Kenai Refinery - Executive Summary
TESORO ALASKA COMPANY KENAI REFINERY |
RISK MANAGEMENT PLAN EXECUTIVE SUMMARY
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Tesoro Alaska Company's (Tesoro's) Kenai refinery has a long-standing commitment to worker 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 trained personnel will respond to control and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Kenai refinery, located in Nikiski, Alaska, operates a variety of processes to produce petroleum products (e.g., natural gas, propane, butane, and gasoline) from raw crude oil. The refinery uses or produces several regulated flammables, such as propane and butane.
D ASSESSMENT RESULTS
The worst-case scenario associated with a release of flammable substances at the refinery is a vapor cloud explosion involving the maximum inventory of the largest storage tank containing flammable substances. If such a massive release were to occur, much of the material would disperse away from the site before the flammable cloud found an ignition source. However, we assume that the entire amount stays within the flammable cloud, thus ensuring that the estimated impact is worse than would actually occur. The maximum tank inventory of 3.4 million lb. is assumed to release, completely vaporize, and ignite, resulting in a vapor cloud explosion (VCE) . The maximum distance to the 1-psi overpressure endpoint for this scenario is 1.2 miles. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive or active mitigation measures was taken into account in evaluating this scenario.
The alternative scenario for
flammables is an explosion of one of our process vessels holding a flammable mixture of mostly propane. Although such events are extremely rare, they can occur when a fire impinges on a tank long enough to weaken the vessel. When such an explosion does occur, a large fireball can often rise for several hundred feet above the storage tank. For this vessel, the potential fireball could cause second degree burns up to 0.11 miles (560 feet) from the vessel and create a 1 psi overpressure up to .4 miles. Tesoro has never experienced a release of this magnitude.
FIVE-YEAR ACCIDENT HISTORY
At Tesoro we are proud of our safety performance. The Kenai refinery has had an excellent record of accident prevention since the start of our operation in 1969. In fact, we have never experienced an incident that impacted people or property outside of the refinery since 1969. One reason for our success at preventing accidents is that we investigate even minor incidents promptly and thoroughly to
determine ways to prevent similar incidents from occurring. Thus, we can eliminate many incidents before they become problems.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program in place at the Kenai refinery.
The Kenai refinery encourages employees to participate in all facets of 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 a process hazard analysis (PHA) team. Employees have access to all information created as part of the Refinery Safety Program. Regularly held safety meetings in each department are one way in which employee's are able to participate in the review and development of programs and work practices. Other specific ways that employees can be involved in the Refinery Safety Program are documented in an employee participation pl
an that is maintained at the refinery.
Process Safety Information
The Kenai 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 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/exposure treatment considerations, 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. The refinery has developed procedures for operating the process within safe limits for temperature, level, composition, etc. In addition the refinery en
sures that the process is maintained within these limits using process controls, monitoring instruments, trained personnel, and protective instrument systems (e.g., automated shutdown systems).
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 Kenai 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 Kenai refinery 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. 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 reviewed and resolved by local management. 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 miti
gation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding 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, the Kenai 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. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.
The Kenai refinery maintains written procedures that address various modes of process operations, such as unit startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and initial sta
rtup 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. 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 Kenai refinery provide guidance on how to respond to upper or lower limit variances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators as electronic files on PC's located in the control rooms and in hard copy (emergency procedures only).
To complement the written procedures for process operations, the Kenai refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in
refinery 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 related 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. Before operating in a process operators must be certified by demonstrating skill and knowledge of in that specific process. In addition, all 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 routinely with the maximum time frame to be 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.
The Kenai refinery uses contractors to suppl
ement its 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.
(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
(4) Safe work practices prior to their beginning work.
Information is provided to contractors during the mandatory contractor orientation. This orientation provides contractors with the general knowledge of the refinery operations, its hazards, work practices, and evacuation procedures for emergencies.
In addition, the Kenai 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 (PSSR)
The Kenai refinery conducts a PSSR for any facility modification that requires a change in the process safety information. 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 an additional check to make sure construction is in accordance with the design specifications and that all systems are operationally ready. The PSSR team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
The Kenai refinery 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.
(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.
(5) Applicable safe work practices to help ensure that they can perform their job in a safe manner.
In addition written procedures are used to help ensure work is performed in a consistent manner and provide a basis for training.
d 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 (MOC) 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. The Kenai refinery 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
The Kenai 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 contract personnel with a 24 hr. security staff.
(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 spark-producing activities (i.e., hot work).
(5) A permit and procedure to ensure that adequate precautions are in place before entry into a confined spaces.
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
The Kenai 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.
Changes are reviewed to:
re that adequate controls are in place to manage any new hazards.
(2) Verify that existing controls have not been compromised by the change.
(3) Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes.
(4) In addition, operating and maintenance personnel are provided any necessary training on the change.
The Kenai refinery promptly investigates all 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 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, the Kenai 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.
CHEMICAL-SPECIFIC PREVENTION STEPS
The processes at the Kenai refinery 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 the Kenai refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures or human errors.
In addition to the accident prevention program activities, the Kenai refinery has safety features on many units to help contain and control a release, quickly detect a release, and reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes:
7 Portable hydrocarbon detectors
7 Gas and toxic detectors for control rooms and the laboratory
7 H2S detectors for the su
Release Containment and 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 or automated)
7 Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
7 Vessel to permit partial removal of the process inventory in the event of a release (e.g., a dump tank)
7 Curbing or diking to contain liquid releases
7 Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control
system, backup firewater pump)
7 Atmospheric relief devices
7 Fire suppression and extinguishing systems
7 Deluge system for specific equipment
7 Trained emergency response personnel
7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)
7 Blast-resistant buildings to help protect control systems and personnel
EMERGENCY RESPONSE PROGRAM INFORMATION
The Kenai refinery maintai
ns 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, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the Kenai 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 updated when necessary based on modifications made to refinery processes or other refinery facilities.
The overall emergency response program for the Kenai refinery is coordinated with local emergency responders, such as the fire department and the office of the Alaska State Troopers, as well as state and federal agencies. The Kenai refinery has around-the-clock communications capability with appropriate community officials and emergency response organizations. This provides a means of facilitating quick response to an incident, as well as notifying the public of an incident if necessary. The Kenai refinery conducts periodic emergency response exercises that involve refinery personnel, contractors, and emergency response organizations. The refinery provides refresher training to emergency responders regarding their responsibilities during an emergency.
PLANNED CHANGES TO IMPROVE SAFETY
7 In May of 1999 a new emergency response truck was ordered for the Refinery Fire Brig
ade. This emergency vehicle is the latest technology for use against flammable liquid fires.
7 In February of 1999 the senior management of Tesoro adopted the Tesoro Safety and Health Expectations which are the Tesoro Corporation's system for managing safety more effectively. This system will provide a systematic measurement system to insure continuous improvement to the management of process safety. This measurement will be used at all Tesoro facilities.