Los Angeles Refining Company (LARC) - Executive Summary
EXECUTIVE SUMMARY |
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
The Los Angeles Refining Company (LARC), a division of Equilon Enterprises LLC, has a long-standing commitment to worker, public, and environmental 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. LARC mission statement is "to lead the industry in safety, environmental and financial performance through the development and participation of all employee". Our policy is to implement reasonable controls to prevent potential releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release to the extent possible.
LARC's process units and physical systems including the tank farm are divided into three areas referred to "asset areas". The overall responsibility of th
e day-to-day operation of each asset area is assigned to an individual, known as the "asset area manager". In addition to the asset areas, there are five technical departments at LARC. The overall RMP Program responsibility resides with the president of LARC. The specific responsibility for the development and implementation if each RMP element is with the various asset area and technical department managers. The refinery has also designated a qualified person, who is responsible for coordinating the Process Safety Management and Risk Management Program activities at LARC.
DESCRIPTION OF THE REFINERY AND REGULATED SUBSTANCES
LARC is located in a zone that is designated for heavy industrial use. This 299-acre refinery is divided by Pacific Coast Highway with most of the facility located on the north side of the highway. Sepulveda Boulevard bounds the northern portion of the refinery to the north, Alameda Street and Southern Pacific rail tracks to the west, and the Dominguez Ch
annel to the east. The southern portion is a triangle-shaped parcel that approaches Anaheim Boulevard to the south and is bounded by Dominguez Channel to the east, and by the Equilon Marketing Sales Terminal to the west.
LARC processes approximately 100,000 barrels of crude oil per day, through a variety of operations, including hydrocracking, hydrotreating, fluid catalytic cracking, delayed coking, and alkylation. The products of the refinery include various petroleum products, such as liquefied petroleum gas (LPG), gasoline, jet fuel, and diesel fuel.
Among the refinery units and systems, there are only fourteen units that contain "regulated substances" above the threshold limits as specified in the RMP Rule. These fourteen units are designated as "covered processes" in this document. We have also made a conservative assumption that all the fourteen covered processes are eligible for Program Level 3.
Per the RMP Rule, LARC handles two regulated toxic substances, which are
hydrogen sulfide, and anhydrous ammonia, and several regulated flammable substances, such as hydrogen, propylene, and butane.
For the regulated toxic substances, the endpoints are as follows:
Anhydrous Ammonia 200 ppm (0.14 mg/l
Hydrogen Sulfide 30 ppm (0.042 mg/l)
For regulated flammable substances, the endpoints are as follows:
Overpressure of 1 pound per square inch (psi) for vapor cloud explosions
Radiant heat of 5 kilowatts per square meter (kW/m2) for jet fires
Lower flammability limit (LFL) for flash fires
WORST-CASE RELEASE SCENARIOS
A worst-case release scenario has been defined in the EPA Rule as the release of the largest quantity of a regulated substance from a vessel or process line rupture that could result in the greatest distance to a specified endpoint. We reviewed the covered processes and identified scenarios that would be suitable for the worst-case release analysis. This was followed by the review of vessels and storage tanks to determine those with la
rgest quantities of regulated substances. We then calculated the inventories of all vessels in the covered units and systems. The vessels with the largest inventories of regulated toxic and flammable materials were selected.
In selecting hypothetical worst case release scenarios, we paid particular attention to not only the vessels with largest inventories of regulated substances, but also to high pressure and high temperature process vessels and those that are located near the refinery fence lines. This approach takes into consideration smaller inventories at higher pressures or temperatures that may result in greater distances to the toxic endpoint. We also considered those vessels that contain high concentrations of hydrogen sulfide mixed with hydrocarbons.
Once these vessels were identified, we used EPA's RMP*CompTM to determine the distance to the endpoints for the worst-case release scenario analysis. We reviewed all the vulnerability zones, resulted from this analysis.
A vulnerability zone is defined as a circle whose center is the point of release and its radius is the length of the endpoint plume, which is predicted by a dispersion model (e.g., RMP*CompTM). We selected the cases, which resulted in the largest zones for the refinery areas and their vicinities to the public sectors around the refinery.
Several possible consequences of releases of flammable substances are considered, including flash fire, pool fire, BLEVE, and vapor cloud explosion. We analyzed all these possibilities, and concluded that vapor cloud explosion was the most appropriate consequence. The RMP rule imposes several mandatory assumptions that we adhered to when performing the offsite consequence analysis of the worst case release scenarios. Three worst case release scenarios have been selected for the refinery, i.e., two for toxic chemical substances (anhydrous ammonia and hydrogen sulfide) and one for butylene representing flammable materials.
ALTERNATIVE RELEASE A
Alternative scenarios are potential release cases that may result in plumes whose footprints, represented by the endpoints, could extend beyond the refinery boundary. The process of alternative release scenario identification was initiated with the review of the worst-case release cases. We then reviewed other vessels, containing various quantities of regulated substances, which considered having a higher likelihood of release. In this process, all covered processes were reviewed and candidate cases for the alternative release scenario analysis were subsequently selected.
Once the list of candidate scenarios was developed, we used PHAST 5.2 computer program to model the selected scenarios. We reviewed the vulnerability zones resulted from the analysis of the alternative release scenarios. In the alternative release scenario analysis, we used the site-specific meteorological data. We also selected the size of release, which was estimated from a hole-size that would resu
lt from equipment or pipe failure. The size of the holes were based on several factors, including pipe diameter, valve size, and pump seal size.
The release duration was primarily based on the length of time that the administering controls (including the operator) to stop the release. In general, we thought 20 minutes is a reasonable response time to stop most releases at the refinery. In some cases, the duration of the release was shorter, which was dictated by the inventory of the material in the vessel(s) connected to the equipment. The idea was to include at least two scenarios for ammonia and hydrogen sulfide and one for the flammable materials for the refinery as a single stationary source. On the other hand, because the refinery is near certain communities, we also wanted to include scenarios that could potentially impact those communities. As a result, we selected three alternative release scenarios for toxic and five cases for flammable. The RMP rule does not impose a
ny mandatory assumptions for the offsite consequence analysis of the alternative release scenarios.
The LARC plant has experienced two incidents during the last five years that meet the EPA's requirements for the five-year accident history:
1. Hydrotreating Unit 4 (HTU-4) fire in 1996. This incident resulted in major equipment damage and ten (10) OSHA recordable injuries internally. There were some alleged offsite damages and injuries reported. The majority of these claims have been dismissed without pay and the balance has been settled with minimal pay.
2. Alkylation Unit acid carry-over in 1997. This incident resulted in major equipment damage and eight (8) OSHA recordable injuries internally, but it did not have any known offsite effects.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program in place at LARC.
LARC has instituted an employee participation p
rogram to consult with the employees in the development and implementation of all the PSM elements. Employee participation is encouraged at all levels of the LARC organization. Special groups, committees and individuals have been identified as having PSM responsibilities at the refinery. Nevertheless, all employees are encouraged to raise specific suggestions or concerns related to process safety management by contacting their immediate supervisor or the PSM coordinator. The LARC's Employee Participation Program is described in Standing Instruction PSM-1.
Process Safety Information
At LARC, we have compiled process safety information for all the units that have been through a process hazard analysis. This information concerns process chemicals, process technology, and process equipment that is used in the LARC PSM program. The compiled process safety information is a resource for the teams performing process hazard analyses. The information can also be helpful for the trainers
who develop the training programs and the operating procedures, for the contractors whose employees will be working with the refinery processes, and for the emergency responders.
Process Hazard Analysis
Process Hazard Analysis (PHA) is a primary element of the Prevention Program at LARC. We perform process hazard analysis at LARC to obtain information that will help improve process safety and system reliability, as well as reducing the potential consequences of accidental releases of hazardous chemicals. Because of the size and complexity of the refinery units, we have selected Hazop as the appropriate PHA method. A Hazop team at LARC usually consists of a process engineer, an experienced operator, an instrument & electrical engineer/technician, a mechanical engineer and other part time team members. The team leader (Hazop facilitator) is fully knowledgeable in the proper implementation of the Hazop methodology. The part time team members provide expertise in areas such as safety
and health, and equipment inspection/metallurgy/corrosion.
LARC provides written procedures that address various modes of process operations, such as: unit startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and initial startup of a new process. LARC's operating procedures describe tasks to be performed, data to be recorded, operating conditions to be maintained, samples to be collected, and safety and health precautions to be taken. LARC takes steps to update the procedures to reflect current operations and the procedures are certified annually by the operating staff. In addition, operating procedures are updated when there is a change in the process as a result of the management of change procedures.
Training is also a primary element of the Prevention Program at LARC. The training program consists of job skill (qualification) and safety training. The qualification training programs are described in the Sta
nding Instructions of O-43 (Operation Training Policy) and M-42 (Maintenance Training Policy), which clearly establish the goals and objectives that LARC wishes to achieve with the training that is provided to the employees. LARC provides initial training to new hires and regular refresher training to the refinery employees.
The job skill training is presented in various forms and degrees, depending on the skills and job positions of the employees. The purpose of this training is to elevate the aptitude and knowledge of the operation and maintenance crews on the process control and technology used, and equipment operated in the refinery. All employees at LARC, including maintenance and contractor employees, involved with highly hazardous chemicals and regulated substances are provided with safety training. The goal of the safety training is to provide information to workers so they will understand recognized hazards of the chemicals and processes they work with and around.
LARC has established a screening-process that helps identify and select contractors who will perform works in and around processes that involve hazardous chemicals. Such contractors must have the appropriate skills, knowledge, and certifications for job tasks, as applicable. The Contractors Safety Program is described in Standing Instruction SAF-30. For contractors, whose safety performance on the job is not known, LARC obtains information on injury and illness rates and references. We also evaluate contractor work methods and experiences. Therefore, contractors with no safety programs or with unacceptable safety records will not be invited to perform works at LARC.
Management of Change
LARC has implemented a Management of Change (MOC) procedure, reflected in Standing Instruction PSM-2, to manage changes to the refinery units. Changes include modifications to equipment, procedures, raw materials, and processing conditions other than "replacement in kind". The LARC M
anagement of Change procedure includes modification in the operating procedures that contain the operating parameters, such as pressure limits, temperature ranges, flow rates, and other process variables. The Management of Change procedure also covers changes in process technology and changes to equipment and instrumentation.
Changes in process technology can result from changes in production rates, raw materials, experimentation, equipment unavailability, new equipment, new product development, change in catalyst and changes in operating conditions to improve yield or quality. Equipment changes include, among others, change in materials of construction, equipment specifications, capacity, piping pre-arrangements, experimental equipment, computer program revisions, and changes in alarms and interlocks. Temporary changes are also subject to the management of change provisions. The MOC procedure is also used to insure that the equipment and procedures are returned to their original
or designed conditions at the end of the temporary change.
Pre-Startup Safety Reviews
At LARC a pre-startup safety review (PSSR) is carried out in conjunction with a management of change (MOC) or a new project Hazop. LARC conducts a PSSR before a modification to a system or a unit is implemented, or before a new project is commissioned. It is also LARC's practice to conduct a process hazard analysis (e.g., Hazop) for various types of changes and for all new projects. As a result, there could be some recommendations resulting from the process hazard analysis of a change or a new system. High priority Hazop recommendations are addressed before a change or a new system is implemented to verify the safe operation of the system under modification or renovation. A PSSR is carried out in the form of a checklist to comply with requirements of the OSHA regulations.
A mechanical integrity program is in place for the continued integrity of process equipment at LA
RC. Equipment used to process, transfer or store hazardous chemicals have been designed, constructed, installed, and maintained to reduce the likelihood of accidental releases of such chemicals. This program covers: pressure vessels, storage tanks, piping systems, pressure relief systems and safety devices, emergency shutdown systems, electronic controls, and rotating equipment (e.g., pumps and compressors.) LARC also reviews the maintenance programs and shutdown schedules to determine if there are areas where "breakdown" maintenance is used rather than an on-going mechanical integrity program. Elements of the mechanical integrity program are as follows: (1) categorization of equipment and instrumentation, (2) inspection and testing program, (3) maintenance program, (4) documentation, and (5) quality assurance program.
Hot Work Permit
All non-routine and some routine works, conducted in process areas at LARC, are controlled using specific company instructions, described in the
Standing Instructions SAF-3 (Safe Work Permits), SAF-4 (Hot Work Permits), and SAF-5 (Entry Work Permit). A hot work permit describes the steps that the operating staff, the maintenance staff, and contractor representatives must follow to obtain the necessary clearance to perform different types of work. The hazards identified involving the work that is to be accomplished is communicated to those doing the work, but also to those operating personnel whose work could affect the safety of the process. The hot work permit procedures refer and coordinate, as applicable, to lockout/tagout procedures, line breaking procedures, and confined space entry procedures and authorizations.
LARC's incident investigation procedure is described in standing instruction SAF-11, and applies to the investigation of different types of incidents that may occur in the facility. The intent of an incident investigation is for LARC to identify the cause of incidents and to prevent
or minimize their recurrence. A multi-disciplinary team is assembled to gather the facts of the events and to identify, to the extent possible, the cause of the incident. Team members are selected on the basis of their training, knowledge, and ability to contribute to a team effort to investigate the incident. The team usually includes an operator from the area where the incident occurred. The operator's knowledge of the events can help identify and verify relevant facts about the incident that occurred. The intent of the investigation team and the investigation process deals with all involved individuals in a fair, open and consistent manner. The incident report, its findings and recommendations are entered in the incident investigation tracking system, which can be accessed by all the employees and those who can benefit from the information.
In compliance with Equilon's policies, LARC has implemented an Environmental, Health, and Safety Compliance Assura
nce Program. The program helps to verify that LARC's programs and practices comply with applicable laws and regulations. LARC undergoes an Environmental Audit and a Health and Safety compliance Audit, conducted once every three years by an Equilon Corporate staff. The audit approach includes the following steps: (1) pre-audit preparation, (2) on-site field review, and (3) post-audit follow-up. The audit team, composed of qualified staff, will be assigned a leader who will be responsible for taking these steps.
At LARC we recognize that the "Y2K" issue may affect every aspect of our business, including computer software, computer hardware, telecommunications, industrial automation and relationships with our suppliers and customers. Our Y2K efforts include programs to educate our employees, development of detailed guidelines for project management, testing and remediation. All our production and automation systems are routinely analyzed for potential failures and a
ppropriate responses are identified and documented. Significant progress in upgrading systems for Y2K compliance has been made and expectations are that this effort will be completed by June 30, 1999.
CHEMICAL SPECIFIC PREVENTION STEPS
The accident prevention programs summarized previously apply to all the covered processes and their related hazards. These programs help prevent potential accident scenarios that could be caused by equipment failures or human errors. In addition to the accident prevention program activities, LARC has safety features on many units to help contain or control potential releases, quickly detect a release, and reduce (mitigate) the consequences of a potential release. The following types of safety features are used in various processes.
1. Release Detection
7 Hydrocarbon detectors with alarms
7 Hydrogen sulfide detectors with alarms
2. Release containment and Control
7 Pressure relief valves that discharge to the refinery flare system to capture a
nd incinerate sporadic releases
7 Scrubber to neutralize sulfuric acid fume
7 Emergency valves to isolate the release source from the release points (manual and automated)
7 Automated emergency shutdown switches for process parameters (e.g., high level, high temperature)
7 Dike areas around storage tanks to contain liquid releases
7 Redundant equipment and instrumentation (uninterrupted power supply for process control system, backup firewater pumps, etc.)
7 Atmospheric relief devices
3. Release Mitigation
7 Fire suppression and extinguishing systems
7 Deluge system for LPG storage tanks and ammonia tank
7 Trained emergency response personnel
7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)
7 Blast-resistant control room to help protect control systems and personnel
As part of the process safety program, LARC has made an effort to reduce the number and quantities of regulated substances stored on site. For example, LARC phased out chl
orine used for cooling water treatment and replaced it with bleach. Plans are in place to change a hydrogen production process that will eliminate the presence of a dilute gas (a mixture of hydrogen sulfide and carbon dioxide) underground line. This project will result in the reduction of anhydrous ammonia consumption by twenty percent.
EMERGENCY RESPONSE PROGRAM INFORMATION
LARC has implemented an emergency response program to prepare for potential incidents, respond to them effectively, and recover from their impacts. The ERP has included a set of potential incidents that are used for emergency drills, including accidental release of toxic gases (ammonia and hydrogen sulfide), accidental release of flammable materials resulting in a fire and explosion, and accidental spill of hazardous materials on the ground within the refinery perimeter.
LARC uses an Emergency Management Organization, known as Incident Command System (ICS), to respond and manage incidents. The ICS has a hi
erarchical (chain of command) structure, which places the highest responsibility on the Emergency Manager, who has the overall responsibility for the emergency. The Emergency Manger is a liaison between the Incident Commander and the public and the Company. The next level of responsibility resides on four section chiefs: Command Chief, Operations Chief, Planning Chief, and Logistics/Finance Chief. All section chiefs receive directions from the Incident Commander. Each position in the organization has specific assignments and responsibilities, which are defined in the ERP. The ICS is expanded or contracted to meet the needs or requirements of an emergency. As the scope and complexity of an emergency expands so does the Incident Command System.
LARC has a three-tier emergency activation system in place. Level 1 emergency is defined as an event, which can occur at a local work area (e.g., a unit), with minor consequences to health or property, which would not have an impact on the
other units in the refinery. Level 1 emergency is handled by the personnel available on the unit and does not require assistance from personnel outside of the work area. A Level 2 emergency is a refinery emergency that would not require assistance from responders outside of LARC, but would require additional resources from the LARC Fire Brigade. The highest level of an emergency is Level 3, which is defined as an emergency of a size and scope that would require outside resources. A Level 3 emergency is triggered when life and property are endangered or when the emergency could result or has resulted in offsite consequences.
LARC maintains an industrial Fire Brigade, which consists of three emergency response teams, specialized in rescue, hazardous materials, and spill containment. Each ER Team is lead by a captain and consists of six to nine members. External sources provide assistance in the form of alerting the public, evacuation, transportation, and providing hazard mitigat
ion equipment, supplies, and personnel to complement LARC capabilities. It should be emphasized that external assistance is requested only during a Level 3 emergency. In addition to these sources, LARC has coordinated with the local hospitals, clinics, and doctors about properties of the various types of hazardous materials processed and handled at the refinery. All ER Team members, ER Team captains, and Asset Safety Coordinators are required to attend quarterly onsite training. Outside training is also provided annually to various ERT members, Shift Supervisors, and Asset Safety Coordinators. Emergency training and ICS role-play is provided annually to the Emergency response Management Organization.
COMMUNICATION WITH THE PUBLIC
Pursuant to the requirements of the RMP Rule, Equilon, in a joint effort with other local RMP covered industry companies in Southern California, has made strides to establish a sound communication link with the communities surrounding the industrial fac
ilities. The primary objectives of this endeavor have been to: (a) share with the public our knowledge about the operations and activities, as well as hazards of the facilities, (b) learn from the public their interests and concerns, and (c) establish an on-going relationship with the community regarding potential risks of the facilities.
Monthly meetings were held between representatives from the industry, community, and agencies to establish a plan of communication for the RMP to all those concerned. We prepared brochures describing the RMP Rule, industry specific hazards, prevention programs, and emergency response. Presentations discussing these topics were made to community groups. The presentations also included information regarding the industry vulnerability zones for the worst-case release and alternative case release scenarios.