Clark Blue Island Refinery - Executive Summary |
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PRELIMINARY RISK MANAGEMENT PLAN EXECUTIVE SUMMARY FOR THE CLARK REFINERY IN BLUE ISLAND, ILLINOIS ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Clark Refining and Marketing Company (Clark) Blue Island Refinery has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources devoted to 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 onsite personnel will respond to control and mitigate the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES Clark operates a variety of processes to produce petroleum products (propane, butane, gasoline, etc.) from crude oil. The refinery has several regulated flammables, such as propane, butane, etc., as well as hydrofluoric acid (H F), which is a regulated toxic substance. HAZARD ASSESSMENT RESULTS The EPA-mandated worst-case scenario associated with toxic substances at the refinery is a catastrophic failure of a settler in the HF Alkylation Unit, resulting in a release of 235,000 lb of pressurized anhydrous HF gas over a 10-min period. Due to the location of the refinery, the toxic cloud formed by such an event will reach offsite public receptors. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures is taken into account in evaluating this scenario. The EPA-mandated worst-case scenario associated with a release of flammable substances at the refinery is a vapor cloud explosion involving the full inventory of the largest storage tank containing 1,810,000 lb of normal butane. The tank inventory is assumed to release to the atmosphere, completely vaporize, and ignite, resulting in a vapor cloud explosi on. The overpressure created by the vapor cloud explosion will reach offsite public receptors. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this scenario. The alternative scenario for HF is a partial rupture of an unloading hose from an HF tank truck. If this scenario were to occur, our operators would shut off the flow from the truck within seconds. For this scenario, however, we chose to assume that it takes 30 seconds to stop the release. During this period, 169 lb of HF is released. The toxic cloud resulting from this release would reach offsite public receptors. The alternative scenario for flammables is a rupture of an unloading hose from a railcar containing butane. If this scenario were to occur, our operators would shut off the flow from the railcar within seconds. For this scenario, we chose to assume that it takes 2 minutes to stop the rele ase. Of the 5,800 lb of butane released during this 2-minute period 1740 lb is assumed to vaporize and ignite, resulting in a vapor cloud explosion. The overpressure created by the vapor cloud explosion will reach offsite public receptors. Alternative case scenarios are evaluated during a hazard analysis. Potential situations are evaluated to determine the types of safety systems needed to prevent an incident from occurring, and to determine the appropriate emergency response actions needed. The hazard analysis team then compares the potential situation to the existing system(s) to determine whether equipment or procedure changes are needed. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Clark refinery. Because processes at the refinery that are regulated by the EPA risk management program (RMP) rule are also subject to the OSHA process safety management (PSM) regulation, this summary ad dresses each of the OSHA PSM elements that are part of the RMP prevention program and describes the management systems in place to implement the accident prevention program. Employee Participation Clark encourages employees to participate in all facets of PSM 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 accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the refinery and addresses each accident prevention program element. In addition, the refinery has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the refinery, including operations, maintenance, engineering, and refinery management. Process Safety Information Clark 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 responsible 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. 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 documented safety-related limits for specific process parameters (temperature, level, composition, etc.) in the operating procedures for each process. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly 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 Clark has a comprehensive program to ensure that hazards associated with the various processes are identified an d controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. Clark 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, maintenance, and engineering experience. 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. The team findings are forwarded to management for resolution. The team also assigns a risk ranking to the findings. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All findings are tracked until they are resolved. The final resolution of each finding is documented and retained. The PHA is updated at least every 5 years to ensure that the hazard analysis is consistent with the current process. The results and findings from these updates are documented and retained, and the findings are forwarded to management. Operating Procedures Clark maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures are used as a reference by experienced operators and provide the 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 (MOC) process. In addition, the operating procedures provide guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, Clark has implemented a comprehensive operations training program for all employees. 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-specific duties and tasks. After operators demonstrate (by testing) adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. 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 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. Contractors Clark uses contractors to provide a broad range of nonoperating services, including pipefitting, painting, landscaping, and other services. Procedures are 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, and (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, and (4) safe work practices prior to their beginning work. In addition, the Clark refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) The Clark refinery conducts a PSSR for any facility modification that requires a change in the process safety information. PSSRs 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 has been properly completed and that support systems (e.g., procedures) are in place. A PSSR involves a checklist review and field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The Clark 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, and (5) applying quality assurance measures. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). When a deficiency is identified, the defici ency is reviewed with management to determine the appropriate course of action. Quality assurance is another integral part of the mechanical integrity program. Clark incorporates quality assurance measures into equipment purchases and repairs to 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 Clark 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 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. These procedures and training of affected personnel form a system to ensure that operations and maintenance activities are performed safely. Management of Change (MOC) Clark has a comprehensive system to manage changes to processes. The MOC system ensures that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes are properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The Clark refinery promptly investigates all incidents th at resulted in, or reasonably could have resulted in, a fire, explosion, or toxic gas release that could cause major property damage, environmental loss, or personal injury. Each investigation determines the facts and develops 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. Compliance Audits To ensure that the accident prevent ion program is functioning properly, the Clark 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 Clark 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 Clark refinery. In addition to the accident prevention program activities, the Clark refinery has safety features on many units to help (1) contain and control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release Detection o Hydrocarbon and HF acid detectors with alarms Release Containment and Control o Flare to capture episodic releases from process relief valves o Scrubber to neutralize chemical releases o Valves to permit isolation of the process (manual and/or automated) o Automated shutdown systems for specific process parameters o Vessels to permit partial removal of the process inventory o Curbing or diking to contain liquid releases o Redundant equipment and instrumentation Release Mitigation o Fire suppression and extinguishing systems o Deluge system for specific equipment o Onsite trained emergency response personnel FIVE-YEAR ACCIDENT HISTORY In October 1996, a fire in the HF Alkylation Unit caused damage to our facility, but the fire did not lead to a ny offsite effects and no HF acid was released as a result of the incident. In fact, no incident in the last 5 years led to offsite effects as defined by the RMP regulation. Clark is committed to preventing accidents by investigating every incident very carefully to determine ways to prevent similar incidents from occurring. EMERGENCY RESPONSE PROGRAM INFORMATION Clark maintains a written emergency response program, which protects worker and public safety, as well as the environment. The program consists of trained personnel and procedures for responding to a release of a regulated substance. The emergency response program addresses 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 postincident cleanup and decontamination requirements. Also, the Clark refinery has procedures th at 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 MOC process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Clark refinery is coordinated with local fire and police departments and state and federal agencies through the Incident Command System. The Clark refinery has around-the-clock radio communications capability with appropriate community officials and emergency response organizations (e.g., the fire department). This provides a means of facilitating quick response to an incident, as well as notifying the public of an incident if necessary. The Clark refinery conducts periodic emergency response exercises that involve refinery personnel, contractors, and emergency response organizations. The refinery provides annual refresher training to emergency responders regarding their responsibilities during an emergency. PLANNED CHANGES TO IMPROVE SAFETY Clark management believes an incident-free operation is essential for properly conducting its business and requires that safety improvements be an integral part of management at Blue Island refinery. As a result, the Blue Island refinery places priority on all of the Release Prevention Program elements, including the following programs, for continually improving safety: 7 Process hazard analysis 7 Employee training 7 Equipment maintenance 7 Management of change 7 Audits 7 Incident investigation |