Tosco San Francisco Area Refinery at Rodeo - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND RESPONSE PLAN The management and employees of the San Francisco Area Refinery at Rodeo are fully committed to a program of responsible management in all areas including health, environment and safety. In fulfilling this commitment, management will ensure systems are in place to provide the resources and training to identify issues and maintain a safe and healthful environment as indicated by Company standards, accepted safety and environmental practices, and compliance with legislative requirements. We will operate and maintain our plants, facilities and equipment and handle our raw materials and products in a manner to prevent personal injuries/illnesses, losses to Company property, releases to the environment, or impact to the communities in which we operate. DESCRIPTION OF STATIONARY SOURCE AND REGULATED SUBSTANCES The Tosco San Francisco Area Refinery at Rodeo, located in Rodeo, California, processes crude oil into useable petroleum products f or our customers. The refinery produces gasoline, automotive diesel, butane, fuel oil and petroleum coke. In order to produce these products, we store and handle large quantities of regulated flammable materials. In addition, the refinery also uses and stores ammonia above the threshold quantity. To reduce air pollution, the Rodeo Refinery power plant is equipped with Selective Catalytic Reduction devices that convert oxides of nitrogen (NOx) to harmless nitrogen and water. These devices use a solution of ammonia in water (aqueous ammonia), a regulated substance, to perform this conversion. HAZARD ASSESSMENT RESULTS The EPA requires facilities to report on potential worst-case scenarios involving the regulated substances that we handle in amounts exceeding the threshold quantities. The EPA mandates the release conditions for worst-case scenarios. As a result, these scenarios ignore prevention programs that are designed to limit the number and size of chemical releases from our facility. A toxic worst-case scenario describes the potential impacts if the vessel containing the largest quantity of the substance were to be damaged such that it released its entire contents within ten minutes without accounting for response measures that we would take to minimize the impact of such a release. A flammable worst-case scenario describes the potential impacts if the vessel containing the largest quantity of the substance were to suddenly disappear, the contents were to instantaneously vaporize, and a resulting vapor cloud were to ignite and explode. An Alternate Release Scenario (ARS) represents a more likely event. It is used to determine a reasonable outer bound for potential impacts in order to coordinate with local emergency responders. Unlike the worst-case scenarios, our alternate release scenarios are based on actual equipment configurations. In selecting our alternate release scenarios, we considered our practices and procedures for preventing and minimi zing the size of chemical releases. The toxic worst-case scenario for the Rodeo refinery is based on releasing the entire contents of an aqueous ammonia storage tank. This material would spill into the tank's secondary containment dike and then evaporate. The results of the worst-case scenario indicate that releasing the entire contents of one of this tank over a ten-minute period would result in offsite impact. The ammonia toxic endpoint specified by EPA is 200 ppm (parts per million). The alternate release scenario for ammonia is the failure of a loading hose during anhydrous ammonia transfer operations. This scenario assumes the entire contents of the delivery truck would spill and evaporate. The results of the alternate release scenario for ammonia indicate that such a release would have an offsite impact. The flammable worst-case scenario for the Rodeo Refinery is based on releasing the entire contents of our largest butane storage vessel. Butane is the material that is u sed in disposable lighters. Butane is a gas at room temperature and the liquid must be stored under pressure in vessels designed for this purpose. The results of the worst-case scenario indicate that the instantaneous release and subsequent explosion of the entire contents of the vessel would result in offsite impact. The endpoint specified by EPA for this type of release is an overpressure of 1 psi. The alternate release scenario for flammable materials is a flammable vapor cloud formed by a liquefied petroleum gas, or LPG, release. LPG is a mixture of propane and butane, which are the fuels used in home barbecue grills and disposable cigarette lighters. The results of dispersion modeling indicate that this cloud would remain flammable as it crosses a public road that is beyond our fenceline. FIVE-YEAR ACCIDENT HISTORY The five year accident history for Toscos Rodeo Refinery includes information on accidental releases that occurred between June 1, 1994 and June 1, 1999. Tosc o acquired the Rodeo Refinery from Unocal effective April 1, 1997. At the time of acquisition, Unocal was involved in litigation over several accidental releases that occurred during this period. As a result, Toscos access to specific information on releases that occurred at Rodeo prior to April 1, 1997 is limited. The descriptions of these releases represent our best understanding based on the information available. The Rodeo Refinery has experienced two accidental releases since June 1994 that qualify for reporting under the EPA's criteria. The first event occurred on September 15, 1994, prior to Tosco's ownership. This event involved a release of regulated flammables containing small amounts of hydrogen sulfide, which is also a regulated toxic substance. The released cause offsite odors because of the hydrogen sulfide in the vapors. There were reports that some of the children at a nearby school sought medical attention as a result of the release. Investigation of the eve nt revealed that the vapors were vented to the atmosphere through a pressure relief device on a tank following shutdown of a compressor that collects low-pressure vapors from the tank. As a result of this release and numerous reliability problems with the compressor system, the compressor and its associated instrumentation were upgraded in 1996. The second event occurred on April 16, 1997. This incident involved the release of hydrogen sulfide and sulfur dioxide, both regulated toxic materials, from the Sulfur Recovery Unit. As a precaution, local officials asked nearby residents to shelter in place. Investigation of the incident revealed that the event resulted from failure to detect and correct a high-level condition in a process vessel at a processing unit upstream of the Sulfur Recovery Unit. The vessel overflowed and contaminated the feed to the Sulfur Recovery Unit with hydrocarbons. These hydrocarbons interfered with the normal process chemistry. The result was a release of sulfur dioxide and some hydrogen sulfide from the combustor stack. As a result of the investigation, operators received refresher training on the Sulfur Recovery Unit process chemistry and early detection of upset conditions. Also, instrumentation at the vessel that overflowed was modified to provide earlier detection of a high-level condition. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following summaries represent numerous prevention programs and practices at the Rodeo Refinery. Rodeo Refinery employees are committed to operating a safe facility through the establishment, review, and continuous improvement of these programs and practices. EMPLOYEE PARTICIPATION The Rodeo Refinery encourages employees to participate in all aspects of process safety management and accident prevention. Examples of employee participation include safety committee involvement, developing and reviewing safe operating procedures, and participation in the process hazard analysis pro gram. Information on the refinery's prevention programs is available to employees, and they are encouraged to recommend improvements to any of the programs. In addition, refinery management has a strong commitment to developing and enforcing written policies and procedures and encourages employee input to identify when a policy or procedure needs to be changed or improved to cover new tasks, revised regulations, or employee experience. PROCESS SAFETY INFORMATION The Rodeo Refinery maintains an extensive library of Process Safety Information. This library includes information related to chemicals in the process, the technology of the process, and the equipment in the process. These documents include detailed information on chemical properties and their associated hazards, limits for key process parameters, and equipment design and configuration. This information is available to all employees. Chemical specific information, including hazards, protective measures, symptoms, and first aid procedures is provided via Material Safety Data Sheets. This information is available in hard copy format and via the refinery computer network. The limits for key process parameters (e.g. temperature, pressure, flow, and level) are documented in the unit operating manuals. The process is maintained within these limits using computer process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g. automated shutdown systems). Information on the design and construction of process equipment 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 the basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that protective features in the process are not compromised. PROCESS HAZARD ANALYSIS The Rodeo Refi nery has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Each process is systematically examined using a technique known as process hazard analysis, or PHA. A team of experienced operators, engineers, and other specialists conducts the analyses. This team systematically identifies and evaluates hazards of the process as well as existing accident prevention and mitigation measures and makes suggestions for additional prevention and/or mitigation measures when they believe such measures are necessary. The PHA teams recommendations are then reviewed with management personnel for resolution. Implementation of actions 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 the highest priority. Actions implemented in response to PHA team findings are tracked until they are completed. T he final resolution of each finding is documented and retained. The process hazard analysis for each process unit is updated and re-validated at least every five years. The results and findings of these updates are documented and retained. Once again, any team findings are reviewed with management personnel for resolution and any actions that result are tracked until they are completed. OPERATING PROCEDURES The Rodeo Refinery utilizes written procedures that address various phases of process operations including (1) initial startup of a newly constructed process, (2) unit startup, (3) normal operations, (4) temporary operations, (5) normal shutdown, and (6) emergency shutdown. These procedures provide the basis for consistent initial or refresher training of operators. The procedures are managed by operating personnel and are updated as necessary to reflect changes and new information. Operating procedures are reviewed annually to verify that they are current, updated, and ac curate. Operating procedures and operating manuals are available in hard copy format in each process unit control room. OPERATOR TRAINING To complement the written operating procedures, the Rodeo Refinery has a comprehensive training program for employees involved in operating a process. New employees must successfully complete up to 4 weeks of basic training on refinery operations before receiving their unit-specific training. Basic training addresses applied sciences, job fundamentals, operating skills, and understanding basic refining processes. The time necessary to successfully complete unit-specific training varies with the requirements of each job and the candidate's previous job experience. It typically takes 8-24 weeks to qualify for a specific operating post. Throughout the training process, candidates must continue to qualify by passing written and oral tests, thereby demonstrating understanding and retention of the training materials. Qualification for all operati ng posts within a process area can take up to 3 years. Refresher training on operating procedures is provided to operating employees at least every three years, and refresher safety training is performed annually. In addition, training emphasizing specific topics is performed as necessary (for example, furnace operation, dock operations, etc.). Prior to the commissioning of new or modified equipment, written operating procedures are developed and training is provided to affected operating personnel. Operating personnel also receive training in emergency response and fire fighting procedures. MECHANICAL INTEGRITY/MAINTENANCE TRAINING The first step in a successful mechanical integrity program is ensuring that equipment and processes are properly designed for their intended use. The Rodeo Refinery utilizes specific written procedures and design criteria for its operating equipment. These criteria are contained in Engineering Standards -- referenced to recognized industry standa rds (such as API, ASME, ANSI, and NFPA) -- or specified by engineering firms with expertise in a specific area of design. The Rodeo Refinery has well-established practices and procedures to maintain pressure vessels, storage tanks, piping systems, relief and vent systems, instrumentation and emergency shutdown systems, pumps, and compressors in proper operating condition. The basic elements of this program include: (1) appropriate training or equivalent work experience for those responsible for procuring, installing, maintaining, inspecting, and repairing process equipment, (2) developing maintenance and testing procedures, (3) performing appropriate inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. These activities involve many specialists, including Mechanical Engineers, Metallurgical Engineers, Pressure Vessel and Welding Inspectors, and our maintenance mechanics (for example, Machinists, Electricians, Instrument Techn icians, and Welders). Qualifications of these employees depend on the needed type and level of expertise. The qualifications include either a four-year degree at an accredited college or equivalent work experience, certification by the governing board in their specialty, or journeyman level skills. In addition to their specialized education and training, employees and contractors working in the area of mechanical integrity receive summary training on process hazards, safety and health hazards, applicable maintenance procedures, and safe work practices. Predictive maintenance inspections and tests are performed on equipment to help ensure that it functions as intended and to verify that equipment is within acceptable limits (for example, adequate wall thickness for pressure vessels). If a deficiency is identified, necessary actions are taken to address the deficiency, up to and including shutting down and removing the equipment from service for repair or replacement. Another int egral part of the mechanical integrity program is quality assurance. The Rodeo 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 Rodeo 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, and exit of support personnel, (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), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space is permitted. CONTRACTORS The Rodeo Refinery utilizes contractors to supplement its maintenance workforce and provide additional expertise and resources for specialty tasks or peak work periods (maintenance turnarounds for example). Because some contractors work on or near process equipment, the refinery has procedures in place to ensure that contractors (1) perform the work in a safe manner, (2) have the appropriate knowledge and skills for the tasks they are to perform, (3) are aware of the hazards of the workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow the site safety rules, (6) inform refinery personnel of any hazards that their activities may introduce into the plant, and (7) know what to do if they encounter a hazardous condition in the course of their work. The qualification process for new contractors includes a review of the contractor's safety performance and references from other companies that have used the contractor. Additionally, Tosco personnel perform an audit of t he contractor's written safety programs. This audit is performed by a team consisting of Tosco and contractor employees (usually the Safety Manager and/or Field Safety Supervisor) using a standard checklist developed by Tosco. Any deficiencies in the contractor's safety programs must be corrected to Tosco's satisfaction before a contractor is qualified to bid on work at the refinery. Tosco requires that contractor employees complete overview training before being allowed access to our facilities. These requirements include completion of (1) an 8 hour course on general industrial safety that is given by the Bay Area Training Corporation, and (2) refinery orientation that covers general safety rules, the refinery emergency action plan, the use of the process summary information that Tosco has prepared for each refinery process unit, and training in refinery safe work practices. Contractors who will work in a lead capacity on energized or pressure containing equipment must also pass a written skill test that is specific to refinery work. Tosco periodically audits contractor performance to verify compliance with our requirements. Deficiencies noted during an audit must be corrected either immediately or within five working days, depending on how severe the deficiency is. Tosco also periodically conducts update audits of the contractor's written safety program. MANAGEMENT OF CHANGE The Rodeo Refinery has a program to manage changes to unit operations. This system requires that changes to items such as process equipment, chemicals and feedstocks, technology, procedures, and other facility changes are authorized and properly reviewed before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage and control any new hazards, and (2) verify that existing safeguards are not compromised by the change. This review process is documented utilizing the Management of Change Form. Affected chemical hazard information, proces s operating limits, equipment information, and operating procedures are updated to reflect a change. In addition, operating and maintenance personnel are provided any necessary training on the change prior to its start-up. PRE-STARTUP SAFETY REVIEW The Rodeo Refinery conducts pre-startup safety reviews for a new facility or facility modification to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. These reviews provides an additional check to make sure that construction is in accordance with the design specifications and that supporting systems are operationally ready. A pre-startup safety review involves field verification of the construction and serves a quality assurance function by requiring verification that applicable prevention program requirements are properly implemented. INCIDENT INVESTIGATION The Rodeo Refinery maintains a detailed written incident investigation pr ocedure. This procedure ensures that events that resulted in, or could reasonably have resulted in a fire or explosion, toxic gas release, major property damage, environmental loss, or personal injury are promptly investigated. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the event or a similar event. Investigation findings and recommendations are documented and reviewed with management for resolution. The final resolution of each finding or recommendation is documented and reviewed with workers who could be affected by the findings. Any actions resulting from investigations are tracked until they are resolved. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future process hazard analyses. COMPLIANCE AUDITS To help ensure that the Process Safety Management and accidental release prevention programs are functioning properly, the Rodeo Refinery perio dically conducts audits to verify that the procedures and practices required by the programs are being implemented as intended. Compliance audits are conducted at least every three years. Management and field personnel participate in the audits in order to verify that practices correspond with written procedures. The audit team may include employee(s) from other sites and third parties. The audit team develops findings that are presented to refinery and area management for resolution. Corrective actions taken in response to audit team findings are tracked until they are complete. The final resolution of each finding or action is documented, and the two most recent audit reports are retained. CHEMICAL SPECIFIC PREVENTION STEPS In addition to the prevention program activities, the Rodeo Refinery has safety features installed in process units to help (1) contain or control a release, (2) quickly detect a release, and (3) reduce the consequences of, or mitigate, a release. The fol lowing types of devices are used in various processes throughout the refinery to help prevent incidents: relief valves, rupture disks, check valves, excess flow valves, remotely operated valves, flare systems, automatic interlocks and shutdown systems, hydrocarbon detectors, manual block valves, process alarms (level, temperature, flow, pressure), and computer-aided control systems. Additionally, the following types of features are used in various processes throughout the refinery to help mitigate (reduce the effects of) incidents: sprinkler systems, deluge systems, dikes or containment berms, fixed firewater monitors, and fire fighting foam delivery systems. EMERGENCY RESPONSE The Rodeo Refinery maintains a written emergency response plan to protect its workers, the public, and the environment. The program includes procedures for responding to the release of regulated substances, including the possibility of a fire or explosion. The procedures address various aspects of emergen cy response including notification of local emergency response organizations, proper first-aid and medical treatment for exposures, evacuation and shelter-in-place plans, accounting for personnel after an evacuation, notifications to regulatory agencies, and post incident cleanup and decontamination. The Rodeo Refinery utilizes the Incident Command System in cooperation with local emergency response personnel. The refinery also has procedures that address the maintenance, inspection, and testing of emergency response equipment, as well as instructions and training that addresses the use of the equipment. Employees receive training in these procedures as necessary to perform their emergency response duties. The emergency response program is updated as necessary to reflect changes in refinery processes and suggested improvement. Training on changes to the plan is given to affected employees. The Rodeo Refinery maintains a qualified fire brigade, an oil spill response team, a haza rdous materials team, and a rescue team. Additionally, several refinery employees are certified emergency medical technicians. Frequent training and participation in emergency response drills ensures the readiness of the response organization. The emergency response program for the Rodeo Refinery is coordinated with Contra Costa Health Services, the Rodeo-Hercules Fire Protection District, the Crockett Carquinez Fire Protection District, and the Contra Costa County Office of Emergency Services. This coordination includes periodic meetings with local emergency response officials and industry representatives. The Rodeo Refinery has around-the-clock communications capability with appropriate emergency responders. This provides a means of notifying the public of an incident and facilitating a quick response. PLANNED CHANGES TO IMPROVE SAFETY Continuous Improvement: The Rodeo Refinery continuously seeks and evaluates methods to improve the safety of its operations. Recommendations from audits, incident investigations, process hazard analyses, or employee suggestions provide opportunities to enhance the safety of the refinery. Improvements in technology provide another opportunity to enhance facility safety. For example, the refinery discontinued use of gaseous chlorine several years ago when less hazardous substitutes became viable. Additionally, the refinery is phasing out the use of small quantities of anhydrous ammonia by substituting aqueous ammonia, an inherently safer chemical. Year 2000 (Y2K) Preparedness: Tosco Corporation and the Rodeo Refinery have developed Y2K Task Forces to investigate, develop, and implement plans to minimize any disruption that might occur because of Y2K. Computer software and hardware systems are being reviewed for Y2K compliance, and contingency pre-plans are being developed to address any potential in-plant or supplied utility failures. |