Trainer Refinery - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES |
The Trainer Refinery has a standing commitment to worker and public safety. This commitment is demonstrated by the resources and efforts expended in accident prevention, including compliance with the requirements of OSHA's Process Safety Management (PSM) program. Management systems are in place at the Trainer Refinery to ensure safety is incorporated into the design, installation, operation, inspection, and maintenance of our processes. Our accident prevention program includes maintaining updated operating procedures and practices as well as extensive personnel training on safety. We also have highly trained and well-qualified emergency responders onsite 24 hours a day ready to respond to control and mitigate an incident should one occur.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Trainer Refinery located in Trainer, PA processes raw crude oil into gasoline and other refining products including jet fuel,
diesel fuel, heating oil, heavy fuel oil, liquefied petroleum gas (LPG), and sulfur. The LPG products consist of butane and propane which are both regulated flammable substances. The refinery produces and/or uses other regulated flammables, such as hydrogen, methane, ethane, pentane, etc. In addition, the refinery uses and/or processes hydrofluoric acid, ammonia, and hydrogen sulfide which are regulated toxic substances.
HAZARD ASSESSMENT RESULTS
The worst-case scenario (WCS) associated with toxic substances is failure of a storage vessel resulting in the release of its entire content of anhydrous hydrofluoric acid with no administrative controls in place and the unit shut down for maintenance. Approximately every 3 to 4 years, the entire unit's inventory of acid is transferred into this vessel for about 30 days until the maintenance is completed. In evaluating this WCS, the numerous safeguards and passive mitigation that are in place to prevent a release and to minimize any con
sequences were not taken into account. The results of the WCS indicate that such a release would result in offsite impacts to public and environmental receptors.
The alternative release scenario (ARS) for hydrofluoric acid is a failure of a small diameter drain valve on a suction line of a pump. A quantity of acid could be released over a 10-minute period before the operators isolated the leak. The elevated water deluge towers would be activated remotely to knock down vapors. The resulting vapor cloud could reach an offsite endpoint and nearby public receptors. This event was selected as a more realistic scenario for use in emergency response planning with the community.
Two (2) worst-case scenarios (WCS) were developed for flammable substances since these scenarios potentially affect different public receptors.
The first WCS for flammable substances is a vapor cloud explosion (VCE) involving the full inventory of a sphere containing a flammable mixture composed primarily of
propane. Although there are numerous controls in place to prevent such releases and to control and mitigate their consequences, no administrative controls were taken into account in evaluating this WCS. Therefore, the full vessel inventory is assumed to release, completely vaporize, and ignite, resulting in a VCE. The VCE would result in offsite impacts to public receptors.
The second WCS for flammable substances is a vapor cloud explosion (VCE) involving the full inventory of a sphere containing a flammable mixture composed primarily of butane. Although there are numerous controls in place to prevent such releases and to control and mitigate their consequences, no administrative controls or passive mitigation was taken into account in evaluating this WCS. Therefore, the full vessel inventory of is assumed to release, completely vaporize, and ignite, resulting in a VCE. The VCE would result in offsite impacts to public receptors.
The alternative release scenario (ARS) for fl
ammable substances involves a release of a flammable mixture composed primarily of propane from a relief valve on a storage sphere, which if ignited would result in a flash fire. A quantity of propane could be released over a 30-minute period before the operators isolated the release. The flammable vapor cloud could reach an offsite endpoint and public receptors. This event was selected as a more realistic scenario for use in emergency response planning with the community.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program in place at the Trainer 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.
The Trainer Refinery encourages employees to participate in all facet
s 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 as well as incident/near miss investigations. Information on the refinery's accident prevention program is available to all employees and they are encouraged to suggest improvements to any of the programs. 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 to address process safety and employee safety issues. These activities include committees to promote and address both process and personal safety such as the Joint Management Labor Health & Safety Committee, Safe Operations Committee, and PSM subcommittees. The committees ty
pically consist of members from a broad cross-section of the refinery, including operations, mechanical, technical and plant management.
Process Safety Information
The Trainer 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, safe limits of critical and key process parameters, specific chemical inventories, and equipment design basis/configuration information. A table summarizing the reference documents and their location, and updating procedure is readily available as part of the written employee participation plan to help employees locate any necessary process safety information.
Chemical-specific information, including exposure hazards, chemical reactivity/stability hazards, and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process units and operations, the refinery has documen
ted safety-related limits for specific critical operating and key process parameters (e.g., temperature, pressure, level, and composition) as part of procedures for normal operations. 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 including piping and instrumentation diagrams 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 comprom
Process Hazard Analysis
The Trainer Refinery has a comprehensive program to identify and control 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 Trainer 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 highly experienced people who have operating, engineering, and safety expertise. 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 when the team believes such measures are necessary.
The PHA team findings are forwarded to refinery management for resolutio
n. Implementation of mitigation options 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 priority attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete or resolved. 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, Trainer Refinery periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years. 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 is documented and retained.
The Trainer Refiner
y maintains written procedures that address various modes of process operations, such as (1) normal operations that provide guidance on corrective actions to be taken when responding to upper or lower limit exceedances for critical operating and key process parameters, (2) temporary operations, (3) normal shutdown, (4) emergency shutdown, (5) unit startup and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators for refresher training purposes and provide a basis for consistent training of new operators.
The procedures are maintained and updated by the unit operating personnel to reflect comments from users and changes made through the management of change process. The procedures are reviewed annually to ensure they are current and accurate. Written operating procedures are readily available to all personnel to use as necessary to safely perform their job tasks.
To complement the written procedures for process operati
ons, the Trainer Refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees receive fundamental training in refinery operations. After successfully completing this training, a new operator receives unit-specific training. This training provides the skills and knowledge required to perform the duties of a specific job in operations, and is provided to both New Hires who complete Fundamentals, as well as incumbent operators who are cross training on other jobs. Job specific training provides detailed instruction on the process and process equipment. This phase of training includes hands-on demonstrations (or simulations) of start-up, shutdown and emergency operating procedures. It also includes the review and practice of routine, job-specific tasks performed by the operator (e.g. drawing and testing samples).
After operators demonstrate (e.g., through tests & skills demonstration) having adequate knowledge to perfor
m the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically review operating procedures and safe work practices so that their skills and knowledge are maintained at an acceptable level. Performance-based refresher training on critical tasks is conducted at least every 3 years. Training is documented for each operator, including the means used to verify that the operator understood the training.
The Trainer Refinery uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because most contractors work on or near process equipment, the refinery has procedures in place so 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 refiner
y 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 refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel and/or Contractor safety personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Reviews (PSSRs)
The Trainer Refinery conducts a PSSR for new facilities or facility modifications 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. Depending upon the complexity and the hazard potential associated with the new or modified facility, one (1) of three (3) levels of PSSRs are conducted. Checklists are utilized to verify all aspects of startup readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
The Trainer Refinery has well-established practices/procedures and uses original equipment manufacturers' (OEM) instructions 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. In combination, the
se 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 instructions for maintenance of equipment, (4) refinery's emergency response plan, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written instructions and practices 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 identified, the necessary actions are taken to address the deficiency.
Another integral part of the mechanical integrity program is quality assurance. The Trainer Refinery incorporates quality assurance measures into equipment purchases and repair
s. 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.
Safe Work Practices
The Trainer Refinery has long-standing safe work practices in place for worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel who enter process areas, (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. These procedures (and others), along with training of affected personnel, form a system so that operations and maintenance activities are performed safely.
Management of Change
The Trainer Refinery has a comprehensive syst
em to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, and other facility changes be reviewed and authorized before being implemented. Changes that are strictly procedural in nature are managed in a separate program. All changes are reviewed to (1) determine that adequate controls are in place to manage and control any new hazards and (2) verify that existing safeguards have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, process and instrumentation diagrams, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change prior to its startup.
The Trainer Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environm
ental loss, or personal injury. The goal of each investigation is to determine the root cause 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. The investigation team's recommendations are tracked until they are resolved. The final resolution of each recommendation is documented, and the investigation results are reviewed with all employees (including contractors when appropriate) who could be affected by the findings. The results of the investigation are retained for at least 5 years so that they can be reviewed during future PHAs and PHA revalidations.
To help the accident prevention program to function properly, the Trainer Refinery conducts periodic audits to determine whether the procedures and practices required by the accident prevention program are b
eing implemented. Compliance audits are conducted at least every 3 years. Employees 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.
CHEMICAL-SPECIFIC PREVENTION STEPS
The processes at the Trainer Refinery have hazards that must be managed for continued safe operation. The accident prevention program summarized previously is applied to all our Program 3 EPA RMP-covered processes at the Trainer Refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors.
In addition to the accident prevention program activities, the Trainer Refinery has safety features on units to help (1) detect a release, (2) contain/control a release, and (3) reduce the consequences of (mitigate) a release. The following t
ypes of safety devices are used in various processes throughout the refinery to help prevent incidents:
7 Chemical specific sensitive paint used to detect leaks at joints
7 Hydrocarbon and chemical specific detectors with alarms
7 Video camera surveillance for detecting a chemical specific release
7 VOC monitoring program
7 Process relief valves that discharge to a flare
7 Relief gas scrubber for chemical neutralization
7 Valves to permit isolation and/or depressuring of the process or a portion of the process (manual, automated, and remotely operated)
7 Automated shutdown systems for specific process parameters (e.g., high level, high temperature, high pressure)
- Emergency shutdown system
7 Vessel to permit rapid removal of the process acid inventory in the event of a release (i.e., dump vessel)
7 Curbing or diking to contain liquid releases
7 Redundant critical equipment and instrumentation (e.g., uninterruptibl
e power supply for process control system, backup firewater pumps)
7 Check valves for limiting flow in one direction
7 Fire suppression and extinguishing systems
7 Water deluge and sprinkler systems for specific equipment
7 Highly trained emergency response personnel on duty 24 hours a day
7 Mutual aid emergency response
7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)
FIVE-YEAR ACCIDENT HISTORY
During the past 5 years only one incident occurred at the Trainer Refinery involving a release of a regulated substance that meets RMP reporting requirements. Two employees were injured when they came in contact with hydrofluoric acid on December 22, 1997. The total quantity of hydrofluoric acid released was less than 1 gallon. This incident did not result in offsite effects. A formal incident investigation was conducted and revisions to accident prevention procedures were made to prevent similar incidents from occ
EMERGENCY RESPONSE PROGRAM INFORMATION
The Trainer 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 if a release occurs, and post incident cleanup and decontamination requirements. In addition, the Trainer 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 emergency response program for the Trainer Refinery is coordinated with the Delaware County, PA, 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 Trainer 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 Tra
iner Refinery conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.
PLANNED CHANGES TO IMPROVE SAFETY
The Trainer Refinery emphasizes continuous improvement to augment and strengthen its accident prevention program. Many of the safeguards have already been instituted and are in place to prevent an accidental release as well as to mitigate or minimize its impact should one occur. Other safeguards and safety devices will be installed as they are developed as part of the ongoing effort to enhance the overall safe operation of the Trainer Refinery.
Year 2000 (Y2K) Preparedness: Tosco Corporation and the Trainer Refinery have developed Y2K Task Forces to investigate, develop, and implement plans to minimize any disruption from possible Y2K issues. Computer software and hardware systems are being revi
ewed for Y2K compliance, and contingency pre-plans are being developed to address any potential in-plant or supplier system failures.