Murphy Oil USA Superior Refinery - Executive Summary

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Risk Management Plan Executive Summary 
 
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES 
 
The Murphy Oil USA, Inc. (Murphy Superior) Superior Refinery has a long-standing commitment to employee and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes.  Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our highly trained personnel, working in cooperation with appropriate governmental agencies, will quickly respond to control and contain the release.  In the unlikely event of a catastrophic release, the refinery, working in conjunction with local emergency management staff, is well prepared to respond and mitigate adverse consequences to the community or the environment.  The refinery maintains an accurate and comprehensive emergency  
response plan.  This plan is also maintained in the Douglas County Emergency Government Center.  Emergency notification of the public is coordinated through these agencies. 
 
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES 
 
The Murphy Oil Superior Refinery, located in Superior, Wisconsin, operates a variety of processes to produce petroleum products including: fuel gas, propane, butane, fuel oil, and gasoline, from raw crude oil.  The refinery has several regulated flammables, such as propane and butane as well as hydrogen fluoride (HF), which is a regulated toxic substance. 
 
HAZARD ASSESSMENT RESULTS 
 
The worst-case scenario associated with toxic substances at the Murphy Superior refinery is a catastrophic failure in the Alkylation Unit, resulting in a release of 81,000 lb of HF gas over a 10-minute period. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures has  
been taken into account in evaluating this scenario.  The estimated distance to the point at which EPA considers the effect of such a toxic exposure a serious danger to the public is 25 miles. This estimation is based on EPA's look up tables in accordance with the regulation. 
 
The worst-case scenario associated with a release of flammable substances at the Murphy Superior refinery is a vapor cloud explosion involving the full inventory of the largest storage tank containing normal butane.  The maximum tank inventory of 195,000 lb is assumed to release to the atmosphere, completely vaporize, and ignite, resulting in a vapor cloud explosion.  The maximum distance to the point at which EPA considers the effect of such an explosion a serious danger to the public is 0.47 miles.  Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures were taken into account in evaluating this scenario. This estimation is based o 
n EPA's look up tables in accordance with the regulation. 
 
The alternative toxic release scenario is again for hydrofluoric acid and involves the rupture of an unloading hose from a hydrogen fluoride tank truck.  If this scenario were to occur, our operators would shut off the flow from the truck within a few seconds.  For this scenario, however, we chose to assume that it takes 1 minute to stop the spill, so that the results from our analysis should be larger than would actually be experienced if this event were to occur. The estimated distance to the point at which EPA considers the effect of such a toxic exposure a serious danger to the public is 0.31 miles.  Murphy Superior has never experienced a release approaching this magnitude. 
 
The alternative scenario for flammables is a BLEVE of one of our storage tanks holding isobutane.  Although such events are extremely rare, they can occur when a fire impinges on the storage tank long enough to weaken the vessel. The effects of this sc 
enario may cause second degree burns up to 0.37 miles from the storage tank.  Murphy Superior has never experienced a release approaching this magnitude. 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS 
 
The following is a summary of the general accident prevention program in place at the refinery.  Because processes 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 that are part of the RMP Prevention Program and describes the management system in place to implement the accident prevention program.  Each element of the OSHA PSM standard is assigned an element leader and the responsibilities of the element leaders are outlined in the PSM program which is maintained at the refinery. 
 
Employee Participation 
 
The Murphy Oil Superior Refinery encourages employees to participate in all facets of process safety management, accident prevention and operations. Examples of employee participation includ 
e but are not limited to updating and compiling technical documents, serving on various committees, development of procedures, and participating as members of process hazard analysis (PHA) teams.  Employees have access to all information created as part of the refinery accident prevention program.  Specific ways that employees are involved in the accident prevention program are documented in an employee participation plan.  In addition, the refinery has a number of programs in place that address process safety and employee safety issues. These processes 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 
 
The Murphy Superior refinery keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits f 
or key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is available to all employees through a computerized access system.  This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. Employees are trained and tested on the appropriate range of safe operating limits for process parameters (e.g., temperature, level, composition).  The refinery has a computerized process control system which helps the operators to ensure that the process is maintained within these limits.  Process control systems, monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems) provide a safe operatin 
g environment. 
 
The refinery 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 
 
The Murphy Superior refinery has a comprehensive program in place 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 primarily uses the hazard and operability (HAZOP) analysis technique to p 
erform these evaluations.  HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques.  The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This 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.  
The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team.  This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention.  All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete.  The final resolution of each finding is documen 
ted and retained pursuant to normal policies. 
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Murphy Superior refinery periodically updates and revalidates the hazard analysis 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. The results and findings from these updates are documented and retained pursuant to normal policies.  Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained pursuant to normal policies. 
 
Operating Procedures 
 
The Murphy Superior refinery maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. T 
hese procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators.  These procedures are periodically reviewed and annually certified as current and accurate.  The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process.   
In addition, the operating procedures at the refinery provide guidance on how to respond to upset conditions for specific process or equipment parameters.  This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. 
 
Training 
 
To complement the written procedures for process operations, the Murphy refinery has implemented a comprehensive training program for all employees involved in operating a process.  All new employees receive basic training in refinery operations. After successfully com 
pleting this training, a new operator is paired with a senior operator to learn process-specific duties, tasks and to train on the written operating procedures.  After operators demonstrate (e.g., through written 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, operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level.  This refresher training is conducted at least every 3 years.  All of this training is documented for each operator, including the means used to verify that the operator understood the training.  Murphy Superior also conducts annual HAZWOPER training and has a system in place to provide operators with regulatory training updates.  Training manuals are available to the operators for most positions. 
 
Contractors 
 
The Murphy refinery uses contractors to supplement it 
s work force.  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 site safety rules, and (6) inform refinery personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work.  In addition, the Murphy refinery evaluates contractor safety programs and performance during the selection of a contractor.  Refinery personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 
 
Pre-startup Safety Reviews (PSSRs) 
 
The Murphy r 
efinery conducts a PSSR for facility modifications that warrant a change in the process safety information or operating procedures.  The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service.  This review provides one additional check to make sure construction is in accordance with the design specifications and that supporting systems are operationally ready.  The PSSR team uses checklists to verify aspects of readiness.  A PSSR involves field verification of the construction and serves as a final check that program requirements are properly implemented. 
 
Mechanical Integrity 
 
The Murphy refinery has well-established practices and procedures to maintain pressure vessels, piping systems, relief 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.  Murphy Superior has a comprehensive training program for all maintenance workers.  Written maintenance procedures help ensure that work is performed in a consistent manner.  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 befor 
e placing the equipment back into service. The temporary use of equipment would be allowed only after the system is reviewed to determine what actions are necessary to ensure the safe operation of the equipment until a repair can be made (e.g. reduction of pressures or temperatures).  The temporary use of equipment is covered under the MOC policy which addresses these types of issues. 
Another integral part of the mechanical integrity program is quality assurance.  The Murphy refinery incorporates quality assurance measures into equipment purchases and repairs.  This helps ensure that equipment and parts are suitable for their intended use and that proper materials and spare parts are used when repairs are made.  
 
Safe Work Practices 
 
The Murphy refinery has long-standing safe work practices in place to help ensure worker and process safety.  Examples of these include (1) control of the entry/presence/exit of all personnel including employees and support personnel, (2) a lockout/tagout  
procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space.  These procedures (and others), along with training of personnel, form a system to help ensure that operations and maintenance activities are performed safely.  Procedures are available to all personnel in a Standard Practice Instruction manual maintained at the refinery. 
 
Management of Change 
 
The Murphy refinery has a comprehensive system to manage changes to processes.  This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented.  Ch 
anges are reviewed to (1) ensure that adequate controls are in place to manage 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 necessary training on the change. 
 
Incident Investigation 
 
The Murphy refinery promptly investigates incidents that resulted in, or reasonably could have resulted in, a fire, explosion, or toxic gas release that caused 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 forwards these results to refinery management for resolution. Corrective a 
ctions 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 employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.  The Superior refinery has had no incidents with offsite impacts and has had no reportable accidents under the regulation.  This is due in part to a commitment to fully investigate even small incidents such that future incidents can be prevented. 
 
Compliance Audits 
 
To help ensure that the accident prevention program is functioning properly, the Murphy refinery periodically conducts an audit 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 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 the two most recent audit reports are retained pursuant to normal policies.   
 
CHEMICAL-SPECIFIC PREVENTION STEPS 
 
The processes at the Murphy refinery have hazards that are managed to ensure continued safe operation. The accident prevention program summarized previously is applied to EPA RMP-covered processes at the Murphy refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. 
In addition to the accident prevention program activities, the Murphy refinery has safety features on many units to help (1) contain and control a release, 
(2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release.  The following types of safety features are used in various processes: 
 
 
Release Detection 
* Fixed Hydrocarbon detectors with alarms 
* Fixed Hydrogen sulfide detectors with alarms 
* Portable Hydrocarbon/H2S detectors 
 
Release Containment and Control 
* Process relief valves that discharge to a flare to capture and incinerate episodic releases 
* Scrubber to neutralize chemical releases 
* Valves to permit isolation of the processes (manual and/or automated) 
* Automated shutdown systems for specific process parameters (e.g., high level, high temperature)Curbing or diking to contain liquid releases 
* Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 
* Atmospheric relief devices 
 
Release Mitigation 
* Fire suppression and extinguishing systems  
* Deluge system for specific equipment 
* Trained emergency response personnel 
* Persona 
l protective equipment (e.g., protective clothing, self-contained breathing  
apparatus, class A protective suits) 
 
 
FIVE-YEAR ACCIDENT HISTORY 
The Murphy refinery has an excellent record of accident prevention over the past 5 years.  Murphy has experienced no accidents in the past 5 years involving an RMP-regulated substance that have resulted in any of the EPA-specified onsite or offsite effects. One reason for our success at preventing accidents is that we investigate incidents very carefully to determine ways to prevent similar incidents from occurring.  
 
EMERGENCY RESPONSE PROGRAM INFORMATION 
 
The Murphy refinery 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. Specific emergency response procedures address aspects  
of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and postincident cleanup and decontamination requirements.  Also, the Murphy refinery 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 as necessary to perform their specific emergency response duties. The emergency response program is reviewed annually and updated when necessary based on modifications made to refinery processes or other refinery facilities.  
The overall emergency response program for the Murphy refinery is coordinated with the Superior Local Emergency Planning Committee (LEPC), the fire department, the sheriff's office, and state and federal agencies through the 
Incident Command System. This coordination includes periodic meetings of the committee, which includes local emergency response officials, government officials, and industry representatives.  The Murphy refinery has around-the-clock communications capability with appropriate community officials (e.g., the fire department, regional hazmat team) and emergency response organizations through the 911 system.  In the event of a release, which so warrants, 911 would be called with information on potential community impact.  The local community government and response personnel would then initiate the proper response warranted by the situation. This system provides a means of facilitating quick response to an incident, as well as notifying the public of an incident if necessary.  In addition to periodic LEPC meetings, the Murphy refinery conducts periodic emergency response exercises that involve refinery personnel, contractors, and emergency response organizations.  The refinery provides ann 
ual refresher training to on site emergency responders regarding their responsibilities during an emergency and has a trained emergency response team.   
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
The Murphy refinery resolves findings from PHAs, some of which result in modifications to the process.  The following types of changes are planned: 
 
Additional equipment to respond to HF releases which will include process monitors for the detection of HF, a water curtain surrounding portions of the alkylation unit, operator controlled reticulating monitors to fog the area, and a camera system which will allow remote monitoring of any releases and associated response activities.  These systems should be in place by the end of 1999. 
 
Addition of a deluge system surrounding the pressurized storage tanks.  This would provide cooling to vessels in the event of a fire in that area.  This system should be in place by the end of 1999. 
 
We are currently working with local officials to develop a community not 
ification system to  provide notification of the public in the event of a release.  This system will inform them of the proper actions to take in the event of an emergency (i.e. shelter in place, evacuate).
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