BP Amoco Alliance Refinery - Executive Summary
BP Amoco Alliance Refinery |
Risk Management Plan
The BP Amoco Alliance Refinery is located south of Belle Chasse, Louisiana. Alliance is a petroleum refinery which processes raw crude oil into many important products including propane, diesel fuel, gasolines, jet fuel, and other intermediate refinery products.
As a company, the goals of BP Amoco are simply stated - no accidents, no harm to people, and no damage to the environment.
To achieve these goals, BP Amoco Alliance Refinery employs approximately 600 employees and contractors to run and maintain the refinery in optimum condition. Alliance Refinery started operations in 1971 and remains one of the country's most efficient and modern refineries.
In 1996, the Environmental Protection Agency (EPA) implemented a new regulation called the Risk Management Program, or RMP, for facilities that handle certain amounts of toxic and flammable chemicals. As part of this new policy, facilities must provide informati
on to the EPA about these chemicals, the potential risk they pose to the community, and the many ways companies like BP Amoco manage those risks.
Alliance Refinery processes crude oil, which inherently requires the use and production of flammable chemicals in quantities large enough to be regulated by RMP. In addition, the refinery uses two toxic chemicals in large enough quantities to be regulated by RMP. These two chemicals are hydrogen fluoride (HF), which is used in the alkylation process, and chlorine (Cl2), which is used for water treatment.
Below is a discussion of BP Amoco Alliance Refinery's Risk Management Program followed by a discussion of the many systems that we have in place to prevent incidents from occurring. The RMP includes:
1.0 Hazard Assessment
2.0 Accidental Release Prevention Program
3.0 Emergency Response Program
Sections 4.0 and 5.0 discuss BP Amoco Alliance Refinery's accident release prevention and response policies, and future safety and environme
ntal improvements, respectively.
1.0 Hazard Assessment
One of the most significant requirements of the RMP rule is the requirement of a hazard assessment. This assessment provides the refinery and the public information regarding the types and extent of the hazards at the facility. The hazard assessment consists of two exercises: an offsite consequence analysis and a five-year accident history.
1.1 Offsite Consequence Analysis
For the offsite consequence analysis, companies must report worse case scenarios (WCS) for each class of regulated substances -- flammable and toxic. Alternative release scenarios (ARS) are required for flammable chemicals as a class and for each RMP toxic chemical above the threshold quantity at the facility.
Worst Case Scenarios (WCS)
A worst case scenario (WCS) is defined as the rapid and complete release of a RMP chemical that results in the greatest potential impact distance under worst case weather conditions (e.g., temperature, windspeed). It is
also assumed that none of the site's safety systems are operational.
BP Amoco Alliance Refinery's WCS for flammables is based on the failure of a butane storage sphere, under the worst possible weather conditions, with no safety controls considered. The scenario assumes that the release results in a vapor cloud explosion. It is extremely unlikely that a release would occur, that all safety features would fail, and that the worst case weather conditions would prevail all at once. BP Amoco Alliance Refinery has systems in place to prevent and respond to incidents in the butane storage sphere area, such as pressure relief devices, level indicators and routine inspections.
BP Amoco Alliance Refinery's WCS for toxics is based on the failure of the hydrogen fluoride (HF) acid settler. Using EPA's guidelines, the failure would result in a release of the entire contents of the HF vessel in ten minutes. Again, no safety controls are considered in this scenario which in
cludes the worst case weather conditions. The chance of this type of event occurring is extremely remote. BP Amoco Alliance Refinery has many systems in the HF area to prevent and respond to incidents including HF detectors, a containment dike, and a water spray system that can be used in the event of a release.
Alternative Release Scenarios (ARS)
EPA requires companies to also report alternative release scenarios (ARS) that are based on more realistic data. The ARS' represent potential incidents that could occur at the refinery, and they take into account the many controls that we have in place - we can count on our important safety systems that help us prevent incidents and respond to emergencies.
The EPA guidelines require us to provide ARS' for all RMP chemicals that exceed their threshold quantities. The flammable RMP chemical at BP Amoco Alliance Refinery is butane and the toxic RMP chemicals are hydrogen fluoride (HF) and chlorine (Cl2).
BP Amoco Alliance Re
finery's ARS for flammables is based on the failure of an eight inch pipe on a butane sphere, in which butane is released over a ten minute period, under typical weather conditions. The butane would be released in both liquid and vapor form. The scenario assumes that the liquid butane released forms a pool which ignites and burns. As mentioned previously, BP Amoco Alliance Refinery has systems in place to prevent and respond to incidents in the butane storage sphere area, such as pressure relief devices, level indicators and routine inspections.
BP Amoco Alliance Refinery's ARS for HF is based on the failure of a truck unloading hose, in which HF would be released for approximately ten minutes under typical weather conditions. Water spray mitigation has been considered. BP Amoco Alliance Refinery has many systems in the HF area to prevent and respond to incidents including HF detectors, a containment dike, and a water spray system that can be used in the event of a release.
BP Amoco Alliance Refinery's ARS for Cl2 is based on the failure of a 3/4 inch line, in which Cl2 would be released for approximately ten minutes under typical weather conditions. BP Amoco Alliance Refinery inspects cylinders before placing them on-line. Chlorine patch kits are kept on-site and available for use if a leak in a cylinder would occur.
1.2 Five Year Accident History
We are proud to report that the BP Amoco Alliance Refinery has not had a release of an RMP toxic or flammable compound that meets the requirement of the RMP rule in the last five years. However, we believe it is important to learn from all incidents; therefore, we have an incident investigation program in place to review any incidents that might occur at the refinery and to prevent such incidents from happening in the future.
The information above regarding BP Amoco Alliance Refinery RMP WCS' may cause concern but it is important to take into consideration that the EPA WCS guidance is overly conservative
; therefore, it is highly unlikely that a WCS event would occur. The following sections describe BP Amoco's commitment to people and the environment and the many programs that we have in place to prevent major incidents from occurring at our refinery.
2.0 Accidental Release Prevention Program Steps
It is believed that if a refinery has a successful process safety management system in place, most incidents can be avoided. The Occupational Safety Health Administration (OSHA) has promulgated a regulation that provides guidance to industry for developing and maintaining a Process Safety Management (PSM) program. BP Amoco Alliance Refinery initiated its PSM program in the early 1990's. The RMP general accident prevention program is based on the OSHA PSM standard; therefore we have provided a summary of the refinery's PSM elements below.
* Employee Participation - All employees are encouraged to actively participate in the prevention programs at Alliance Refinery.
* Process Safety Information - At Alliance Refinery, we keep detailed information about our processes, chemicals, and equipment. This allows us to operate and maintain the refinery safely.
* Process Hazard Analysis (PHA) - PHA's are studies that refinery teams perform to make sure equipment is designed, built, and operated within safe limits.
* Operating Procedures - Alliance Refinery has written procedures that address different modes of operation at the refinery. These procedures serve as a reference for experienced personnel and a training tool for new employees. The procedures are certified annually.
* Training - The refinery has an extensive training program that addresses both training for new employees and refresher training for all operators. Employees are not allowed to work independently until they have demonstrated adequate knowledge in a process, and records are kept on each employee's progress.
* Contractors - Contract workers at the refinery are expected to follow th
e same safety procedures as BP Amoco employees. Alliance Refinery evaluates contractor safety performance when selecting a contractor and monitors contractors to ensure that they are working safely.
* Pre-Startup Safety Reviews (PSSRs) - Alliance Refinery performs PSSR's when there is an addition or change at the refinery. This ensures that the change is compatible with the unit design. This provides a safety check prior to startup of equipment.
* Mechanical Integrity - The mechanical integrity program at Alliance Refinery ensures that existing equipment is in working order and that new equipment is suitable for its intended use.
* Safe Work Practices - Alliance Refinery has many safe work practices in place to ensure safety. These include plant security, hot work and confined space procedures, and procedures to secure equipment before maintenance is performed. The safe practice procedures are reviewed annually to ensure that procedures are current and necessary changes are made
to reflect changes in the process, chemicals, technology, equipment and/or to meet regulatory compliance.
* Management of Change (MOC) - The MOC system at Alliance Refinery ensures that any changes to equipment are consistent with existing equipment and procedures.
* Incident Investigation - Alliance Refinery investigates all incidents and near misses at the refinery. This provides a mechanism to learn from our accidents and improve safety.
* Compliance Audits - Every three years, Alliance Refinery conducts an audit to make sure that all of the safety programs are in place and functioning properly. In addition to audits, we conduct in-house inspections that are a part of a monthly Health & Safety Compliance Evaluation Program.
In addition to the General Accidental Release Prevention Program elements, Alliance has safety features on the refinery's process units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of, or mitigate a relea
se. The following types of safety features are used in various processes:
( Release Detection
Hydrocarbon detectors with alarms
Toxic gas detectors with alarms
( Release Containment/Control
Process relief valves that discharge to a flare system to capture and incinerate episodic releases
Scrubbers to neutralize chemical releases
Valves to permit isolation of the process (manual or automated)
Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
Vessels to permit partial removal of the process inventory in the event of a release (e.g., dump
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 systems for specific equipment
Trained emergency response personnel
Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)
3.0 Emergency Response Program
The BP Amoco Alliance Refinery has its own emergency response team that covers fire response, hazardous materials response, and first aid response on a 24-hour basis. The emergency response team trains regularly to maintain their readiness and preparedness to tackle any incident involving flammable or toxic chemicals handled by the refinery, and other occupational incidents.
The BP Amoco Alliance 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 rel
eased. The procedures address all aspects of emergency response, including 1) proper first-aid and medical treatment for exposures, 2) evacuation plans and accounting for personnel after an evacuation, 3) notification of local emergency response and the public if a release occurs, and 4) post-incident cleanup and decontamination requirements.
In addition, the BP Amoco Alliance 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 emergency response program changes are administered through the Management of Change process, which includes informing and/or training affected personnel in the changes.
e overall emergency response program for the BP Amoco Alliance Refinery is coordinated with the Belle Chasse Fire Department and Plaquemines Parish Local Emergency Planning Committee (LEPC). This coordination includes close liaison with refinery emergency response teams and periodic meetings between local emergency response officials, local government officials, and industry representatives. The BP Amoco Alliance Refinery has 24-hour communications capability with appropriate officials and emergency response agencies. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. BP Amoco Alliance Refinery conducts periodic emergency drills that involve the LEPC, emergency response agencies, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.
4.0 Accidental Release Prevention and Response Policies
Alliance Refinery main
tains the high level of commitment to Health, Safety and the Environment that has been set forth by the CEO of the company, Sir John Brown. Every BP Amoco employee is responsible for operating within strict Health, Safety and Environmental (HSE) guidelines. As a company, we will continue to drive down the environmental and health impact of our operation by reducing waste, emission and discharges, and using energy more efficiently. We will produce quality products that can be used safely by our customers.
BP Amoco's commitment to safety of people and the environment has been shown through the many awards we have received and the milestones that we have achieved. Alliance Refinery has received numerous awards from national organizations such as the American Petroleum Institute (API) and the National Petroleum Refiners Association (NPRA), most recently winning the NPRA's Gold Award for a 47% improvement in OSHA Recordables over a three year period. The Alliance
Refinery employees received the Award of Honor from the New Orleans Metropolitan Safety Council in May, 1999, for creating one of the safest, local work environments in a nine parish area.
As part of BP Amoco's environmental policy, we are committed to the protection and respect of the environment in which the refinery operates. We operate in such a manner as to minimize the refinery's impact on the environment while competitively producing quality petroleum products. Evidence of our commitment is in the many environmental programs we have in place at the refinery and the initiatives that we have taken to make the Alliance Refinery an efficiently run and environmentally friendly refinery.
Environmental emissions from the refinery have declined significantly throughout the last decade due to BP Amoco's strong commitment to the environment and with improved technology that is now available. Since 1992, the BP Amoco Alliance Refinery has reduced emissions
95%. It is BP Amoco's goal to identify all areas within the refinery where appropriate feasible technology can be applied to minimize environmental releases even further in the future. Evidence of this is that for the third consecutive year, the BP Amoco Alliance Refinery has earned a special citation from the Governor's Environmental Leadership Awards program for its work to prevent pollution. BP Amoco's commitment is further demonstrated by the investment of approximately $200 million since 1988 to complete a series of environmental projects to not only comply with new environmental regulations but also to improve environmental performance.
In addition, in December of 1998, Alliance Refinery received a coveted international certification, marking the first time a U.S. oil refinery has ever earned the "ISO-14001" title. ISO-14001 is a set of rigorous environmental standards developed by the International Standards Organization (ISO). The ISO-14001 standard provides a guide fo
r companies in measuring the thoroughness and effectiveness of their environmental management system.
5.0 Future Safety and Environmental Improvements
Everybody who works for BP, anywhere, is responsible for getting Health, Safety and Environmental (HSE) performance right. Good HSE performance is critical to the success of our business and is strongly promoted by the company's top executives worldwide.
Our goals are simply stated - no accidents, no harm to people, and no damage to the environment.
We will continue to drive down the environmental and health impact of our operations by reducing waste, emissions and discharges, and using energy efficiently.
Wherever we have control or influence we will:
( Consult, listen and respond openly to our customers, neighbors, and public interest groups
( Work with others - our partners, suppliers, competitors and regulators - to raise the standards of our
( Openly report our performance -- good an
( Recognize those who contribute to improved HSE performance
Our business plans include measurable HSE targets. We are all committed to meeting them.