Marathon Ashland Petroleum, LLC ILRefiningDivision - Executive Summary
MARATHON ASHLAND PETROLEUM |
ILLINOIS REFINING DIVISION
Risk Management Program Plan
1. EXECUTIVE SUMMARY
The Marathon Ashland Petroleum's Illinois Refining Division (hereafter referred to as "IRD") is committed to operating in a manner that is safe for IRD workers, the public, and the environment. As part of this commitment, IRD has established systems to help ensure safe operation of the processes at this facility. One part of these systems is a risk management program (RMP) that helps manage the risks at IRD and that complies with the requirements of the Environmental Protection Agency's (EPA's) rule 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at IRD. This document is intended to satisfy the RMPlan executive summary requirements of the RMP rule and to provide the public with a description of the risk
management program at IRD.
1.1 Accidental Release Prevention and Emergency Response Policies
IRD is committed to the safety of its workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. IRD implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, our trained personnel will respond to control and contain such releases. IRD evaluates each situation, evacuates workers as necessary and responds based on our capabilities and training. If necessary, outside emergency responders, including the local fire department would be contacted to assist in controlling and containing the release and to prevent and/or reduce the consequences of the release. IRD, the local emergency planning committee (LEPC), and the fire department have also established a system to use for warning the community if an accident occurs that could threate
n the community.
The IRD Division Manager has overall responsibility for the development and implementation of the risk management program for EPA-regulated processes at division facilities. However, the specific responsibilities for certain aspects of that program have been delegated by the Division Manager to other personnel who report either directly, or through other management personnel, to the Division Manager. Those relationships are depicted on the division organization chart maintained by the Division Manager's staff. Specific responsibility for the implementation of the division process safety management (PSM) and accident prevention program has been delegated to the Division PSM Coordinator, who is responsible for the RMP hazard assessment and risk management plan. The division emergency response program, including compliance with the RMP aspects of that effort, is the responsibility of the Division Safety Supervisor. In keeping with our policy that safe operation is
part of everyone's job, many other division personnel are also involved in RMP activities on an ongoing basis.
1.2 IRD Regulated Substances
IRD is a full range refinery and petroleum products facility located in Robinson Illinois. We use crude petroleum as our feed material and make a variety of petroleum-based products, including gasoline, diesel fuel, jet fuel, heating oil, petroleum coke, and liquefied petroleum gases such as propane and butane. Many of these products are flammable substances that EPA has specifically listed in the RMP rule and are present in our process units above the EPA threshold quantity of 10,000 lb. In total, we have 15 processes that are covered by the RMP rule because of their flammable process materials. These processes are listed in the RMP data included with this summary (Section 1.17 of the RMP Data Elements).
In addition to coverage because of flammable materials, IRD also handles one toxic substance regulated by the RMP rule. Hydrofluoric
acid is used as a catalyst in the HF Alkylation unit that produces gasoline. This unit is covered because it contains more than the EPA RMP threshold quantity of hydrofluoric acid.
1.3 Offsite Consequence Analysis
IRD performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance that could affect the public or the environment. The offsite consequence analysis consists of evaluating both worst-case scenarios and alternative release scenarios. IRD does not expect a worst-case release scenario to ever occur. An alternative release scenario represents a release that might occur during the lifetime of a facility like IRD. Alternative release scenarios can be used to help the local emergency planning committee (LEPC) improve the community emergency response plan. We have submitted release scenario analyses to EPA and have shared that information with the LEPC and other organizations involved in emergency response activities. It is
also available to local residents and businesses. The paragraphs below briefly describe some of the scenarios we analyzed and are the scenarios for which we have included detailed information in our risk management plan. Please recognize that none of these events have occurred at our facility. Also, for some of these events, we have emergency mitigation systems that should help reduce the consequences of the events if they occurred. In all cases, if such events occurred, we would activate our emergency response plan to respond to the event, notify local authorities, and take appropriate actions to protect both our employees and people in the community.
Worst-case Release Scenarios
The worst-case scenario associated with toxic substances in RMP-covered processes at the refinery is a failure of the hydrofluoric (HF) acid storage tank in our HF Alkylation Unit. If such a failure released the maximum inventory of the tank (410,000 pounds), the HF acid would vaporize, resulting in a
toxic exposure hazard in the downwind area that would extend outside of the boundary of the refinery. As specified by EPA, this analysis assumes that all of the HF acid is released to the air and no credit is taken for operation of our HF acid vapor mitigation system (i.e., a water spray system to reduce the amount of vapor that leaves the unit if released).
The worst-case scenario associated with a release of flammable substances in RMP-covered processes at the refinery is a vapor cloud explosion, involving the full inventory of the largest storage tank containing a mixture of butane, isobutane, and isopentane. The analysis assumes that the maximum possible inventory of 4,200,000 pounds is released, completely vaporizes, and ignites, resulting in a vapor cloud explosion. Because there are some public receptor locations just outside the refinery property, this event could affect members of the public at those closest locations.
There are no Program 1 processes at the refinery; ther
efore, no additional worst-case analyses are reported in this risk management plan. Also, we did not identify any worst-case scenarios that would affect public receptors other than the receptors affected by the scenarios reported above.
Alternative Release Scenarios
We analyzed numerous release scenarios for toxic materials. The single toxic release scenario we are reporting as part of the risk management plan involves a release of HF acid from a hose failure during tank truck unloading. This would result in a release of 4,617 pounds of HF acid in the time required to isolate the truck and the acid storage tank, thereby stopping the release. The analysis indicated that the resulting HF vapor cloud could result in toxic exposures to people outside the refinery boundary.
The alternative release scenario in our risk management plan for flammable substances at the refinery is a vapor cloud explosion from a failure of a transfer hose during propane truck loading. The hose failure woul
d release 24,800 pounds of flammable material in the time required to isolate the release. The analysis assumed that all of this material would be involved in a vapor cloud explosion and showed that the resulting overpressure from the explosion would affect public receptor locations outside the refinery.
As stated previously, we have included details regarding these scenarios in the additional information submitted to EPA with this executive summary, and have shared that information with the LEPC, other organizations involved in emergency planning, and members of the local community. If you are interested in this information, please contact the IRD Environmental & Safety Manager at (618) 544-2121.
1.4 Accidental Release Prevention Program
The following is a summary of the general accident prevention program in place at the IRD. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject to the Occupational Safety and Health Administration (OSH
A) process safety management (PSM) standard, and because the OSHA PSM requirements are very similar to the EPA RMP requirements for refineries, this summary addresses each of the OSHA PSM elements. The PSM program at this facility has been extended by IRD, where necessary, to satisfy EPA's Program Level 3 accident prevention program requirements.
IRD 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 process hazard analysis (PHA), incident investigation, and compliance audit teams. Employees have access to all information created as part of the IRD 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 IRD and addresses each accident pr
evention program element. In addition, IRD has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming 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
IRD 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 IRD 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 written employee participation plan to help employees locate any necessary process safety informatio
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, IRD has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in a Critical Process Variables Document. IRD ensures that the process is maintained within these limits by using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).
IRD also maintains numerous 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,
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
IRD has a comprehensive PHA 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 those hazards.
IRD 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 available. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the
process as well as accident prevention and mitigation measures, and makes recommendations for additional prevention and/or mitigation measures when the team believes such measures are necessary.
The PHA team recommendations are forwarded to local and corporate management for resolution. Implementation of safety improvements in response to PHA findings is based on a relative risk ranking assigned by the PHA team. They ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved safety improvements being implemented in response to PHA team recommendations are tracked until they 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, IRD periodically updates and revalidates the PHA 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. Offsite consequences have been incorporated in all PHA's completed after August 1996. The results and recommendations from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the recommendations is documented and retained.
IRD 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 can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and annually certified as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made to the process. In addition, IRD
operating procedures provide guidance on how to respond to events that result in exceeding safe operating limits for specific process or equipment parameters. The written operating procedures are readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks.
To complement the written procedures for process operations, IRD has implemented a company training program for all employees involved in operating a process. New employees receive basic training in IRD operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior 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 periodically receive refresher trai
ning 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.
IRD uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, IRD 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 IRD 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 haz
ards, (3) emergency response plan requirements, (4) safe work practices prior to their beginning work, and (5) work permit process (i.e. hot work, confined space, etc.). In addition, IRD evaluates contractor safety programs and performance during the selection of a contractor. IRD personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Reviews
IRD conducts a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information. The purpose of the review 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 review team uses checklists to verify all aspects of
readiness. A review involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
IRD 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 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 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. IRD 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
RD 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/tagout 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 welding and other spark-producing activities, 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 activities are performed safely.
Management of Change
IRD 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), 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 and maintenance personnel are provided with any necessary training on the change.
IRD 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 and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwa
rds these results to IRD management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked 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.
To help ensure that the accident prevention program is functioning properly, IRD periodically conducts audits to determine whether the 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 IRD management for resolution. Corrective ac
tions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
1.5 Chemical-specific Prevention Steps
The processes at IRD have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at IRD. Collectively, these prevention program activities help prevent potential accident scenarios of both hydrofluoric acid and flammable substances caused by equipment failures or human errors.
In addition to the accident prevention program activities, IRD has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safety features are used in various processes:
( Hydrocarbon detectors with alarms in the LPG storage facilities
( Hydrocarbon detectors with alarms in the HF Alkylation unit area.
* Process relief valves that discharge to a flare to capture and incinerate process materials to prevent overpressure damage to equipment.
* Relief gas scrubber to neutralize releases from process relief valves on the HF Alkylation unit.
( Acid storage tank used for the removal of hydrofluoric acid from the HF Alkylation unit in the event of a release.
* Release mitigation systems (water spray systems) in the HF Alkylation unit.
* Manual and automatic valves to permit isolation of the processes.
* Automated shutdown systems for specific process parameters (e.g., high level, high temperature).
* Curbing or diking to contain liquid releases.
* Redundant equipment and instrumentation where needed (e.g., uninterruptible power supply for some critical process control system, redundant firewater pumps, electrical and diesel).
* Fire suppression and extinguishing systems (dry c
hemical and liquid).
* Deluge system for LPG storage tanks and HF Alkylation process.
* Trained emergency response personnel.
* Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)
1.6 Five-year Accident History
No releases of regulated substances have occurred from IRD in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site.
1.7 Emergency Response Program
IRD 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
exposures, refinery evacuation plans and accounting for refinery personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and postincident cleanup and decontamination requirements. In addition, IRD has procedures that address 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 to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to refinery processes or facilities.
The overall emergency response program for IRD is coordinated with the Crawford County local emergency planning committee (LEPC) and with offsite responders who would be called to support emergency response efforts if required. This coordination includes periodic meetings of the LEPC, which includes local emergency response officials, lo
cal government officials, and industry representatives. IRD has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department), as well as direct access to the city's community warning system. 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 participating in periodic LEPC meetings, IRD conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.
1.8 Planned Changes to Improve Safety
IRD constantly strives to improve the safety of its operations through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers. IRD resolves in a timely manner all findings from PHAs, some o
f which result in modifications to the process. The following types of changes are planned during the next 5 years:
* Revisions to personnel training programs.
* Upgrade fireproofing on structure at the Catalytic Cracking unit.
* Improved spill control dikes in the tank farm.