Chevron Richmond Refinery - Executive Summary
EXECUTIVE SUMMARY |
This document was prepared as part of the Risk Management Program (RMP) of the Chevron Richmond Refinery. The purpose of this Risk Management Plan (RMPlan) is to:
* Document the safety systems in place at the Chevron Richmond Refinery to protect employees, the community, and the environment from accidental releases, and
* Share information with the community on the refinery's operations, including how substances regulated by RMP are managed and the risks they pose to the community.
E.1 Chevron Corporate Policy on Protecting People and the Environment
The Chevron Richmond Refinery is owned and operated by Chevron Products Company, a division of Chevron U.S.A., Inc. Chevron is committed to being a responsible member of any community in which it has operations by giving top priority to safe and environmentally sound operations. It is Chevron's policy to conduct business in a socially responsible and ethical manner that protects safety, health, and the environment.
This commitment to safe and environmentally sound operations is documented in Chevron Corporate Policy 530, Protecting People and the Environment, and in the Chevron Richmond Refinery's mission statement.
Our Vision at the Chevron Richmond Refinery is "to achieve pacesetter performance in system reliability, incident-free operation, and on-time and on-test product, at the lowest sustainable cost. We will achieve pacesetter performance through the knowledge, pride, creativity, teamwork and commitment of all employees." In pursuit of our Vision, we follow these guiding principles:
* Ensure that our activities promote a safe and healthful workplace by focusing on reliable and consistent operation of refinery facilities.
* Conduct our business with the highest ethical standards in compliance with the letter and spirit of the law.
* Recognize that people are valuable and that human performance is the key to our success.
* Continuously improve the skills and knowledge of our employees.
Create a work environment characterized by:
- questioning, creative, and innovative employees who believe "I can make a difference",
- employees committed to open communication, teamwork, and personal involvement, and
- participative leadership based on coaching and facilitation.
* Prevent adverse impacts of our business on the environment and the surrounding community.
* Foster an awareness of our stakeholders and focus our efforts on satisfying them.
* Demonstrate stewardship by effective management of time, facilities, and financial resources.
* Continuously improve the quality of our products and work processes.
E.2 Description of the Stationary Source and Regulated Substances
The primary business of the Chevron Richmond Refinery is to make transportation fuels from crude oil. Transportation fuel products include gasoline, jet fuel, and diesel fuel. The refinery also produces lubricating oils, liquefied petroleum gas (LPG), and wax products. Several byproducts are produced as p
art of this process, including sulfur and anhydrous ammonia, which are recovered from sulfur and nitrogen contained in the crude oil. The substances regulated by RMP at the Chevron Richmond Refinery include flammable hydrocarbons, anhydrous ammonia, and aqueous ammonia.
E.3 Hazard Assessment
As part of the RMP requirements, the Chevron Richmond Refinery is required to conduct a hazard assessment, which includes a Worst Case Scenario (WCS) analysis and an Alternative Release Scenario (ARS) analysis. The assumptions required by U.S. EPA for use in the WCS analysis are very conservative (and in many cases, unrealistic) and provide results that are unlikely to occur. One reason for this is the fact that the WCS does not take into account the systems and controls the refinery has in place to prevent a catastrophic failure. Consequently, U.S. EPA has stated that the distance to endpoint estimated under worst case conditions should not be considered a zone in which the public is in danger
; rather, the worst case scenario is intended to encourage communication between a facility and the maximum possible residential population.
The ARS, by definition, are more likely than the worst case scenarios; however, they are still very unlikely given the refinery's prevention program. The ARS are used primarily as tools for developing emergency response plans internally and in conjunction with outside emergency response organizations
The RMP rule requires facilities to develop one WCS for regulated toxic substances and one WCS for regulated flammable substances. Additional WCS are required if different public receptors would be affected, and WCS are also required for any Program 1 process (to demonstrate that there are no impacts in a worst-case release). For the WCS, distances were calculated using U.S. EPA's RMP*Comp computer program, which is based on the Offsite Consequence Analysis Guidance issued by U.S. EPA. Worst case weather conditions (F stability and 1.5 meter per s
econd wind speed) were assumed in the WCS analysis.
In addition, one ARS is required for each regulated toxic substance, and one ARS is required for flammable substances as a class. For the ARS, Chevron used a consequence analysis computer program, Canary 3.1 by Quest Consultants, Inc., to provide more refined modeling results. Typical weather conditions (D stability and 3 meters per second wind speed) were assumed in the ARS analysis.
E.3.1 Worst Case Scenarios
The WCS for regulated toxic substances at the Chevron Richmond Refinery involves the release of the entire inventory of an anhydrous ammonia storage vessel over a ten-minute period. Written procedures limit the quantity in the vessel to 220,000 lbs. (45% of vessel volume). This scenario is extremely unlikely given the safety systems in place at the refinery. Further, although there are numerous control measures that, in an actual event, would mitigate the release, no active mitigation systems can be considered in the WCS an
alysis according to the regulations. The WCS analysis shows that the plume of anhydrous ammonia could travel offsite and impact public receptors before dispersing enough to no longer pose an acute health hazard.
The WCS associated with regulated flammable substances is a vapor cloud explosion (VCE) involving the largest LPG storage sphere, which contains butane. The entire inventory of 3.7 million pounds is assumed to release, vaporize, and ignite. Written procedures that limit the liquid quantity to 92% of the vessel volume were taken into account. None of the existing active mitigation systems were considered in the analysis. The WCS analysis shows that the explosion endpoint could reach offsite and impact public receptors.
An additional WCS for flammable substances involves a VCE of a pentane rail car. This scenario is included because it impacts different public receptors than the LPG storage sphere scenario. The full inventory of 160,000 lbs. is assumed to release, vaporize, an
d ignite. The WCS analysis shows that the explosion could reach offsite and impact public receptors.
In addition, a WCS analysis was performed for twenty Program 1 processes. These scenarios involved the release of the entire contents of the vessel containing the largest quantity of regulated substances in each process. No administrative or passive controls were taken into account. None of these scenarios were predicted to have RMP endpoints that reach public receptors.
E.3.2 Alternative Release Scenarios
The ARS for anhydrous ammonia was selected to be a large leak (3/4-inch hole) from a liquid line on the ammonia storage vessel. The refinery has water fog sprays surrounding the NH3 storage area to disperse the vapor cloud in the event of an accidental release. This active mitigation was estimated to reduce the release rate of ammonia by 56% by absorbing and dispersing the released vapor. Detectors, alarms, and automatic shutoffs are in place to minimize the duration of such an acc
idental release; however, a 30-minute release duration was used assuming that manual shutoff would be required. Dispersion modeling predicts that the ammonia could travel offsite before dispersing enough to no longer pose an acute health hazard; however, this scenario does not reach public receptors. If the water spray mitigation is not accounted for, the scenario still does not reach public receptors.
The ARS for aqueous ammonia was selected to be a bleeder break (3/4-inch hole) from an aqueous ammonia storage tank. A 30-minute release duration was used assuming that manual shutoff would be required. No active or passive mitigation was accounted for. Dispersion modeling predicts that the ammonia would neither travel offsite nor reach a public receptor before dispersing enough to no longer pose an acute health hazard. No scenario that is more likely than the worst case scenario was identified as having offsite impacts.
The ARS for regulated flammable substances was selected to be a l
arge leak (3/4-inch hole) in a propane rail car that ignites and results in a flash fire (also known as vapor cloud fire). This scenario was chosen as the most appropriate ARS based on its proximity to the public and the ability to respond to a leak near the railcars before a fire occurs. A propane rail car was chosen over a pentane car (which was used as the WCS) because it had a greater dispersion distance for the same release scenario. A 30-minute release duration was used based on the estimated time to detect and isolate the leak. No administrative controls or mitigation measures were assumed. The ARS analysis predicts that the vapor cloud and resulting fire could extend offsite and reach public receptors.
E.4 Five-Year Accident History
The RMP regulations require facilities to provide information on any accidents in the last five years involving RMP-regulated substances that meet certain criteria. In the last five years, there have been three incidents involving RMP covered pr
ocesses; two of the incidents had offsite impacts. One onsite injury occurred from a butane leak in 1994. A 1997 release of hydrogen sulfide from the HNC process resulted in the activation of the Community Alert Network. Significant onsite property damage, a shelter-in-place order, and one onsite and possible offsite injuries occurred during the Isomax fire in 1999. No offsite deaths, evacuations, or environmental damage has occurred.
E.5 General Accidental Release Prevention Program
A key component of the refinery's prevention program is the Process Safety Management (PSM) program. The Chevron Richmond Refinery applies PSM to the entire refinery, not just to processes that are required by Occupational Safety and Health Administration (OSHA) to implement a PSM program. The refinery's PSM program is documented in Refinery Instruction (RI)-360, "Richmond Refinery PSM Policy". Refinery Instructions are available on the Refinery Information Server, the internal web page for the Chevron
Richmond Refinery, which provides pertinent information accessible to all employees.
E.6 Chemical-Specific Prevention Steps
The processes at the Chevron Richmond Refinery involve hazards that must be carefully managed to ensure safe operation. In addition to the general accident prevention program, the Chevron Richmond Refinery has numerous safety features to quickly detect a release and/or reduce the consequences of a release. Chemical-specific safeguards for RMP regulated substances are described below.
The LPG Storage area has been designed to minimize the risk of releasing LPG to the atmosphere by providing high equipment reliability, minimizing the number of connections, avoiding unnecessary equipment, and protecting against inadvertent damage or failure. Some of the specific prevention and mitigation safeguards are described below:
* The LPG storage spheres are located away from the refinery perimeter to minimize the effect on the public in the even
t of a release.
* Each sphere is separated by a distance equal to at least the diameter of the larger sphere.
* Each sphere is equipped with a firewater deluge system to cool the vessel to prevent failure in the event of a fire.
* The LPG storage area is equipped with alarms, pressure relief devices, and emergency block valves to prevent or limit the severity of a release.
* Each sphere is equipped with a fusible link valve, which is a check valve that will automatically close during a fire and isolate the sphere from all other systems.
* The surrounding area is equipped with a fire suppression system, which consists of fixed fire monitors.
* The drainage near the spheres would cause released liquid to drain away from the spheres and the rest of the refinery and would minimize the surface area to reduce the amount of evaporation.
Anhydrous Ammonia (NH3)
The NH3 Storage area has also been designed to minimize the risk of releasing anhydrous ammonia. Some of the specific prevent
ion and mitigation safeguards are described below:
* The ammonia storage is located away from the refinery perimeter so as to minimize the effect on the public in the event of a release.
* Each storage vessel is equipped with a firewater deluge system to disperse the vapor cloud and to cool the vessel in the event of a fire.
* The NH3 Storage area is equipped with a NH3 leak detection system with both audible and control room alarms.
* The NH3 Storage area is equipped with alarms, pressure relief devices, excess flow valves, and emergency block valves to prevent or limit the severity of a release.
* The NH3 Storage area is encircled by a firewater-monitor fog system, which consists of water fog sprays that effectively disperse the vapor cloud. One large water fog spray can be remotely operated.
* The drainage in the storage area is such that a release of liquid drains away from the bullets and minimizes the surface area to reduce the amount of evaporation.
E.7 Emergency Respon
Overall safety is a function of a facility's prevention program as well as its accident mitigation program, i.e., the ability to minimize the consequences of an accident if one occurs. The Chevron Richmond Refinery maintains an emergency response program designed to protect worker and public safety as well as the environment. As part of the emergency response program, there is a written Emergency Response Plan for responding to accidental chemical releases, including procedures for notifying the public and local emergency response agencies. The program also includes the maintenance, inspection, and testing of emergency response equipment. In addition, the Chevron Richmond Refinery Fire Department, the largest refinery fire department in the country, works closely with local emergency responders in preparing for emergencies.
The Emergency Response Plan addresses all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation pl
ans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release does occur, and post-incident cleanup and decontamination requirements. The Plan is documented in a series of Refinery Instructions (RIs), which are maintained on the Refinery Information Server and are available to all employees. Hardcopies of the plan are also maintained throughout the Refinery. The Emergency Response Plan is reviewed and updated to ensure that it remains accurate and current. Every employee receives training in these procedures as necessary to perform their specific emergency response duties.
The emergency response program has procedures in place for notifying employees, on-site and outside emergency responders, government agencies, and the community in the event of a release. Upon the first detection of a release or other emergency situation, an employee would call the refinery emergency phone number, which initiates the emergency re
sponse. For hazardous material releases with potential offsite impacts (or meeting other reporting criteria), Contra Costa Health Services (CCHS), the Richmond Fire Department, and other agencies are notified immediately. If appropriate, the CCHS will activate the Community Warning System (CWS) to alert the community. The Chevron Richmond Refinery worked closely with CCHS to establish the CWS and was a major contributor to the CWS project. The CWS consists of several components as follows:
* Sirens. Five sirens can currently be activated to provide a loud audible signal throughout the cities of Richmond and San Pablo. Seventeen additional sirens are expected to be in service by July 1999. Upon hearing the sirens, residents should proceed indoors to shelter-in-place and turn on their TV or radio to obtain further instructions or more information about the incident.
* Community Alert Network (CAN). The CAN system is a telephone ring-down system that would automatically call households
in the area of a release to provide notification and instructions.
* Emergency Alert Receivers. In the near future, these small radio devices will be available, which would provide the community with an additional means of notification in the event of a chemical emergency.
* Media. An initial warning, updates, instructions, and an "all-clear" would be distributed to the community through radio, television, and cable by CCHS.
The Fire Department at the Chevron Richmond Refinery has the largest emergency response organization of any refinery in the country; it consists of 30 full-time and 75 volunteer men and women dedicated to providing all aspects of emergency services for the refinery. The Chevron Fire Department trains its personnel to handle any emergency that might occur, including all types of fires (process plant, building, wild fire, etc.), rescues, hazardous material incidents including oil spills, and medical emergencies. The Chevron Fire Department also inspects, tests, an
d maintains a variety of emergency response equipped at the refinery, which includes emergency response vehicles (including fire trucks), fire extinguishers, water deluge systems, in-plant stationary fire monitors, fixed foam systems, and a water fog system.
Also as part of the emergency response program, the Chevron Richmond Refinery works closely with local emergency responders in preparing for, and responding to, emergencies. This includes conducting emergency drills in which an offsite responding agency (Richmond Fire Department and/or CCHS), the Chevron Fire Department, and non-responding employees work together to resolve a given scenario. The Chevron Richmond Refinery also works closely with CCHS for any necessary response to hazardous material releases (such as downwind air monitoring) and to alert the public in case of accidental releases, fires, or explosions.
The Chevron Fire Department also provides mutual aid to the City of Richmond Fire Department and responds outside
of the refinery within the City of Richmond whenever asked to do so by the city fire department. The Chevron Fire Department also belongs to an industrial mutual aid organization, Petrochemical Mutual Aid Organization (PMAO), and has responded to other oil companies and chemical plants during emergencies. Likewise, the emergency response resources of the other companies in PMAO are available for an emergency at Chevron if needed.
E.8 Planned Changes to Improve Safety
Safety has been a part of the working culture at the Chevron Richmond Refinery for many years. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. Studies associated with prevention program elements such as process hazard analyses, incident investigations, management of change procedures, and compliance audits are conducted regularly at the Chevron Richmond Refinery to verify designs and to identify potential hazard
s. Recommendations are developed as a result of reviews of these and other programs, such as equipment inspections, safety meetings, industry experience, technology improvements, and employee suggestions.
The Chevron Richmond Refinery addresses all findings from these programs, some of which result in modifications to the equipment or procedures. Some recent changes that have been made include:
* Reduced the inventory contained in ammonia storage vessels by 40%.
* Replaced gaseous chlorine system at the swimming pool with a solid pellet system.
* Discontinued storage of ammonia railcars at the storage facility outside of the refinery boundary. Storage was moved into the refinery and away from the public.
* Using railroad siding along Castro Street primarily for empty cars. Most of the full LPG railcars are now kept within the refinery, away from the public.