Bakersfield Refining Co. - Area 3 - Executive Summary |
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11 Risk Management Plan Equilon Enterprises LLC Bakersfield Refining Company - Area 3 Executive Summary This is the Risk Management Plan (RMP) for Area 3 of Equilon Enterprises LLC, Bakersfield Refining Company (BRC). The RMP is required under the U.S. Environmental Protection Agency (EPA) Risk Management Program codified in 40 Code of Federal Regulations, Part 68 (40 CFR 68). Delayed coking operations are conducted in Area 3. Refining operations are primarily conducted in Areas 1 and 2, which are on contiguous properties and not adjacent to Area 3. A separate RMP submittal has been prepared for Areas 1 and 2. The purpose of the RMP program is to identify and prevent potential accidental releases of specific "regulated substances" that have the potential to cause harm to the public and the e nvironment. "Regulated substances" are hazardous chemicals identified by EPA. Because BRC has quantities of various "regulated substances" above a threshold amount, this RMP has been prepared. The remainder of the Executive Summary is organized as follows: Section 1: Accidental Release Prevention and Emergency Response Policies at BRC Section 2: Overview of Regulated Substances at BRC Section 3: Worst Case Release Scenarios and Alternative Release Scenarios Section 4: BRC Accidental Release Prevention Program Section 5: Five-Year Accidental Release Summary Section 6: Emergency Response Program Section 1. Accidental Release Prevention and Emergency Response Policies at BRC Equipment at the various BRC units must be designed, operated, and maintained in full compliance with applicable internal engineering standards, accepted industry codes, or industry standards. Syst ems and procedures are in place to control changes in process technology, facilities, and operating and maintenance procedures in order to provide for continued safe and reliable operations. All employees at BRC have the responsibility to protect the environment and to ensure the safety and security of his/her fellow workers. Written policies and standards are in place at BRC to ensure: z The safety and health of employees and other workers at the site; z Protection of the environment; z Reliable and efficient operation of the facilities; z Minimization of the risk of product or property losses; and z Maintaining a positive relationship with the communities adjacent to our facility. These written policies and standards are discussed further elsewhere in this submittal. Section 2. Overview of Regulated Substances at BRC Table 1 lists the covered BRC process units that are subject to the f ederal Risk Management Program, defines the appropriate RMP program level, and identifies the regulated substances handled in these units. Table 1 Summary of Covered Process Units - BRC Area 3 Unit Federal Regulated Regulated RMP Toxic Flammable Program Level Delayed Coker Unit (Units 30 Level 3 Ammonia Hydrogen and 34) Processes vacuum (anhydrous Ethylene residuum, or the fraction of ) 1-Butene the crude oil that did not Propylene vaporize in the Crude or Vacuum Isopentane Units. The vacuum residuum is Pentane heated and then thermally Isobutane cracked in the Coke Drum. The Butane vapors are discharged to a Propane fractionator and separated into Ethane specific petroleum liquids, and Methane the coke that remains in the Coke Drum is hydraulically removed, classified by size, de- watered, and then transported offsite to buyers for use as fuel. Amine Treating Unit (Units 35 Level 3 None Ethylene and 36) Consists of a closed Propylene circulation system in which an 1-Butene amine solution removes hydrogen Isopentane sulfide (H2S) from sour liquid Pentane and gas streams. Isobutane Butane Propane Ethane Methane Area 3 Tank Farm (Unit 72) Level 3 None Ethane Storage, interplant transfer, Methane blending, dewatering, chemical treatment, pipeline receiving and shipping, rail receiving and shipping, and truck loading / unloading of crude oils, intermediate products, additives, chemicals, and finished products. Section 3. Worst Case Release Scenarios and Alternative Release Scenarios Offsite consequence analyses are essential in identifying potential hazards of accidental releases. The results of the analyses are used to assist the Kern County Environmental Health Services Department and Fire Department in its emergency response planning. 3.1 Worst-Case Scenarios BRC conducted offsite consequence analyses for the worst-case scenarios (WCS) using the Environmental Protection Agency's (EPA) RMP Offsite Consequence Analysis Guidelines (OCAG). This methodology was used because the RMP rule set forth specific criteria t hat must be followed for modeling the worst-case scenarios. The worst case scenarios must incorporate very conservative, simplified assumptions about the nature of the releases and the resulting emission rates into the air. The EPA has defined the worst-case release scenario as one that results in the greatest distance from the point of release to a specified "endpoint". As defined by the rule, the endpoint for toxics substances is a specified concentration, and for flammables is a specified overpressure from a vapor cloud explosion (VCE). The worst-case scenario for a regulated toxic is one where the total quantity in the largest vessel or pipe is released over 10 minutes, resulting in acute health effects associated with airborne exposure. For a regulated flammable, the worst-case scenario is one where the total quantity of regulated flammable in the largest vessel or pipe is assumed to vaporize and instantaneou sly result in a vapor cloud explosion. A summary of the worst-case scenarios for BRC Area 3 is provided in Table 2. As required by the RMP rule, the results are shown for one scenario for a vessel containing a toxic substance (ammonia). For flammables, however, it is necessary to present scenarios for two vessels because, in this case, the two releases impacted different offsite areas. Table 2 Worst-Case Scenario Results - BRC Area 3 Chemical Area / UnitTank/Vess Amount (pounds) Radial Endpoint el Distan ce (miles ) Ammonia, Area 3 0.14 mg/l Anhydrou Utilities 85-Y30-T 43,566 2.3 (ERPG-2)a s (10-min release) (toxic gas) P ropylen Unit 35 1 psi VCE e (Delayed 35-V406 17,356 0.21 overpress (flammab Coker Unit) (instantaneous ure le release) mixture) Methane Unit 72 1 psi VCE (flammab (Tank Farm) 900A 3,397 0.12 overpress le (instantaneous ure mixture) release) aERPG-2: The maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair an individual's ability to take protective action. 3.2 Alternative Release Scenarios In addition to worst case scenarios, this RMP contains a second set of release scenarios designated as alternative release scenarios (ARS). These scenarios are more realistic t han worst- case scenarios for assessing the potential hazards posed by BRC process units and developing emergency response plans. Although these scenarios may be unlikely to occur, they are physically possible and reasonably feasible. EPA OCAG procedures were not used for modeling the alternative release scenarios. More flexibility is provided for in characterizing releases and assessing the impacts for the alternative release scenarios. BRC used the "PHAST Professional" model by DNV Technica for the ARS. PHASTProfessional is an advanced consequence modeling program that examines the progress of a potential incident from initial release, through the formation of a cloud and/or liquid pool, and on to final dispersion and flammable/toxic effects. A summary of the alternative release scenarios for BRC Area 3 is provided in Table 3. There is one scenario for each toxic substance and one for flammables. The ammonia releas e and the flammable release were assumed to be stopped after 60 minutes, though a longer duration would not change the results presented. Table 3 Alternative Release Scenario Results- BRC Area 3 Chemical Area / Tank/Vessel Amount Radial Endpoint Unit (pounds) Distan ce (miles ) Ammonia, Area 2 85-Y30-T 43,566 0.14 Anhydrou Utilitie (1" Diam. (29-min 0.43 mg/l s s Hole) release) (ERPG-2) (toxic gas) Propylen Unit 35 35-V406 17,356 1 psi e (2" Diam. (11-min 0.09 VCE (flammab Hole) release) overpres le sure gas) 0.034 LFLa aLower flammability limit Section 4. BRC Accidental Release Prevention Program This section describes the general accident prevention programs in place at BRC. This program is required for all level 3 covered process units described in Section 2, Table 1, and is applied throughout the facility. Employees are responsible for implementing the prevention elements for his/her department as follows: Responsible Prevention Element Department Process Safety Process Safety Management Group Information Process Hazards Analyses Compliance Audits Employee Participation Contractor Orientation Management of Change Incident Investigation Safety Group Hot Work Procedure Contractors Emergency Response Training Department Operating Procedures Employee Training Operations Management of Change Department Pre-Startup Safety Reviews Incident Investigation Production Services Mechanical Integrity Department Asset Manager Incident Investigation All records associated with the prevention elements and the Risk Management Program are retained for a minimum of five years. 4.1 Process Safety Information BRC maintains a variety of technical documents that are used to help ensure safe operations of the process units. Process Safety Information (PSI), which addresses chemical properties and associated hazards, limits for key process parameters, limits for specific chemical inventories, and equipment design inform ation, was compiled for each process unit. PSI is used in process unit hazard analyses, inspection, maintenance, and training activities. This information is kept current by management of change and pre-startup safety review procedures, which are discussed further in this section. 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. 4.2 Process Hazards Analysis BRC conducted process hazards analyses (PHAs) to ensure that hazards associated with process units are identified and controlled. Under this program, each process is systematically examined by a multi-disciplinary team to identify hazards that could result in an accidental release of a regulated substance and to ensure that adequate control is in place to manage those hazards. BRC has used the hazard and operability study methodology as the refinery's primary process hazards analysis technique. Some of the revalidation has been done using the "what if" and risk matrix methodologies. Pertinent parameters, such as flow, temperature, pressure, and liquid level, were reviewed. To help ensure that the process controls or process hazards do not deviate significantly from the original design safety features, BRC updates and revalidates the hazard analyses every five years. As part of the technical studies, BRC conducted a seismic review of the refinery. The refinery is located in an area that is prone to earthquakes. A walk through was conducted in 1996 by a qualified engineering company (EQE). The objective of seismic assessments was to provide reasonable assurance that a release of regulated substance having off-site consequence would not occur as a result of a major ear thquake. The results and findings from the seismic review are documented and retained in the computerized tracking system. 4.3 Operating Procedures BRC has developed and implemented written operating procedures that provide clear instructions for safely conducting activities involved in each process. The written operating procedures address the various modes of process operations, such as unit startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and initial startup of a new process. These procedures are used as references by experienced operators and for consistent training of new operators. The procedures are maintained current and accurate by revising them to reflect changes made through the management of change process and through annual certification. 4.4 Training BRC's general policy requires operating personnel to be trained in the safe operation of facilities, handling process upsets, emer gency response, and personal safety. Employees who understand the process and how to safely operate a process can significantly decrease the number and severity of incidents. Refresher training for all operations and maintenance employees in Safety, Health, and Environmental subjects and operating procedures (as appropriate) is provided at varying intervals, depending upon requirements. 4.5 Management of Change A Management of Change (MOC) review is required for modifications to facilities or changes to process unit operating conditions. The procedure does not apply to "replacement in kind" which is defined as replacements that satisfy the design specifications. The MOC process is intended to assess the impact of proposed changes on process safety, the environment, operability, reliability, and product quality in process units. The requirements for Management of Change are documented in a written procedure. Management of C hange information is kept for the life of the process unit. 4.6 Pre-Startup Safety Reviews The purpose of the Pre-Startup Safety Review is to ensure safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides additional assurance that construction is in accordance with the design specifications and that all systems are operationally ready. The Pre-Startup Safety Review also verifies that accident prevention program requirements are properly implemented. Pre-startup reviews are goverened by a written Pre-Startup Safety review procedure and covers a variety or issues, including: z construction and/or equipment are in accordance with design specifications; z safety, operating, maintenance, and emergency procedures are in place and are adequate; z for new facilities, a process hazard analysis has been performed and rec ommendations have been resolved or implemented before start-up; z modified facilities have complied with MOC requirements including updating of the process safety information (e.g., piping instrument diagrams, operating procedures, etc.); z training of each applicable operating employee and maintenance worker has been completed. 4.7 Mechanical Integrity BRC has established and implemented written procedures to maintain the ongoing integrity of process equipment, pressure vessels and storage tanks, relief and vent systems and devices, emergency shutdown systems, and controls. The BRC mechanical integrity program follows recognized and generally accepted good engineering practices. BRC maintains a certification record that each inspection and test has been performed, which includes the date of the inspection, the name of the inspector and test, and the serial number or other identifier of the equipment. Every recommendation made by an inspector is resolved and documented. In so doing, BRC will correct deficiencies in equipment which are outside acceptable limits (as defined by the process safety information) before further use, or in a safe and timely manner that ensures safe operation. 4.8 Compliance Audits To ensure that the accident prevention program is functioning properly, BRC conducts audits every three years to assure that the accident prevention program is being implemented. The audits include an assessment of written prevention program elements, retained records (e.g., training records, completed hot work permits, etc.), and personnel interviews to assess level of implementation for the prevention program. Compliance reviews are performed by trained, expert personnel. Audit results are communicated to affected employees and contractors, and retained for five years. Action items or recommendation resulting from the various audits are tracked to completion through a computerized database. 4.9 Incident Investigation The BRC accident investigation program covers four types of incidents: " personal injury; " environmental release; " equipment damage and loss of production caused by fire, equipment failure or other circumstance; and " those incidents that could have reasonably resulted in a catastrophic event. The goal of an investigation is to determine the facts associated with a release or near miss and to develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team is directed by a team leader who has had training in incident investigation and root cause analysis. The results of the investigation are communicated to all employees. BRC maintains copies of incident investigation reports for a minimum of five years. Corrective measures and action items resulting from an inv estigation are tracked to completion in a computerized database. 4.10 Employee Participation All BRC employees have the right to participate in the development and conduct of process safety management activities as stated in the Risk Management and Process Safety Management rules. It is the policy and practice of BRC to encourage employee participation in all aspects of accidental release prevention elements. All process safety records are available for review by employees and the Joint Health and Safety Committees. 4.11 Safe Work Practices BRC Safe Work Practices include Hot Work, Confined Space Entry, Lock Out / Tagout, Line Entry, and various other types of work covered under a Departmental Safety Permit. The BRC Hot Work permit certifies that the various portions of fire prevention and protection requirements have been implemented prior to beginning hot work operations. This procedure documents the date(s) authorized for hot work, identifies the equipment on which hot work is to be done, and assures that all personnel involved in permitting are trained on this procedure. 4.12 Contractors Contractors at BRC are selected based on their past safety performance, their current safety programs, and their conformance to the BRC Refinery Safety Rules and Regulations Manual. The BRC Refinery Safety Rules and Regulations Manual provides contractor employees safety information, including entrance and exit procedures, safe work practices and work permitting procedures, emergency action plans, process safety information, and contractor injury/illness reporting. BRC also requires annual contractor orientation training, which includes information on the emergency action plan, potential process hazards, and site safety rules. Proof of training is provided via renewable access cards. Section 5. Five-Year Accidental Release Summary BRC compiled a five-year accident histo ry for accidental releases from covered processes in Area 3 that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. The compilation of this information satisfies the requirements of the federal Risk Management Program and U.S. Environmental Protection Agency implementing regulations (40 Code of Federal Regulations, Part 68). A review was conducted on all incident, emergency release, and equipment breakdown reports from June 1994 through June 1999 to identify accidental releases of regulated substances from covered processes that involved the impacts described above. No such releases from covered units in Area 3 containing regulated substances resulted in the impacts described above. Section 6. Emergency Response Program BRC has established a comprehensive Emergency Response Program. The purpose of the program is to protect workers, the public, and the environment from harm due to Refinery emergencies. The program includes procedures to provide for comprehensive emergency response through the following: z First aid and medical treatment z Emergency incidents, including fire, potential fire, hazardous materials releases, and natural disasters such as floods, winds, earthquake and electrical storms z Emergency evacuation and rescue z Notification of local, state and federal emergency response agencies and the public if an incident occurs z Post-incident clean-up and decontamination The Emergency Response Program provides for training of all refinery staff, which varies in level of detail based on assigned roles and responsibilities for staff under the Program. Routine audits are routinely performed by BRC staff, corporate staff, and third parties (the Kern County Fire Department and BRC's insurance company) to assure compliance with portions or all of the Emergency Response Program. File Code: 1,501,000 v:\psm\private\rmp\99A3_RMP_ES.doc |