Bayway Refinery - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND RESPONSE PLAN The Bayway Refinery is committed to worker and public safety. The recognition and control of risks are instrumental to the safe, efficient, and environmentally compliant operation of the refinery. The refinerys accident prevention and risk management plan is organized to be consistent with the OSHA Process Safety Management regulation, which provides for systematic and comprehensive attention to key elements of process hazard management, addressing issues of technology, personnel, and equipment. This structure facilitates our overall program which emphasizes accident prevention through safe design, installation, operation, inspection, and maintenance of our processes. Even though we emphasize the prevention of accidents, we also maintain a highly trained, qualified, and well-equipped emergency response organization to quickly respond to and mitigate an incident should one occur. DESCRIPTION OF STATIONARY SOURCE AND REGULATED SUBSTA NCES The Bayway Refinery, located in Linden, New Jersey, operates a wide variety of operating processes to convert raw crude oil into useable petroleum products for our customers. The refinery produces many commonly used petroleum products, including gasoline, heating oil, diesel, jet fuel, propane, butane, and petrochemical feedstocks. These products and their production account for numerous regulated flammable substances being present on site, including propane, butane, hydrogen, and mixtures of other regulated flammable substances. The Bayway Refinery does not exceed the EPA threshold quantity for any RMP regulated toxic materials. HAZARD ASSESSMENT RESULTS A Worst Case Scenario (WCS) represents the release and subsequent ignition of the entire contents of the storage vessel having the greatest offsite impact, without allowing for existing prevention measures, detection equipment, or response measures which are in place. Based upon the location of storage vessels (one contain ing primarily butane, the other containing primarily propylene), two flammable WCSs are reported for Bayway because of the potential to reach different offsite locations. The maximum vessel inventory was determined by the maximum operational fill height, which is monitored and protected by a high level alarm system. The results show that each of the refinerys two WCSs for flammable materials would reach the 1-psi overpressure endpoint offsite. The management systems and accidental release prevention program summarized later in this document will describe many of the steps we take to make an incident of this magnitude highly improbable. An Alternative Release Scenario (ARS) represents a more likely and realistic event. The ARS allows consideration of existing prevention, detection, minimization, and response measures which the facility has in place. After the evaluation of numerous ARSs, and consistent with the refinerys five-year accident history, no ARSs were found that w ould have a distance to endpoint reaching past the refinerys fenceline. FIVE-YEAR ACCIDENT HISTORY The Bayway Refinery has had an excellent accident record over the history of the facility, and has had only one event in the past five years involving the release of a regulated substance which meets the RMP reporting requirement. The incident occurred in 1996 when a hydrogen leak occurred inside one of our process furnaces, and the resulting fire required shutting down the equipment for repair. There were no injuries or offsite impacts associated with the fire; however, the equipment damage that resulted from the fire was financially significant. As a result of the refinerys incident investigation, a faulty instrument was determined to be the cause of the fire. This instrument and other similar instruments throughout the refinery were evaluated and corrected as necessary to prevent the recurrence of this type of incident. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Bayway Refinery. Because processes at the refinery that are regulated by the EPA RMP regulations are also subject to the OSHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accidental release prevention program. In addition to the OSHA PSM regulation, the refinery is also regulated by the New Jersey Toxic Catastrophe Prevention Act (TCPA) for processes covered by that regulation. The following elements represent numerous programs and practices that the Bayway Refinery has institutionalized as Management Systems. Through the establishment, review, and continuous improvement of these Management Systems, the Bayway Refinery demonstrates its commitment to operating a safe, healthy, and environmentally sound facility. EMPLOYEE PARTICIPATION The Bayway Refinery encourages employees to particip ate in all facets 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 program. Information on the refinerys prevention program is available to all employees, and they are encouraged to recommend improvements to any of the programs. Specific ways that employees can be involved in the prevention program are documented in the employee participation plan element of the PSM Management Systems Documentation. Copies of this document are maintained at the refinery and address each element of the accidental release prevention program. In addition to this program, the refinery has a strong commitment to following written policies and procedures, and encourages employees input to identify when a policy or procedure needs to be changed or improved to cover new tasks, revised regulations, or employee experience. Thro ugh this teamwork, a determination can be made to update the policy or procedure, and then train everyone involved on the revised requirements. PROCESS SAFETY INFORMATION The Bayway Refinery maintains an extensive library of Process Safety Information which includes information related to chemicals in the process, technology of the process, and equipment in the process. These documents include detailed information on chemical properties and their associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. The process safety information is available to all employees, either directly on the unit, or by contacting their supervisor. Chemical specific information, including hazards, protective measures, symptoms, and first aid procedures is provided via Material Safety Data Sheets (MSDSs). For specific process areas, the refinery has documented safety-related limits for specific process parameters (e .g. temperature, pressure, flow, and level). These are documented in the Operating Conditions and Controls section of the unit Operating Manuals. The refinery ensures that 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). The refinery also maintains technical documentation that provides 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 the 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 (PHA) The Bayway Refinery has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Bayway Refinery primarily utilizes 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 by a team representing operating experience, as well as safety and engineering expertise. 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 the team believes such measures are necessary. The PHA teams recommendations are forwarded to the management of the involved unit or area for resolution. Implementation of mi tigation measures 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 immediate attention. All mitigation measures being implemented in response to PHA team findings are tracked until they are resolved. The final resolution of each finding is documented and retained. To help ensure that the process operation and controls do not eventually deviate significantly from the original design safety parameters, the Bayway Refinery periodically updates and revalidates the hazard analyses. These periodic reviews are conducted at least every five years. The results and findings of these updates are documented and retained. Once again, any team findings are forwarded to the unit or area management for resolution, with the final resolution of the findings documented and retained. OPERATING PROCEDURES The Bayway Refinery utilizes written procedures that addre ss various facets of process operations, such as (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 are in an operating manual that is used as a reference by unit operators and provides a basis for consistent initial or refresher training of operators. The procedures are maintained by the involved area operating personnel, and are updated to reflect changes identified through the Management of Change process, through refresher training, or changes/improvements identified through normal operating experience. The operating manual is reviewed annually to ensure that it is current, updated, and accurate. The written operating procedures are readily available to all personnel to use as necessary to safely perform thier jobs. OPERATOR TRAINING To complement the written procedures for process operations, the Bayway Refinery has implemented a comprehensive training program for all employees involved in operating a process. New refinery operations employees (candidates) must successfully complete up to 8 weeks of basic training in refinery operations before being assigned to a unit specific training program. Basic training addresses applied sciences, job fundamentals, process operations, and understanding basic refining processes and operations. The time necessary to successfully complete unit specific training varies with the requirements of each job. Typically it requires from 12-18 weeks to qualify as an assistant operator on a specific operating post. Throughout the training process, candidates must continue to qualify by passing written and hands-on tests, thereby demonstrating understanding and retention of the training materials. Full operator qualification can require up to 3 years of field training progression. Refresher training on operating procedures is provided to all operating employees at least every three years, an d refresher safety training is performed annually. In addition, classes emphasizing specific topics of concern are offered as necessary (for example, furnace operations, dock operations, etc.). Operating personnel also receive training in emergency avoidance and emergency operating and fire fighting procedures. Prior to the commissioning of new or modified equipment, written operating procedures are developed and training is provided to all affected operating personnel. All required training is documented. MECHANICAL INTEGRITY/MAINTENANCE TRAINING The Bayway Refinery utilizes specific written procedures and design criteria for its operating equipment. Engineering references and resources utilized may include (as applicable) Bayway Engineering Standards, reference to recognized industry standards (such as API, ASME, ANSI, and NFPA), and the use of engineering consultants with expertise in a specific area of design. In addition, process design includes consideration of materials of construction, and piping and equipment configurations to facilitate operability and maintenance. The Bayway 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 a safe operating condition. The basic aspects of this program include: (1) providing appropriate training for each employee involved in maintaining the on-going integrity of process equipment, (2) developing written procedures, (3) performing appropriate inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these programs form a system that maintains the mechanical integrity of the process equipment. Maintenance employees attend up to 8 weeks of initial training on refinery operations, which includes (1) an overview of basic refinery operations, (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 tasks in a safe manner. In addition to this training, maintenance employees receive craft-specific training appropriate to the type of work they are to perform. Craft-specific training examples may include training as a welder, boilermaker, rigger, machinist, or carpenter, etc., and is often accomplished through a combination of classroom and hands-on training and testing. Maintenance employees then receive up to 8 months of on the job training before qualifying to independently perform craft-specific tasks. Refresher and specialty training courses are also provided as appropriate. Written safety procedures, identified in the Accident Prevention Manual, help ensure that work is performed in a consistent manner and provides a basis for training. Preventative maintenance inspections and tests are performed on equipment to help ensure that it func tions 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. Another integral part of the mechanical integrity program is quality assurance. The Bayway 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. CONTRACTORS The Bayway Refinery utilizes contractors to supplement its maintenance workforce and provide additional expertise and resources for specialty tasks or peak work periods (maintenance shutdowns 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 the y 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, (7) and know what to do if they encounter a hazardous condition in the course of their work. This is achieved by pre-qualifying contractors to bid on refinery contracts, (documented via the Contractor Qualification Form), and if selected, providing those contractors with pertinent information prior to their beginning work including (1) a process overview, (2) safety and health hazards, (3) emergency response plan requirements, and (4) required safe work practices. Contractor employees attend initial and annual training on Bayways site-specific safety and health requirements. A program of job site auditing is used to monitor contractor performance. The contractor is also required to perform self evaluations of their safety programs and resulting performance. Refinery personnel perform periodic formal reviews of the safety and quality of the contractors work while on-site. PRE-STARTUP SAFETY REVIEW (PSSR) The Bayway Refinery conducts a PSSR 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. This review provides one additional check to make sure that construction is in accordance with the design specifications and that all supporting systems are operationally ready. Checklists are utilized to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that applicable prevention program requirements are properly implemented. SAFE WORK PRACTICES The Bayway Refinery has long-standing safe work practices in place for worker and process safety. E xamples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure for 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 so that adequate precautions are in place before entry into a confined space is permitted. These procedures are maintained in the Accident Prevention Manual, which along with training, provides a system so that operations and maintenance activities are performed safely. MANAGEMENT OF CHANGE The Bayway Refinery has a comprehensive 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 reviewed and authorized before being implemented. Changes are re viewed to (1) determine that adequate controls are in place to manage and control any new hazards, and (2) verify that existing safeguards and process and equipment design conditions have not been compromised by the change. Affected chemical hazard information, process operating limits, equipment information, as well as operating procedures are updated to incorporate these changes. In addition, operating or maintenance personnel are provided any necessary training on the modification prior to its start-up. INCIDENT INVESTIGATION The Bayway Refinery promptly investigates all incidents which 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. The investigation team documents its findings, develops recommendations to prevent a recurrence , and provides those recommendations to refinery management for resolution. The investigation teams recommendations are tracked until they are resolved. The final resolution of each recommendation is documented, and the investigation results are reviewed with all workers who could be affected by the findings. The results of the incident investigation are retained for at least 5 years so that they can be reviewed during future PHAs and PHA revalidations. COMPLIANCE AUDITS To help the Process Safety Management and accidental release prevention programs function properly, the Bayway Refinery periodically conducts audits to determine whether the procedures and practices required by the programs are being implemented as intended. Employees participate in compliance audits which are conducted at least every three years. The audit team may include employee(s) from other sites and contracted outside consultants. The audit team develops findings that are presented to refinery and ar ea management for resolution. Corrective actions taken in response to audit team findings are tracked until they are complete. Additionally, independent audits are performed by the NJDEP under TCPA regulations. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the Bayway Refinery have hazards that are managed for continued safe operation. The accidental release prevention program summarized in this submittal applies to all Program 3 EPA RMP-covered processes at the Bayway Refinery. Collectively these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failure or (2) human error. In addition to the prevention program activities, the Bayway 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 following types of safety devices are used in various processes throughout the refinery to help prevent incide nts: 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. The following types of safety features are used in various processes throughout the refinery to help mitigate (reduce the effects of) incidents: sprinkler systems, deluge systems, fixed fire water monitors, diking/containment berms, fire fighting foam systems, supplemented by in-plant emergency response capabilities 24 hours a day. EMERGENCY RESPONSE The Bayway Refinery maintains a written emergency response plan to protect its workers and the public, as well as the environment. The program includes procedures for responding to the release of a regulated substance, including the possibility of a fire or explosion. The procedures address all aspects of emergency response, including notification o f local emergency response organizations, proper first-aid and medical treatment for exposures, evacuation and shelter in place (safe haven) plans, accounting for personnel after an evacuation, notifications to regulatory agencies, and post incident cleanup and decontamination. The Bayway Refinery utilizes the Incident Command System of incident management 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 suggestions for improvement. Training on changes is presented to affected workers. In addition to providing professional fire fighters on-site 24 hours/day, 7 days/week, the Bay way Refinery maintains a qualified Fire Brigade, Hazardous Materials Teams, Rescue Team, and Emergency Medical Technician (EMT) response capabilities. Frequent training and participation in emergency response drills ensures the readiness of the response organization. The overall emergency response program for the Bayway Refinery is coordinated with the Linden 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 Bayway Refinery has around-the-clock communications capability with appropriate LEPC officials and emergency responders. This provides a means of notifying the public of an incident and facilitating a quick response. The Bayway Refinery conducts periodic drills and training sessions with the local emergency responders. PLANNED CHANGES TO IMPROVE SAFETY Continuous Improvement: The Bayway Refinery continuousl y 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 the use of chlorine for both water treatment and catalyst regeneration with less hazardous alternative chemicals. Year 2000 (Y2K) Preparedness: Tosco Corporation and the Bayway Refinery have developed Y2K Task Forces to investigate, develop, and implement plans to minimize any disruption that possible Y2K issues could yield. 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 supplier system failures. |