Los Angeles Refinery Wilmington Plant - Executive Summary |
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TOSCO LOS ANGELES REFINERY WILMINGTON PLANT RISK MANAGEMENT PLAN EXECUTIVE SUMMARY FEDERAL EPA PROGRAM ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Tosco's Los Angeles Refinery (LAR) is fully committed to a program of responsible management in all areas, including health, environment and worker and public safety. In fulfilling this commitment, management systems are in place to provide the resources and training to maintain compliance with the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standard, ensuring that safety is incorporated into the design, installation, operation and maintenance of our processes. Accident prevention is emphasized through strict operating procedures, safe work practices, ongoing training and administrative and operational controls. While continually striving to prevent accidental releases, should one occur, the refinery maintains a well-trained and equipped Emergency Response Team for fast response and incid ent mitigation and control. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Tosco Los Angeles Refinery Wilmington Plant, located in Wilmington, California, operates a variety of processes designed to take intermediate oil products from Tosco's Carson Plant and upgrade/modify them to produce a variety of refinery products including gasoline, jet fuel, and diesel fuel. The refinery produces and/or uses regulated flammables including, propane, butane, hydrogen and mixtures of regulated flammable substances. In addition, the refinery uses both aqueous and anhydrous ammonia, both of which are regulated toxic substances, for pollution control. HAZARD ASSESSMENT RESULTS The worst-case scenario (WCS) associated with toxic substances at the Wilmington Plant is a catastrophic failure in either of two anhydrous ammonia storage vessels located in different units, resulting in releases of ammonia gas over a 10-minute period. While the refinery has safeguards in place to prev ent releases and to mitigate serious consequences should a release occur, no administrative controls or passive mitigations were considered in evaluating this scenario. The maximum distances to the toxic endpoint of 200 ppm (0.14 milligrams per liter) for these WCSs would include offsite impact. Both scenarios are discussed, since the disparate relative source locations within the plant could potentially impact different offsite receptors. The alternative release scenario (ARS) for anhydrous ammonia is a leaking relief valve, resulting in offsite impact in the immediate vicinity of the refinery. The WCS associated with flammable substances at the refinery is a vapor cloud explosion (VCE), resulting from the release of the full inventory of the largest storage tank containing butane. Controls to prevent and/or mitigate such a release were not considered during this evaluation, therefore; the butane is assumed to release, completely vaporize and ignite into a vapor cloud explosion. The maximum distance to the 1-psi endpoint for this WCS would include offsite impact. The ARS for flammable substances is a VCE resulting from a release of butane from a transfer line. The maximum distance to the 1-psi overpressure endpoint for this ARS includes offsite impact in the immediate vicinity of the refinery. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The Tosco Los Angeles Refinery has a comprehensive accidental release prevention program that follows the elements found in the OSHA PSM standard to prevent incidents from occurring. The following is a summary of these elements and a description of the management system that is in place to implement the prevention program. Employee Participation Active employee participation is regarded as essential to the continuous improvement of the LAR PSM program, and hence in the prevention of accidents. LAR has a written employee participation policy that outlines the many ways in which employees are involved in the accident prevention program, and employees have access to all information generated within the program. All process hazard analysis teams include an experienced unit operator, and employees are also members of teams formed for compliance audits, incident investigations and pre-startup safety reviews. The plant emergency response team is comprised of qualified employees who receive specialized training and participate in emergency drills. Employees are expected to report incidents that may occur, as well as any safety concerns they may have. Employee assistance is enlisted to develop training programs and operating procedures and compile other critical process information. Additionally, LAR has various safety programs designed to increase plant safety by encouraging employee involvement. Process Safety Information LAR maintains key technical documents that contain information essential to safe operation of the various processes. This information is accessible to employees to facilitate the i dentification and understanding of hazards posed by chemicals used or produced in the processes and includes chemical hazard, process technology and equipment information. Material Safety Data Sheets (MSDSs) have been compiled for all chemicals used onsite, whether or not they are deemed hazardous. MSDSs include information regarding a chemical's toxicity, corrosivity, thermal and chemical stability, permissible exposure limits, hazardous effects of inadvertent mixing with other materials and other physical data. Operating Information Manuals have been prepared for the various process units. Information available in the manuals includes process flow diagrams, safe operating limits for process parameters, consequences of deviation from design criteria, controls, alarm and shutdown settings and inventory. Equipment design and construction documents on file include information such as process and instrumentation diagrams, construction specifications and materials and electrical classif ications. Process Hazard Analysis LAR conducts a comprehensive program to identify potential hazards that may be associated with processes in the various units and thereby control/properly manage them. The Hazard and Operability (HAZOP) technique is the type of process hazard analysis (PHA) utilized at LAR to ensure that a systematic study of each process is carried out. The HAZOP analysis is recognized by experts as a very comprehensive hazard evaluation technique. The typical HAZOP team includes a knowledgeable operator and engineer who systematically analyze detailed process drawings to identify potential hazards. These potential hazards are assigned a risk rank according to specified criteria. The team evaluates accident prevention and mitigation measures already in place and makes recommendations if they believe additional measures are necessary. Findings of the team are documented and reviewed by management for resolution. Hazards assigned the highest risk rank are given prio rity, thereby ensuring that each hazard receives the appropriate attention. All approved mitigation measures are tracked to completion. Documentation is retained as to the resolution of all PHA findings. Revalidation of PHAs are conducted at least every 5 years, or when a major process change is to be implemented, to ensure that process controls do not significantly deviate from the original design safety features. Again, documented findings are forwarded to management to ensure that critical mitigation recommendations are implemented. Operating Procedures LAR has set forth detailed written procedures with step by step instructions for the various modes of process operations, including startup, normal and temporary operations, emergency operations and shutdown and normal shutdown. These procedures are accessible to employees for reference and training and kept evergreen by revisions implemented through the management of change process, periodic review and annual accuracy certificati on. Training All employees of LAR that are involved in operating a process are trained in the process and its operating procedures. This training emphasizes safety and health hazard issues, emergency operations and safe work practices. Refresher training is provided at least every 3 years to maintain a clear understanding of current operations and any process modifications that may have occurred. Employee comprehension of training is verified, and documentation is maintained. Additionally, operating employees receive required safety training annually. Contractors Contractors are utilized at LAR to supplement employees when increased or specialized activities are conducted. Prior to final contractor selection, the contract employer's safety performance and program are evaluated. LAR provides contractors with a process overview, safety/hazard and safe work practice information and emergency response requirements to ensure appropriate knowledge to safely work at a process unit. In ad dition, the refinery monitors contractor performance and compiles a contract employee injury and illness log to ensure that a good safety record is maintained. Pre-Startup Safety Reviews LAR conducts pre-startup safety reviews (PSSRs) for all new facilities or modifications to facilities that change existing process safety information. These PSSRs ensure that important aspects of a project, such as safety, procedures, personnel and equipment, are prepared and reviewed before equipment is placed in service. Verification of proper equipment construction and prevention program implementation is facilitated by a checklist. Mechanical Integrity Procedures are maintained at LAR to ensure the integrity of process equipment including pressure vessels, storage tanks, piping systems, relief and vent systems/devices, emergency shutdown systems, controls and pumps. Inspection and testing are key components of the mechanical integrity program, with elements and frequency following accepted in dustry good engineering practices and manufacturers' recommendations, augmented by operating experience. All work is documented. Deficiencies that are identified are corrected prior to further use of the equipment or reviewed by a qualified team to determine actions to be taken to ensure safe operations. Quality assurance measures are in place to ensure that new equipment is suitable to the service for which it is intended and is properly installed. Maintenance materials and spare parts are also checked for compatibility with the process and equipment. Employees involved in maintaining process equipment integrity are trained on the process, its hazards and safe work practices and procedures. Safe Work Practices Adherence to safe work practices is deemed imperative at LAR to help ensure that operations and maintenance activities are performed safely. These safe work practices include: 1) a permitting system to authorize and control any hot work (spark-producing) activities, 2) a confi ned space entry permitting system, 3) procedures to safely remove hazardous materials from equipment and piping prior to performing work on or within them, and 4) a lockout/tagout system to confirm that equipment undergoing maintenance is isolated from its energy source. Management of Change All process changes that occur at LAR are managed via a comprehensive management of change (MOC) system. Managed changes include those to process chemicals, technology, equipment, procedures and facilities. Special consideration is given to the technical basis for the change, as well as safety and health impacts, operating procedure modifications, time period for the change and authorization requirements. All changes are reviewed and approved by knowledgeable personnel from various disciplines to ensure that potential new hazards are managed and any controls in place are not adversely affected. Affected employees and contract workers receive training on the change prior to its implementation. In addition, process safety information and operating procedures are revised to reflect any changes. Incident Investigation Should an incident occur that results in or could reasonably have resulted in a release of regulated substances, LAR promptly begins a thorough investigation. A knowledgeable investigation team determines the cause and develops corrective action recommendations to prevent recurrence. Management tracks the resolution of corrective actions. Documentation is retained for a minimum of five years and investigation findings are reviewed with all personnel who could be affected. Compliance Audits Audits to ensure the proper functioning of the accident prevention program are conducted at LAR at least every three years. A knowledgeable audit team carefully reviews facility practices and documents findings for management's review and implementation. Resulting corrective actions are electronically tracked until completion. The two most recent audit reports are kept on file . CHEMICAL-SPECIFIC PREVENTION STEPS The prevention programs summarized above help enable LAR to manage hazards that may be present at the various processes and ensure safe operations. Additionally, LAR is equipped with safety features to assist in: 1) expedient release detection, 2) release containment and control, and 3) release mitigation or consequence reduction. Safety features utilized at LAR include: Release Detection 7 Routine inspections during shifts 7 Hydrocarbon detectors with alarms 7 Hydrogen sulfide (H2S) detectors with alarms 7 Heat sensors, tied to deluge systems, positioned near certain pumps and key storage tanks 7 Flame sensors positioned near heaters Release Containment/Control 7 Process relief valves that discharge to a flare to capture and incinerate episodic releases 7 Carbon filters to remove Volatile Organic Compounds (VOCs) from gas streams 7 Amine systems to remove H2S from fuel gas 7 Valves (manual or automatic) positioned to allow pr ocess isolation 7 Depressurizing valves to arrest reactions 7 Diking/curbing to contain liquid releases 7 Atmospheric relief devices 7 Redundant equipment and instrumentation, such as emergency generators at process units, backup instrument air compressors and diesel-powered firewater pumps and standby batteries for instrument control power Release Mitigation 7 Fire suppression and extinguishing systems 7 Deluge systems positioned near key equipment 7 Fully equipped onsite fire station 7 Trained emergency response personnel, equipped with personal protective equipment 7 Plant-wide emergency alarm system, tested at least weekly FIVE-YEAR ACCIDENT HISTORY The Tosco Los Angeles Refinery Wilmington Plant has an excellent accident prevention record. Over the past 5 years, only one RMP incident has occurred. This incident was an ammonia release that occurred in February 1999. While an immediately adjacent business decided on its own to evacuate as a precaution, there w ere no known health impacts from this release which was a fraction of the amount modeled for release in the ammonia ARS. All incidents of any kind, including near misses, that have occurred have been carefully investigated and critiqued to prevent recurrence. EMERGENCY RESPONSE PROGRAM INFORMATION The Los Angeles Refinery maintains a written emergency response program which is in place to protect worker and public safety as well as the process and 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 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, the public, and post incident cleanup and decontamination procedures. In addition, the refinery has p rocedures that address maintenance, inspection, testing and use of emergency response equipment. Employees receive training in these procedures to perform specific emergency response duties. The emergency response program is updated based on modifications to refinery processes or other refinery facilities. The emergency response program changes are administered through the Management of Change (MOC) program, which includes informing and/or training affected personnel of changes. The overall emergency response program for the Los Angeles Refinery is coordinated with several agencies. This includes local emergency response officials, local government officials, and industry representatives. The refinery has around-the-clock communications capability with appropriate officials including the Fire Department and Law Enforcement. This provides a means of notifying the public of an incident, as well as facilitating appropriate response to an incident. The Los Angeles Refinery conducts periodic emergency drills that involve the local emergency response organizations and provide information to local emergency responders regarding hazards and locations of regulated substances in the refinery. PLANNED CHANGES TO IMPROVE SAFETY Recently, the Los Angeles Refinery reviewed its operations and found that bleach could effectively be used for water treatment, instead of chlorine. In a commitment to worker and public safety, Tosco has now eliminated the storage and use of chlorine at the refinery. A blast-resistant control room is under construction, replacing older control rooms that have less advantageous facility siting aspects. This control room upgrade will include installation of a Distributed Control System (DCS) to improve unit operability and reliability, reducing the potential for releases from unit upsets and shutdowns. An ongoing refinery-wide electrical system upgrade should result in similar benefits to operational safety. Other safety enhancing projects under way at LAR include structural member fireproofing upgrades and deluge systems upgrades. Safety is a priority at LAR. The safety program includes various elements aimed at continuous improvement, such as annual computer-based training for all employees, annual refresher training classes, safety meetings conducted at least monthly and safety bulletins to alert personnel when a safety concern is noted. Continuous improvement is also an operational goal. Recommendations from process hazard analyses, audits, incident investigations and employee input provide opportunities to enhance the safety of the refinery. Seismic reviews of the facility have been conducted to evaluate the need for retrofit structural strengthening to ensure safety during an earthquake. LAR has a comprehensive Y2K contingency plan to ensure safe operations during those dates that may be critical to computerized systems. Remedial action plans are being implemented for identified potential areas of concern. Additional ly, shutdown/startup procedures, loss of utilities issues, emergency response plans and training are being emphasized as priorities. |