ARCO Los Angeles Refinery - Executive Summary |
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ARCO LOS ANGELES REFINERY RISK MANAGEMENT PLAN EXECUTIVE SUMMARY This summary provides an overview of the ARCO Los Angeles Refinery's Program to comply with the U.S. EPA's Risk Management Plan (RMP) and the California Accidental Release Prevention Plan (Cal ARP). ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The ARCO Los Angeles Refinery (LAR) is committed to protecting the health and safety of its employees, contractors, customers, and the general public. Conducting business in a manner that wins public confidence and meets the environmental and economic needs of the communities we serve is critical to our long-term success. This commitment is demonstrated by the resources invested in accident prevention, including the design, construction, operation and maintenance of our facilities, as well as in the training or our employees. Our policy is to implement the necessary controls to prevent foreseeable releases of regulated substances. If a release does occur, we have trained personnel who will respond to control and contain the release, thereby reducing potential impact on our surrounding community. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The ARCO Los Angeles Refinery is located in the city of Carson, California. The site occupies 630 acres and employs more than 850 people. The refinery has to capacity to process approximately 265,000 barrels of crude oil per day to produce a variety of petroleum products, including gasoline, jet fuel, diesel fuel, and petroleum coke, as well as products such as propylene, natural gas liquids and other petrochemicals. The facility also includes the Watson Cogeneration Unit, which is a joint venture between Atlantic Richfield Company and Southern California Edison. The Cogeneration Unit burns natural gas to produce electricity, which is sold to the Edison grid. Waste heat from the process is then used to supply steam to the refinery for process use. The refinery has seve ral regulated flammable substances, such as propane, butane, pentane, etc. In addition, the facility uses ammonia, which is a regulated toxic chemical, in the Cogeneration facility and in the refinery. The primary use of ammonia is in the air pollution control system for the reduction of emissions of nitrogen oxides. It is also used for process corrosion control. HAZARD ASSESSMENT RESULTS Ammonia Hazard Assessment Results The EPA-prescribed worst case scenario (WCS) associated with toxic substances in a Program 3 process at the refinery is a catastrophic failure of the ammonia storage tank in the Cogeneration Unit. Administrative controls are in place, which limit the storage volume in the tank to a maximum volume of 117,200 pounds. In the EPA WCS, the entire contents of the tank are released over a 10-minute period. Atypical and unfavorable weather conditions exist; there is no wind to help disperse the vapors. Although there are numerous controls in place to prevent this type of catastrophic release and to minimize the consequences of such a release, per the EPA-prescribed methodology, none of these mitigation systems are considered in this release scenario. Under these conditions, the maximum distance to the EPA endpoint of 200 ppm (parts per million) for this EPA WCS is 3.6 miles. The alternative case scenario (ARS) for ammonia is a hose failure during off-loading of a tanker truck to the Cogeneration storage tank. With a two-inch hole in the loading hose, and assuming failure of all controls, the entire contents of one of the truck compartments are released in 10 minutes, during which time personnel mobilize a hazardous material response effort to shut down the equipment. With the release of 24,750 pounds of ammonia, the maximum distance to the toxic endpoint of 200 ppm in this ARS is 0.5 miles. Flammable Hazard Assessment Results The EPA-prescribed WCS associated with a release of flammable substances in Program 3 processes at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing pentane. The full inventory of 6,052,944 is assumed to release. Atypical and unfavorable weather conditions exist; there is no wind to help disperse the vapors. Following the EPA-prescribed methodology for this scenario, the material vaporizes and ignites, resulting in a vapor cloud explosion. The maximum distance to the 1-psi endpoint for this EPA WCS is 1.5 miles. Although there are numerous controls in place to prevent such releases and to manage their consequences, per the EPA prescribed methodology, no credit is given for any mitigation measures in this scenario. The ARS for flammable substances at the refinery is a VCE resulting from the release of butane from a transfer line during the offloading of a rail car to a refinery storage tank. In this scenario, the hose uncouples, existing controls are assumed to fail, and butane is released to atmosphere. The release is isola ted and stopped within 20 minutes, during which time 142,000 pounds of butane (the contents of the railcar) are released. The maximum distance to the 1-psi endpoint for this event is 0.2 miles. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the general accident prevention program in place at the ARCO Los Angeles Refinery. Because processes at the refinery 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 systems in place to implement the accident prevention program. Employee Participation The ARCO Los Angeles Refinery provides for and 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 operating procedures to participating as a member of process hazard analysis (PHA) and incident inves tigation teams. Employees have access to all information created as part of the refinery accident prevention program. In addition, the refinery has a number of programs underway that address employee safety issues, including a comprehensive program for behavioral safety. This program provides training for each employee to enable them to observe fellow employees in order to identify and correct behaviors that may lead to accident or injury. Developed and managed by our employees, this peer review program is a well supported by our employees and is a fundamental part of our safety program. Other ways that employees are involved in the accident prevention program are documented in written programs maintained at the facility. Process Safety Information The Los Angeles Refinery maintains extensive documentation that is used to help maintain safe operation of the processes. This documentation addresses chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the refinery are assigned responsibility for maintaining up-to-date process safety information. Chemical specific information, including exposure hazards and emergency response information is provided in material safety data sheets (MSDS). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the refinery has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) contained in Operating Manuals and Design Process Books. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g. automated shutdown systems). The refinery also maintains documentation th at provides 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 The Los Angeles 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 refinery uses the HAZOP (hazard and operability) analysis method and other approved Process Hazard Analysis methods to perform these evaluations. The analyses are co nducted using a team of people who have operating and maintenance experience as well as engineering expertise. The hazards of the process, identification of previous incidents involving accidental release or potential for such, engineering and administrative controls and failure of such, and human factors will be addressed by the team performing the hazard analysis. The findings and recommendations of the team are submitted to area management to assess the likelihood of the potential hazards, assess the severity of the consequences from potential releases, and assign priority for implementation of recommendations. The recommendations and progress towards implementation is followed using a computerized tracking system. The final resolution of findings are 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, LAR periodically updates and revalidates the hazard analysi s results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer in operation. The results and findings from these updates are documented and retained. Operating Procedures The Los Angeles Refinery maintains written procedures that address various modes of process operations, such as 1) unit startup, 2) normal operations, 3) temporary operations, 4) unit emergencies and emergency shutdown, 5) normal shutdown, and 6) initial startup of a new process. The operating procedures are currently available to anyone working in or near a process area at the appropriate process unit control rooms or through area supervisors. The operating procedures are also maintained on-line on the ARCO LAR computer network. The operating procedures are reviewed by supervision before scheduled activities (e.g. scheduled start-ups and shutdowns, scheduled on-line maintenance) and when supervision believes that the current p rocedure should be modified to better execute the planned activities. Critical procedures such as unit emergency procedures are reviewed annually during annual training sessions. Training To complement the written procedures for process operations, ARCO LAR has implemented a comprehensive training program for all employees involved in operating or maintaining a process. Initial training for operating and maintenance personnel who are new to a process includes health and safety training, fundamentals of refining, process overview and process fundamentals. Job specific training is given to operators assigned to an operating unit. This training includes specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the operator's job tasks. Job specific training includes on-the-job training, a written manual, written tests, observations, and written sign-off. LAR also has ongoing refresher and supplemental training for all person nel. Testing is conducted for all job specific training and craft qualification for each level of progression. Once an operator is qualified in a position, they are required to recertify for the job every three years by comprehensive testing. Testing is also conducted on all OSHA-required safety and health training. Employee training and certification records are documented, both in hard copy and computerized training records. Contractors ARCO LAR uses contractors to supplement its work force during periods of increased maintenance or construction activities, or to perform tasks requiring skills that are needed on a non-routine basis. Because some contractors work on or near process equipment, the refinery has procedures in place to ensure that contractors 1) perform their work in a safe manner, 2) have the appropriate knowledge and skills, 3) are aware of the hazards in their workplace, 4) understand what they should do in the event of an emergency, 5) understand and follow sit e safety rules, and 6) inform refinery personnel of any hazards that they find during their work. This is accomplished by providing contractors with a process overview, information about refinery safety and health hazards, emergency response plan requirements, and safe work practices prior to their beginning work. Additionally, all contractors that work at LAR must have completed an 8-hour training program (Refinery Safety Orders) that provides a standardized baseline of safety and health training for all contractors that perform work at local area refineries. Recertification to demonstrate knowledge of the required subject areas is required every two years. In addition, ARCO LAR evaluates contractor safety programs and performance as one of the key criteria for selection of a contractor to perform work in the refinery. Refinery personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-Startup Safety Reviews A pre-startup safety review is conducted at LAR for any new/modified facilities where modification necessitates a change in the process safety information. The pre-startup review is used to confirm that prior to the introduction of hazardous materials to a process, that the following takes place: 1) construction and modification are in accordance with design specifications and applicable codes; 2) safety, operating, maintenance, and emergency procedures are in place and adequate; 3) training of each operating employee and maintenance worker has been completed; and 4) process hazard analysis recommendations have been resolved or actions necessary for startup have been completed. The review uses checklists to verify all aspects of readiness, and involves field verification of construction where necessary. Mechanical Integrity ARCO LAR 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) written procedures to maintain ongoing integrity of process equipment, including methods to allow employee identification and reporting of mechanical integrity problems; 2) inspection and testing, including correction of deficiencies; 3) employee training; and 4) quality assurance. LAR employees report potentially faulty or unsafe equipment via one or more of the following: Operator Daily Logs, a Maintenance Job Order System, direct notification of supervision, EH&S audit programs, or focused audits (platforms, electrical, etc.). LAR has an extensive inspection and testing program. The frequency of inspections is based on historical corrosion rate. LAR has a comprehensive database program, which assimilates and analyzes corrosion data from equipment at LAR and determines their corrosion rates. These rates, together with industry standards or codes are used to determine fre quency of inspections. All inspectors at LAR have certification in the appropriate performance area. Written documentation is maintained for both the administrative and technical procedures. Inspection deficiencies are documented. The status of each inspection and repair completion is tracked until the issue is resolved, implemented, and closed. Another integral part of the mechanical integrity program is quality assurance. ARCO LAR incorporates quality assurance measures into equipment purchases and repairs. Procedures are in place to ensure that new pressure vessels, piping systems, rotating equipment, storage tanks, instrumentation and control equipment, including spare parts are: 1) modified, repaired or fabricated to meet applicable codes; 2) meet design specifications and applicable codes; and 3) are inspected and checked for proper installation and consistency with specifications and manufacturer' instructions. As part of this program, Positive Material Identification (PM I) is conducted, which involves physical testing to ensure that the correct metallurgy is received and installed as specified for both existing equipment, repair work, and new construction. Safe Work Permits ARCO Los Angeles Refinery has long-standing safe work practices in place to help ensure worker and process safety. Examples include 1) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance; 2) a permit and procedure to control spark-producing activities (hot work permit); 3) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space; and 4) a procedure for safe removal of hazardous materials before process piping or equipment is opened. These and other safety procedures, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change ARCO LAR 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 ensure that adequate controls are in place to manage any new hazards and to verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation ARCO LAR promptly investigates all incidents that resulted in, or reasonably could have resulted in personal injury, spills, fire/explosion, release of a toxic or flammable material, major property damage, or environmental damage. The goal of each investigation is to determine the facts and de velop 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 forwards these results to refinery management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are documented and tracked to completion. The investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHA's and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, ARCO Products Company periodically conducts audits of its operating facilities, including LAR, to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted ev ery 3 years. 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 until they are complete. The final resolution of each finding is documented, and audit reports are maintained for review in subsequent audits. CHEMICAL-SPECIFIC PREVENTION STEPS The accident prevention program summarized previously is applied to all EPA RMP and Cal-ARP covered processes at the ARCO Los Angeles Refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures or human error. In addition to these prevention program activities, LAR 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: Release Detection 7 Hydrocarbon detectors with alarms Relea se Containment/Control 7 Process relief valves that discharge to a flare to capture and incinerate episodic releases 7 Valves to permit isolation of the process (manual and automatic) 7 Automated shutdown systems for specific process parameters (e.g., high level, high temperature 7 Diking to contain liquid releases 7 Redundant equipment and instrumentation 7 Atmospheric pressure relief devices Release Mitigation 7 Fire suppression and extinguishing systems 7 Trained emergency response personnel 7 Personal protective equipment (protective clothing, self-contained breathing apparatus) FIVE YEAR ACCIDENT HISTORY The ARCO Los Angeles Refinery has an excellent record of accident prevention over the past 5 years. Due to proactive efforts to prevent accidents and a strong safety program, there have been no incidents in the past 5 years with onsite or offsite effects involving a release of ammonia or a regulated flammable material that meet the reporting criteria of the EPA RMP or Cal-AR P Rules. EMERGENCY RESPONSE PROGRAM ARCO LAR has a comprehensive Emergency Response Plan 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 notification of emergency response agencies if a release occurs that could endanger the public or the environment and post-incident clean-up and decontamination procedures. The plan includes or utilizes the following: 1) pre-emergency planning, including training, drills and reviews; 2) responsibilities for all employees involved in response, control, containment, notification, evacuation, etc.; 3) plans for evacuation to safe areas; 4) emergency traffic control and security; 5) weather monitoring through an on-site weather station (wind direction, wind speed) and vi sible wind socks; 6) emergency first aid and treatment. In addition, the refinery has procedures that address maintenance, inspection and testing of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response plan is updated when necessary, based on modifications made to refinery processes or facilities. The overall emergency response plan for the ARCO Los Angeles Refinery is coordinated with the Los Angeles County Fire Department. This coordination includes periodic meeting and program review as well as joint training opportunities during on-site training exercises and off-site fire and hazardous materials training schools. LAR has around the clock communications capability with appropriate emergency response organizations, which provides a quick means of notifying the public of an incident, if necessary, as well as facilitating a quick response to an incident. Periodic eme rgency drills are conducted that involve the local emergency response organizations, and training is provided to local emergency responders regarding the hazards of regulated substances and other hazardous substances at the refinery. PLANNED CHANGES TO IMPROVE SAFETY The ARCO Los Angeles Refinery is committed to operating excellence in the way we conduct our business and the way we relate to the environment. The company has implemented a system that provides a mechanism for self-assessment and a direction for continuous improvement within our operations. As a result of this self-assessment, we are in the process of evaluating and strengthening our training programs for refinery supervision, and further strengthening our procedures for Management of Change. As an example of this commitment with respect to the regulated chemicals at LAR, we have initiated a review to determine the feasibility of a change from anhydrous ammonia to aqueous ammonia, which could lessen the offsite impa ct in the event of a release. |