Mobil Oil Torrance Refinery - Executive Summary

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Mobil Oil Corporation 
Torrance Refinery, California 
Risk Management Plan 
Executive Summary 
The Mobil Oil Torrance Refinery (Refinery) has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement controls to prevent releases of regulated substances. If a release does occur, our trained personnel respond to control and contain the release. 
The refinery, located in Torrance, California, U.S.A. operates a variety of processes to produce petroleum products (e.g., diesel, jet fuels, and gasoline) from raw crude oil. The refinery has several regulated flammables, such as butanes and LPG. 
In addition, the refinery uses chlorine, hydrogen 
fluoride, and ammonia, and generates H2S, which are also regulated substances. 
The RMP rule requires companies to develop chemical release scenarios that estimate the potential community impact from an accidental release.  These scenarios are useful for emergency planning in the event of an accident.  There are two types of scenarios required by the EPA.  The worst case scenario (WCS) is the release of the largest quantity of a regulated substance.  It assumes the worst case meteorology situation that would allow the release to travel the greatest distance.  The alternative release scenario (ARS) allows industries to develop a more realistic planning scenario.  Off site impacts from either scenario is mitigated by our prevention programs. 
The WCS and ARSs for toxic substances at the refinery involve the release of hydrogen fluoride, ammonia, and chlorine. 
The WCS associated with a release of flammable substances at the refinery is a vapor cloud explos 
ion (VCE) involving a rupture of a butane storage tank. The ARS for flammable substances at the refinery is a VCE involving butane. 
The following is a summary of the general accident prevention program in place at the refinery. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. 
4.1 Employee Participation 
The refinery encourages and requests employees to participate in all facets of process safety management and accident prevention. 
4.2 Process Safety Information 
The refinery 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, an 
d equipment design basis/configuration information.  
4.3 Process Hazard Analysis (PHA) 
PHA is a comprehensive program used for the identification and analysis of hazards in a process for the purpose of systematically evaluating the likelihood and consequences of accidents in order to develop recommendations to reduce and/or control risks. 
The refinery 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 result of the analysesis the identification and evaluation of the hazards of the process as well as recommendations for accident prevention and mitigation measures. 
4.4 Operating Procedures 
The refinery maintains written processes 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 pr 
ocess. These procedures can be used as a reference by experienced operators and provide a 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 process. 
4.5 Training 
To complement the written procedures for process operations, the refinery has implemented a comprehensive training program for all employees involved in operating a process. 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 (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work indepen 
dently. 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. 
4.6 Contractors 
Contractors are required to adhere to the same safety standards as the Torrance  
Refinery employees.   The contractors receive equivalent safety training and information.  
4.7 Pre-startup Safety Reviews (PSSRs) 
The refinery conducts a PSSR for any new facility or facility modification that requires a change in the process safety information The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service.  
4.8 Mechanical Integrity 
The refinery has well-established practices and p 
rocedures to maintain process equipment in 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. The 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 in combination, these activities form a system that maintains the mechanical integrity of the process equipment when repairs are made. 
4.9 Sate Work Practices 
The 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 o 
f 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 others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 
4.10 Management of Change 
The refinery has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be 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 information, process operating limits, and eq 
uipment 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. 
4.11 Incident Investigation 
The refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. 
4. 12 Compliance Audits 
The Torrance Refinery performs audits to ensure the effectiveness of the accident prevention program.  The refinery periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented.  
The processes at the refinery have hazards that are managed to ensure continued safe operation.  
The accident prevention program summarized previously is applied to all Program 2 and 3 EPA RMP-covered processes at the refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human error. 
In addition to the accident prevention program activities, the refinery has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release.  
The refinery has had two accidents that meet the RMP 5-year accident reporting criteria:  (1) a MHF release in 1998 (resulting in a road closure); and (2) a release of HF in 1999 (resulting in precautionary shelter-in-place). 
The 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 proc 
edures for responding to a release. The procedures address 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 post incident cleanup and decontamination requirements. In addition, the 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 MOC process, which includes informing and/or training affected personnel in the changes. 
The overall emergen 
cy response program for the refinery is coordinated with the Southern Cailifornia, Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The refinery has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the refinery conducts periodic emergency drills that involve the Torrance Fire Department and emergency response organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery. 
The refinery resolves all findings from PHAs, some of which resul 
t in modifications to the process. The following types of changes are planned: 
7 Revised P&IDs and PFDs and/or controls in various refinery units 
. Improved fire suppression system in the LPG area 
7 Improved spill control dikes in the tank farm 
7 Various risk reduction programs ongoing 
7 Revised written procedures in the railcar areas
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