Valero Refining Co. - New Jersey - Executive Summary
Paulsboro Refinery Risk Management Plan |
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Paulsboro 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 reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED
The Paulsboro Refinery operates a variety of processes to produce petroleum products, including fuels and lubricants, from raw crude oil. The refinery produces several regulated flammables, such as propane and butane. The refinery also produces hydrogen sulfide, which causes the removal of sulfur compounds from the ref
ined products. Two other regulated chemicals, hydrofluoric acid and chlorine, are used in the refining processes.
HAZARD ASSESSMENT RESULTS
The worst case scenario (WCS) associated with toxic substances at the refinery is a failure of the hydrofluoric acid storage drum, releasing its maximum quantity (244,000 pounds) in ten minutes. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or active mitigation measures is allowed when developing this hypothetical scenario. Therefore, the maximum distance to the toxic endpoint of 20-PPM (0.016 milligrams per liter) for this WCS is 19 miles.
The alternative case scenario (ACS) for hydrofluoric acid is a small leak from a storage vessel. The release rate is 1.5 pounds per minute for 10 minutes. The distance from the leak source to the toxic end point is 0.06 miles, which does not extend outside of the refinery.
The alternate case scenario (ACS) for chlorin
e is leakage from a pipe or fitting, releasing an estimated 67 pounds of chlorine. The distance from the source to the toxic endpoint is 0.1 miles, which does not extend outside of the refinery.
The alternate case scenario (ACS) for hydrogen sulfide is leakage from a pipe or fitting, releasing an estimated 2000 pounds of hydrogen sulfide. The distance from the source to the toxic endpoint is 0.3 miles, which could extend beyond the refinery boundary.
The WCS associated with a release of flammable substances at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest LPG storage tank containing butane. Using methods prescribed by the EPA, the entire tank inventory of 150,000 pounds is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1psi over pressure endpoint for this WCS is 0.24 miles. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for act
ive mitigation measures allowed when developing this hypothetical scenario.
The alternate case scenario ACS for flammable substances at the refinery is a VCE resulting from the release of propane from a transfer releasing 2500 pounds of propane. The maximum distance to the 1-psi over pressure endpoint for this event is 0.1 mile. This event was selected as being a practical scenario for use in emergency planning and response.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program in place at the Paulsboro Refinery. Processes at the refinery that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, as well as New Jersey chemical safety regulations. This summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.
The Paulsboro Refinery encourages employees to participate in all face
ts of process safety management 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. The refinery Joint Health and Safety Committee facilitates much of the refinery safety communications.
Process Safety Information
The Paulsboro 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, and equipment design basis configuration information. Specific departments within the refinery are assigned responsibility for maintaining up-to-date process safety information.
Chemical specific information, including exposure hazards and emergency resp
onse and exposure treatment considerations, is provided in material safety data sheets (MSDS). This information is supplemented by documents that specifically address chemical safety concerns. For specific process areas, the refinery has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the Standard Operating Procedures manuals. 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., alarms, interlocks and automatic 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 bas
is 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
The Paulsboro 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 Paulsboro 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 analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes s
uggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to management for resolution. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Paulsboro Refinery periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings are documented and retained.
ulsboro Refinery 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 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 reviewing them as necessary to reflect changes made through the management of change process.
To complement the written procedures for process operations, the Paulsboro Refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees and unit transfers receive basic operator training in refinery operations related to the process to which they are being assigned. After successfully
completing this training, a newly assigned operator receives on the job training from a qualified operator to learn unit specific duties and tasks. Operators demonstrate required qualification requirements through written tests, demonstrative skills and oral testing. Once the Unit Supervisor has reviewed the qualification of the Operator, their progress is documented and they are released to perform their job responsibilities. There are additional qualified operators working at the process unit for operator support. In addition, operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. Operating procedure review and job rotation is performed every year. Additional refresher testing, on all jobs for which an operator is qualified 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 understoo
d the training.
The Paulsboro Refinery uses contractors to supplement its work force. Because some contractors work on or near process equipment, the refinery has procedures 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 Paulsboro Refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contra
ctors are fulfilling their safety obligations.
Pre Startup Safety Review (PSSR)
The Paulsboro 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. This review provides one additional check to make sure construction is in accordance with the design specifications and that all-supporting systems are operationally ready. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
The Paulsboro Refinery has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown sy
stems 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. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. 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 help ensure that work is performed in a consistent manner and provide a basis for training.
Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identifie
d, employees will correct the deficiency before placing the equipment back into service (if possible), or an MOC team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.
Another integral part of the mechanical integrity program is quality assurance. The Paulsboro Refinery incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and those proper materials and spare parts are used when repairs are made.
Safe Work Practices
The Paulsboro 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 opene
d, (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.
Management of Change
The Paulsboro Refinery has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology, 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 chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these chang
es. In addition, operating and maintenance personnel are provided any necessary training on the change.
The Paulsboro 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. 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 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.
To help ensure that the accident prevention program is functioning properly, the Paulsboro 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. The audit team develops a report of findings and recommendations. 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 Paulsboro Refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all covered processes at the Paulsboro Refinery. Collectively, these preven
tion 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 Paulsboro 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 features are used in various processes:
The refinery used computerized process controls, which provide capability to detect problems, which could lead to chemical releases. In addition, chemical leak detection is provided for specific hazards (HF&H2S) where appropriate.
Release Containment Control
The refinery employs various measures to contain accidental release of hazardous materials, as listed below.
Process relief valves that discharge to a flare to capture and incinerate episodic releases
Scrubber to neutralize chemical releases
Valves to permit isolation of
the process (manual or automated)
Automatic shutdown systems for specific process parameters
Vessel to permit partial removal of the process inventory in the event of a release
Curbing or diking to contain liquid releases
Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)
Atmospheric relief devices
The refinery employs various measures to mitigate accidental release of hazardous materials, as listed below.
Fire suppression and extinguishing systems
Deluge system for specific equipment
Trained emergency response personnel
Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)
FIVE-YEAR ACCIDENT HISTORY
The Paulsboro Refinery has an excellent record of accident prevention over the past 5 years. After many years of safe handling of hazardous materials, an operator recently experienced a chemical burn due to exposure to hydrofluoric acid. The operat
or sustained a burn to the hand after tearing his glove while repairing equipment. The refinery has experienced releases of noxious H2S, which produces offensive odors. These odors have extended into the surrounding community, and during one event, sickened an operator who sought medical treatment. None of the incidents that have occurred have resulted in harmful offsite effects. We investigate every incident very carefully to determine ways to prevent similar incidents from occurring.
EMERGENCY RESPONSE PROGRAM INFORMATION
The Paulsboro 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 procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. 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 Paulsboro 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 overall emergency response program for the Paulsboro Refinery is coordinated with the Greenwich Township Office of Emergency Management (OEM). This coordination includes periodic meetings with local emergency response officials, local government officials, and industry representatives. The Paulsboro 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 meetings, the Paulsboro Refinery conducts periodic emergency drills, which include participation of various local emergency response organizations. The refinery provides refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.
PLANNED CHANGES TO IMPROVE SAFETY
The Paulsboro Refinery strives to improve its safety performance at every opportunity. Each employee is encouraged to identify areas of weakness, and to make suggestions for improved safe performance. Safety performance is an integral part of all new processes, as well as modifications to existing units. Several major expansion projects that include various safety considerations are planned
for early 2000.