndale Refinery.  The Ferndale Refinery handles hazardous materials onsite, and recognizes a responsibility to safely operate the facility in order to protect the surrounding community, employees, and the environment.  The facility has taken a proactive stance to promote the overall safe operation of the processes, with programs to prevent accidents from occurring, planning for emergencies, and maintaining the equipment needed if an emergency does occur.  The RMP formalizes existing programs and procedures so that these programs may be reviewed more efficiently. 
The Ferndale Refinery processes oil into gasoline and refining products.  The facility receives oil from many sources via ship or pipeline, stores it in tanks onsite, then processes the oil into  
products to be shipped elsewhere by pipeline, railcar, barge or truck.  The refining process separates the crude oil into five products: gasoline, diesel fuel, liquefied petroleum gas (LPG), heavy fuel oil and sulfur.  The sulfur is generated because oil contains significant quantities of sulfur that must be removed to produce clean burning gasoline and diesel.  The fuel products are also stored in onsite storage prior to shipping, and any non-hydrocarbon products e.g. sulfur are also stored prior to shipping.  The facility also has the utility and support systems required to provide for safe operation of the facility. 
The RMP consists of two parts required for submittal: 
7 RMP executive summary, prevention program summary, and management system 
7 RMP data elements 
The RMP effort at the facility was divided into three phases.  First, the facility determined which processes were covered by the RMP regulation.  The results of this study are published in the report titled "Phase I: Inve 
ntory Determination" which measured the quantities of regulated substances to determine which processes are subject to RMP.  In phase II, the facility conducted the required hazard assessment as defined by the regulation.  The hazard assessment modeled accidental release scenarios that provided insight about the potential for onsite processes to affect the surrounding community and the environment.  A summary of the hazard assessment is provided in Section 2.  Finally, phase III of the RMP effort is provided in this document.  It contains the executive summary of the overall RMP effort at the facility, a synopsis of the prevention program, a five year accident history and an organizational chart of the management systems in place to implement and maintain the facility's risk management measures. 
The executive summary and data elements are submitted to Local Emergency Planning Committee (LEPC) and the federal government as part of its Risk Management Plan. 
Ferndale Refinery Hazard Ass 
essment-   Offsite Consequence Analysis (OCA) Summary 
The objectives of this hazard assessment are twofold: (1) satisfy the requirements of the RMP regulation and (2) provide OCA information that will help local emergency planning officials improve community emergency response in the event of an accidental release at the refinery. 
For all covered process units, the facility is providing a worst case and alternative release scenario for each regulated toxic substance held in the covered process, and the same scenarios for flammable substances in covered process units.  The Fernale Refinery has one regulated toxic compound: hydrofluoric acid (also known as HF acid).  The Refinery has a number of regulated flammable compounds: methane, ethane, propane, propylene, butane, isobutane, butene, isopentane, and pentane. 
RMP has provided the levels of concern (LOC) for certain regulated substances that have the potential to be carried offsite during a release.  For regulated substances where  
emergency response planning guidelines (ERPG) values have been established RMP requires that the ERPG-2 value be used as the toxic endpoint.  RMP also requires an offsite consequence analysis for potential releases of flammable materials.  In modeling flammable materials, the stationary source is required to present distances to endpoints resulting from any of the following: 
7 Explosion: Overpressure of 1 psig. 
7 Radiant Heat/Fire: Radiant heat of 5 kW/m2 for 40 seconds. 
7 Lower Flammability Limit: a lower flammability limit as provided in NFPA documents or other generally recognized sources. 
Worst Case Scenario 
The worst case scenarios were calculated using the most pessimistic weather conditions and the EPA-mandated release rates.   The worst case scenarios are very unlikely to occur.  Besides implementing the RMP and PSM programs, the Ferndale Refinery also uses management programs to reduce the likelihood of catastrophic events from occurring.  The Ferndale Refinery restricts ac 
cess to the facility, and all visitors to the facility must receive the appropriate contractor safety training before access is permitted. The Ferndale Refinery also limits the vehicle traffic on site, and posts safe driving limits to reduce the likelihood of a vehicular impact with process equipment. Tosco operates the process equipment to the codes and standards to which the equipment was built, and routinely inspects and tests all process equipment per the appropriate codes, standards, and best engineering practices. 
The results of the hazard assessment show that for the HF acid WCS, the downwind impact to a level of concern (LOC) of 20 ppm has the potential to have offsite impact. 
The 1 psig overpressure zone of impact, due to the butane WCS vapor cloud explosion will also have offsite impact. 
The worst case scenarios were calculated using the EPA's OCA guidance reference tables and equations.  LandView, environmental mapping software published by the Bureau of the Census, was u 
sed to assist in the determination of the release impacts to the surrounding community and the environment. 
Alternative Release Scenario 
The facility has modeled alternative release scenarios (ARS's), to identify release scenarios that may have a more realistic chance of occurrence.  The alternative release scenarios allow the facility to present scenarios that assume the use of administrative and actual controls in place at the facility.  
The results of the hazard assessment show that for the HF acid ARS, the downwind impact to a level of concern (LOC) of 20 ppm has the potential to have offsite impact 
The 1 psig overpressure zone of impact, due to the butane ARS vapor cloud explosion has no offsite receptors. 
Several scenarios for both toxic and flammable releases were identified for further investigation.  The widely accepted Areal Locations of Hazardous Atmospheres ALOHA(R) model was also chosen to calculate the ARS toxic scenarios.   The flammable ARS scenario was determined  
using the EPA's OCA guidance reference tables and equations.  The scenarios included actual incidents and near misses from this or similar facilities, as well as scenarios identified in the Process Hazard Analysis studies as possible to reach an offsite receptor.   
The alternate release scenarios chosen for submission for the RMP program are possible, but have never happened at the facility.  Additionally, procedures and policies at the refinery are intended to prevent this scenario from resulting in an offsite impact. This includes the firewater monitors and deluge systems, ambient monitors, transportation protocols, emergency response program, equipment and piping inspection and maintenance programs, and operator training programs. 
Five Year Accident History 
The RMP rule requires facilities to compile a 5-Year Accident History for all RMP regulated substances in covered processes at the facility.  As part of the ongoing PSM Program, the facility documents and tracks all incidents  
and near misses that occur within the facility.  This incident database served as the basis for the five-year accident history presented here. 
RMP requires facilities to report any incident from a covered process involving a regulated substance and resulting in any of the following: 
7 Onsite deaths, injuries, or significant property damage 
7 Offsite deaths, injuries, property damage, evacuations, sheltering-in-place, or environmental damage 
The Facility has a single incident that qualifies by the above criteria.  The incident is summarized below. 
Unit: No. 17 HF Alkylation 
date: 9/22/97 
Description: HF acid release from neutralizing pit resulting in minor operator injury. No offsite impacts. 
Root cause(s): HF Acid truck offloading procedures not followed; nitrogen valve left in the wrong position; check-valve failure. 
Action plan to prevent recurrence: Upgraded truck offloading operating practice; improved access to truck unloading piping and control systems. 
Ferndale Refinery Pre 
vention Program 
The following is a summary of the general accident prevention program in place at the refinery.  Because processes at the facility that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.  Each section below contains a brief summary of the prevention program elements.  Each summary also designates the responsible party for each element. 
Employee Participation 
The intent of this element is to involve employees in the development and implementation of the various PSM element compliance activities.  This involvement is intended to be a cooperative, interactive effort that will bring together the best resources at the refinery to achieve a sound loss prevention program.  Employee Participation is the responsibility of the PSM Superintendent. 
Process Safety Information (PSI) 
The refinery provides c 
omplete and accurate information concerning all covered processes.  This information is essential for having an effective PSM program and for conducting thorough process hazards analysis.  This includes information regarding process chemicals, process technology and process equipment.  The Project Engineering Supervisor is responsible for the refinery PSI. 
Process Hazard Analysis (PHA) 
The refinery has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled.  Within this program, each process unit is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.  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 team believes such measures are necessary. 
Operating Procedures 
Written operating procedures provide clear i 
nstructions for safely conducting activities in the refinery.  The tasks and procedures are appropriate, clear, consistent and communicated with the employees.  The program is designed to satisfy the PSM regulation, RMP requirements, and meet all parts of the compliance guidelines CPL 2-2.45A.  Operating procedures are the responsibility of the Production Manager. 
Training ensures that the products processed in this facility are handled in a consistent and safe manner.  This is accomplished by having knowlegable operators.  An effective training program helps operators understand the nature and causes of problems arising from the process operations and will increase the employee's awareness with respect to the hazards of a particular process thereby preventing unplanned catastrophic incidents.  Training is the responsibility of the Training Superintendant. 
It is the refinery philosophy that all injuries are preventable.  This applies to all personnel on the Fer 
ndale site whether they are Refinery employees or contractor employees.  The contractor safety policy is intended to help assure the refinery that its contractors and subcontractors are qualified and have an effective safety process. Contractors are the responsibility of the Safety Superintendent. 
Pre-Startup Safety Reviews (PSSRs) 
The purpose of a PSSR is to ensure that a new plant or a significant modification to an existing plant is ready to operate safely.  This is a final check that all important considerations have been taken into account before a highly hazardous chemical is introduced to the process. 
The Area Superintendent or delegate is responsible for the PSSR. 
Mechanical Integrity 
The objective of this element is to assure that equipment used to process, store or handle hazardous chemicals is designed, constructed, installed and maintained per good engineering practices.  This will minimize the risk of releases of such chemicals.  The facility has programs for: 
7 Fire 
protection equipment 
7 Control and instrumentation systems 
7 Pumps and compressors 
7 Furnaces 
7 Piping systems 
7 Valves 
7 Tanks and storage vessels 
7 Pressure vessels, heat exchangers, and boilers 
Responsibilities for the components of this Program are as follows: 
Inspection/Testing Procedures: Inspection Supervisor 
Repair Procedures: Inspection Supervisor 
Engineering Procedures: Project Engineering Superintendent 
Training Documentation: Training Superintendent 
Repair Execution: Maintenance Supervisors and Contract Coordinators 
Preventive Maintenance: See Mechanical Integrity Programs for PSVs and Controls 
Safe Work Practices 
The refinery is committed to providing a safe and healthful work place for the workers at the facility, contractors, visitors, and the community surrounding the facility.  Safe work practices are in place to ensure that common hazardous activities are conducted safely.  These procedures (and others), along with training of affected personnel and contractors, f 
orm a system to help ensure that operations and maintenance activities are performed safely.  The Safety Superintendent coordinates safe work practices.  
Examples of standard safe work practices at the refinery include:  
7 Tracking and control of the entry/presence/exit of personnel into and out of the facility 
7 A hazardous energy procedure to ensure isolation of energy sources for equipment undergoing maintenance 
7 A procedure for safe removal of hazardous materials before process piping or equipment is opened 
7 A permit and procedure to control spark producing activities (i.e., hot work) 
7 A permit and procedure to ensure that adequate precautions are in place before entry into a confined space 
7 In addition to the safe work practices outlined above, the refinery conducts regular physical conditions inspections to ensure compliance with federal, state, and local regulations, and company loss control requirements. 
Specific physical conditions inspections are conducted of each proce 
ssing unit, storage and tankage areas, maintenance facilities, warehouse, laboratory, office buildings, and contractor work sites.  Safe work practices, such as lock out/ tag out, hot work, etc. are available from safe work practices computer database. 
Management of Change 
The intent of this procedure is to assure that all modifications to equipment, procedures, raw materials and processing condition other than "replacement in kind" are safe.  Management of Changes is the responsibility of the PSM Superintendent. 
Incident Investigation 
The incident investigation program covers all loss, and near loss (near miss), incidents that occur at the refinery.  Examples of incidents covered by this policy but not limited to are: occupational injuries and illness, unit upsets, production loss, property damage or loss, and environmental incidents such as spills and releases.  Incident investigation is the responsibility of the Safety Superintendent. 
The purpose of the policy is to ensure tha 
t effective incident reporting and investigation procedures are carried out efficiently.  To be effective, all investigations are conducted in a timely (within 48 hours for serious incidents), organized, and objective manner.  The purpose of an investigation is not to fix blame, but rather to determine the facts surrounding the incident, present the findings and conclusions, and make recommendations for corrective actions that will prevent a similar occurrence in the future.  An incident investigation team will investigate all serious incidents. 
Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the Ferndale Refinery periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. 
Per WAC 296-67-057, this facility verifies PSM compliance every three years with an audit.  The PSM Superintendent is responsible for implementing the compliance audit portion of t 
he prevention program. 
Chemical Specific Prevention Steps 
The processes at the refinery have hazards that must be managed to ensure continued safe operation.  The accident prevention program summarized previously is applied to the program 3 process at the Facility.  Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. 
Some of the administrative programs to prevent, detect or mitigate an incident at the facility are presented above.  Specific safety equipment and procedures, known as safeguards, are in place at the facility.  These safeguards are listed as part of the process hazard analyses, process safety information, and in the operating procedures.  Some examples of safeguards are presented below. 
Release Detection 
7 Hydrogen sulfide and hydrogen fluoride detectors with alarms 
7 Facility alarm system to notify personnel in case of emergency 
Release Containment/Control 
7 Process rel 
ief valves to protect all pressure vessels 
7 Operating materials recovery system with process flare to incinerate excess materials from the process 
7 Manual and automatic valves to permit isolation of the process 
7 Automated shutdown systems for specific process parameters 
7 "Fail-safe" valves to isolate equipment in case of unplanned events such as power failures and earthquakes 
7 Containment around all tanks and process areas to contain liquid materials 
7 Backup power supply for critical process equipment 
Release Mitigation 
7 Fire suppression and extinguishing systems 
7 Water deluge systems for specific equipment 
7 Trained emergency response personnel 
7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 
7 Blast-resistant buildings to help protect control systems and personnel 
7 Backup fire protection equipment 
Emergency Response Program Summary 
The Ferndale Refinery provides resources for planning in case of emergencies at the facility.   
The facility is a contributor to the community by protecting the plant and neighbors from damaging effects of emergency situations.  The facility design, maintenance, operating procedures, and training provide for risk minimization before an accident can occur.  In spite of all these things, emergencies can arise, sometimes through forces beyond control.  The emergency response plan, along with training and drills, is designed to prepare the facility to recognize emergency situations of various types and react promptly and correctly to minimize any ill effects.  Local, state, and federal safety rules dictate that the facility study and understand the principles and specifics covered in this preplanning effort and fully understand all roles in the plan. 
The purpose of the Ferndale emergency plan is to provide a cohesive procedure for coordinating effective response procedures by all plant personnel in order that danger to employees, contractors, the general public and the environment m 
ay be lessened in the unlikely event of an emergency. 
Management Systems 
The Refinery Manager is ultimately responsible for implementation of the risk management measures set forth in this document.  The Process Safety Management Superintendent is responsible for upkeep of the Risk Management Plan and Hazard Assessment, and all supporting documentation.  The individual departments assigned in above implement each element of the Prevention Program. 
Planned Enhancements to Safety 
Through the use of prevention programs such as Management of Change and the Process Hazard Analysis revalidation program, Tosco is constantly re-evaluating the current safety systems.  As a result of these, and other safety and risk management initiatives, improvements to the safety of the workers and the surrounding community continue to occur.   
The following is an example of the types of modifications planned at the Tosco Ferndale facility: 
1.  HF laser detectors.  To facilitate quick detection of a hy 
drofluoric acid release, Tosco is installing unit perimeter laser detectors in the acid section of the Alkylation Unit.  These detectors are calibrated to alert operations personnel of a release of HF.  This equipment, combined with the currently installed video monitoring system in the control room, will provide operations staff with the best available technology for detecting HF leaks. This early warning system will assist operations and emergency response personnel in quickly mitigating the release to prevent any offsite consequences, or onsite injuries. 
2. Acid inventory management system.  This emergency system, to be implemented in the Alkylation Unit, will allow operators to transfer hydrofluoric acid from the process unit equipment to single safe storage location.  If a leak were to occur within the process equipment, the operator would activate the emergency acid inventory management system (AIMS), to reduce the duration of an acid release, and to store the acid in a safe loca 
tion until the equipment can be repaired.   The AIMS system will be able to be activated both from the Alkylation Control room, and from another, remote location.  Once activated, a series of emergency operated valves (EOVs) would systematically isolate the process equipment, at the same time transferring any acid in the system to a dedicated Emergency Acid Storage Tank.  The emergency tank is adequately sized to store the process inventory of acid.  When the system has been repaired, the acid in the emergency system can be safely transferred back into the process, without requiring any disposal of material.   
3.  Y2K task force.  Tosco recognizes the importance of the potential impact of the Year 2000 (Y2K) on the facility.  To ensure that the date change does not result in safety or environmental impacts, Tosco has convened a Y2K task force, which consists of engineering, operations, information technology, and managerial staff.  The group was tasked to perform an internal audit to i 
dentify and remedy all potential failure situations arising as a result of the computer bug. Issues that the Y2K task force is addressing include: 
7 Y2K compliance from equipment and software vendors 
7 loss of utilities, such as water, natural gas and power 
7 inoperability of control system computers or inadequate feedback to control room operators 
7 reduced community emergency response capabilities 
7 emergencies at neighboring facilities / outside the plant limits 
Many of these issues had previously been addressed during the unit PHA studies.  As such, redundant or back-up systems, such as a temporary emergency power supplies, field instrumentation, or manual controls are already in place to mitigate against such occurrences.  The operations staff in each unit is trained to handled emergency situations, and will make use of emergency shutdown procedures, if necessary. As a precautionary measure, additional operations and emergency response staff have been requested to work the days o 
f December 31, 1999 and January 1, 2000.
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