Williams Refining LLC - Executive Summary

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Williams Refining, Memphis, Tennessee 
Risk Management Plan (RMP) Executive Summary 
Williams Refining, located at 543 West Mallory Avenue, operates a variety of processes to produce high quality petroleum products from raw crude oil. The refinery has a thoroughly trained, experienced, safety-motivated workforce that has achieved an outstanding safety record. The refinery is in full compliance with the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard. 
Williams Refining has a longstanding commitment to worker and public safety. This commitment is demonstrated by the time, money, and effort invested in 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. Safety tools include engineering controls, real time process monitoring, level, pressure, and temperature alarms, leak detecti 
on systems, and automatic and manual mitigation systems. If a release does occur, our trained personnel will respond quickly and effectively to control and contain the release.  
To comply with the RMP standard we have focused upon the following:  
* Maintaining the management system established by PSM 
* Adapting the system to address RMP 
* Performing the hazard assessments 
* Compiling the data elements 
* Communicating with the public concerning RMP issues.  
All of the refinery process units are currently managed under the PSM standard. Therefore these processes are, in effect, being managed as RMP Program Level 3 processes. 
RMP threshold quantities of flammable mixtures containing Liquefied Petroleum Gases (LPG) such as propane, butanes, propylene, butylenes, etc. are present on site. In addition, a threshold quantity of hydrofluoric acid, an RMP-regulated toxic substance, is used on site. 
Public Communication of RMP 
Williams Refining assumed a leadership role in organizing a comm 
unity-wide RMP Symposium that took place April 13, 1999 at the Agricenter International. The Memphis-Shelby County Local Emergency Planning Committee (LEPC) was the lead agency in this effort. Williams Refining, 11 other area companies, and numerous federal, state, and local regulatory and emergency response agencies participated in the symposium. Each company or agency prepared a booth with informational literature and displays. Persons ready and willing to discuss RMP, safety programs, or answer public questions staffed the booths. Expert speakers, emergency response equipment, and live demonstrations of Shelter-in-Place and HAZMAT response were also featured. We estimate that 600 people attended the symposium. 
The refinery has been working with our Community Advisory Panel (CAP) to identify effective means for communicating RMP/safety information to our immediate neighboring community. CAP members have provided many helpful suggestions, and have offered to distribute our RMP-relate 
d printed materials at various venues in the community. Williams Refining and the CAP members agree that RMP/safety communication should be an ongoing effort. 
Hazard Assessment Results - Identification of Scenarios 
The toxic and flammable worst case scenarios for the refinery were relatively easy to identify. Hydrofluoric (HF) acid is the only covered toxic that is present in a threshold quantity. All HF in the refinery is in the Alkylation Unit. The largest inventory of RMP flammables is, by far, in the LPG spheres. 
Hydrofluoric Acid Release Scenarios and Off Site Consequence Analysis 
The EPA-defined toxic worst case scenario (WCS) at the refinery is a catastrophic loss of containment of the largest possible inventory of HF. All of our prevention and mitigation systems must be assumed to fail in this scenario. Weather conditions for the release must be assumed to be adverse to dissipation of the HF by wind, rain, or other action. The WCS for HF involves the simultaneous release of 
the maximum contents of all three storage tanks, about 163,000 lbs. total, over a 10-minute period. Such a release would create a vapor cloud that would travel in the direction of the wind. As the cloud traveled away from the site, it would become less concentrated and less harmful. The estimated maximum distance to the toxic endpoint of 20 ppm (0.016 milligrams per liter) for this WCS is 16 miles. Although we have numerous systems to prevent such releases and to mitigate their consequences, no credit for prevention or mitigation measures was taken into account in evaluating this scenario.  
The ARS for HF is a gasket leak under pressure that goes undiscovered for two hours. In that time about 5760 lbs. of hydrofluoric acid could escape. Upon discovery of the leak, a water stream would be used to remove acid vapors from the air. Although the release would spread in much the same way as in the worst case scenario, the quantity of the chemical released is much less. The estimated maximu 
m distance to the toxic endpoint of 20 ppm (0.016 milligrams per liter) for this ARS is 0.31 miles (1640 ft.), assuming that there was no breeze to quickly dilute the release. It is very unlikely that the release described above could go undetected for two hours. However, EPA requires that the alternative case release scenario (ARS) reach an offsite endpoint.  
Flammable Release Scenarios and Off Site Consequence Analysis 
The flammable WCS at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the two largest LPG storage tanks, containing Butanes/Butylenes (B/B) Mix. Because of the proximity of the two tanks, we reasoned that a catastrophic VCE from either of the tanks might cause a catastrophic failure of the other tank. Therefore, the WCS is estimated using the full inventory of both tanks combined. B/B Mix was chosen as the worst case flammable because this mixture has the greatest explosive energy of the LPG mixtures stored on site. Other LPG mixtures con 
tain propane, propylene, butane, isobutane, and butylenes in varying ratios. 
The EPA-defined flammable WCS at the refinery is a catastrophic loss of containment of the largest inventory of RMP-listed flammable in the refinery. All of our prevention and mitigation systems must be assumed to fail in this scenario. Weather conditions for the release must be assumed to be adverse to dissipation of the flammable gas by wind, rain, or other action. The full inventory of both tanks, about 10,200,000 lb., is assumed to release, completely vaporize, and ignite, resulting in a VCE. The estimated maximum distance to the 1-psi overpressure endpoint for this WCS is 1.8 miles. Although we have numerous controls to prevent such releases, no credit for prevention measures was taken into account in evaluating this WCS. 
The flammable ARS at the refinery is a VCE resulting from a 10-minute venting of B/B Mix through the 4-inch pressure relief valve atop the storage sphere. This pressure relief valve is 
set at 280 psi. In 10 minutes about 430,000 lbs. of B/B Mix could escape. The estimated maximum distance to the 1-psi overpressure endpoint for this WCS is 0.27 miles (1400 ft). The venting would be stopped by diverting process flow to a different LPG tank, or by opening a valve to another LPG tank. 
Five Year Accident History 
Williams Refining has an excellent record of accident prevention over the past 5 years. No incident has resulted in offsite effects (deaths, injuries, significant property damage, evacuations, shelter-in-place, or environmental damage) as defined by EPA's RMP guidelines (RMP-covered process and RMP-covered chemical). Two minor releases of HF have occurred, and two minor releases of LPG. Four minor releases have involved a LPG/HF mixture. Each incident was carefully investigated to determine the cause of the incident and actions to be taken to prevent similar incidents. All of these releases were detected and contained within the plant. The releases had no impac 
t on the community. Information concerning these minor releases has been submitted in the RMP data elements. 
General Accidental Release Prevention Program Steps 
The following is a summary of the accident prevention program in place at Williams Refining. RMP-regulated processes at the refinery are also subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard, therefore this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. 
The Safety and PSM Department oversees compliance with 29 CFR 1910.119, the Process Safety Management standard. The Department has developed a management system for satisfying the requirements of each of the fourteen elements that comprise the PSM standards. Where it is required, the system specifies a time frame for completion of the necessary action. The management system is intended to accomplish the following: 
* Describe  
the requirements of each paragraph of 1910.119 
* Describe how each requirement will be satisfied 
* Establish responsibilities for compliance action 
* Ensure that all compliance actions are documented 
In accordance with the employee participation requirements of 1910.119, The Memphis Refinery developed and implemented its PSM program with the active participation of team members from every level and department in the plant. As required, the program is audited periodically to evaluate its effectiveness. 
Employee Participation 
Paragraph (c) of the process safety management standard requires that employers actively solicit the involvement of employees in developing, implementing, and maintaining a PSM program, and that all information developed under this standard is available to their employees. 
* The PSM program was developed with the participation of employees from all levels and departments in the refinery. 
* Teams assembled for pre-startup safety reviews, HAZOPs, and incident inve 
stigations are composed of employees representing a broad spectrum of disciplines and experiences. 
* The Joint Health and Safety Committee meets monthly to address PSM and general safety issues. 
* Business Improvement Teams provide an avenue for consideration and discussion of safety, health, and environmental issues. 
* Operations Department writer/trainers bear PSM-related responsibilities and serve as liaisons between the Safety and PSM Department and other departments in the plant. 
* Employees may submit suggestions and comments directly to the PSM Department through the Employee Participation section of the PSM database. 
The Safety and PSM Department oversees the PSM effort. In general, each department is responsible for ensuring employee participation within the department. The management system policy for each PSM element identifies responsibilities that are more specific. 
Process Safety Information 
In accordance with paragraph (d), the Memphis Refinery is required to compile  
information pertaining to the hazards of highly hazardous materials used or produced at the facility, the technology of the processes, and the equipment used. The information must be readily available, and must be updated when changes are made, in accordance with management of change procedures. 
Williams Refining maintains a variety of technical documents that are used to facilitate safe operation of the processes. These documents address limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information.  
* Most process safety information required by the PSM standard is available in the PSM database located on the refinery local area network. For information not found in the database, a referral to its location is provided. 
* Manuals containing operating procedures and process unit descriptions are available online in the PSM database, and in hard copy at several locations. 
* Material safety data sheets for all products and chemica 
ls used or produced at the refinery are available from the PSM database. 
* Piping and instrumentation diagrams (P&IDs) for the entire plant are available at each process unit and in the shift foreman's office. 
* Documentation of pre-startup safety reviews, incident investigations, management of change, etc. is available online. 
The Safety and PSM Department oversees the generation, management, and tracking of PSM-related information. The appropriate department, such as operations, maintenance, or inspection handles specific types of information. 
Process Hazard Analysis 
Paragraph (e) of the PSM regulations requires periodic process hazard analyses of "covered processes." The Memphis Refinery conducts scheduled evaluations of the safety of all processes and related facilities within its boundary limits to ensure safe operation and prevent the catastrophic release of hazardous materials. Potential off site consequences are considered as part of this evaluation. 
The refinery uses the h 
azard and operability (HAZOP) method of analysis, within the framework of the HAZOP computer program in the PSM database. Each analysis is conducted by a cross-functional team and facilitated by someone familiar with both the refinery and HAZOP methodology. The team typically includes an operator from the covered process, a PSM writer, an engineer, maintenance and instrumentation personnel, and a supervisor. Other technical or supervisory personnel may sit in on the evaluation when their expertise is needed. 
As safety concerns are evaluated, they are rated according to probability and consequence. All are documented as part of the process. Those safety concerns that warrant action are formally documented as recommendations, and passed on to an individual or department that will be responsible for resolution. The Safety and PSM Department tracks recommendations until they are resolved. Reports and other documentation for the hazard analysis are accessible from the PSM database on the r 
efinery local area network.  
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, Williams Refining periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will continue until the process is no longer operating. The results and findings from these updates are documented and retained. Update team findings are forwarded to management for consideration. The final resolution of the findings is documented and retained. 
The Safety and PSM Department is responsible for scheduling HAZOPs, preparing the final HAZOP report, communicating the findings and recommendations to the appropriate departments, and for following up on recommendations to ensure their completion. Department managers ensure the participation of their employees on the HAZOP team. 
Operating Procedures 
As required by paragraph (f), the refinery has develope 
d and compiled a comprehensive set of operating procedures intended to provide instruction in the safe operation of refinery processes. Procedures must provide a reliable and consistent reference for all phases of process operations covering startup, shutdown, and normal, temporary, and emergency operations. Williams Refining 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.  
Writers from each process unit, the laboratory, and the tank farm develop the procedures. The writers draw upon the expertise of engineers, supervisors, and other operators when writing the procedures. Before it is authorized, each procedure is reviewed by supervisors, engineers, and management for accuracy, consistency, and completeness. In addition, each procedure is subject to editorial review to ensure readability. All ope 
rating procedures are available through the PSM database and in hard copy. Each procedure contains procedure steps, operating parameters and limits, safety and health hazard information, safety control measures, and assignment of responsibility for performing the procedure. Operating procedures are kept current by the refinery management of change process. 
Operations, Engineering, and the Safety and PSM departments bear responsibility for developing, reviewing, and approving operating procedures. The Operations Department is responsible for correctly implementing operating procedures.  
Paragraph (g) requires the employer to ensure that all refinery employees understand the safety and health hazards associated with operating and maintaining the refinery. This understanding is necessary to protect employees, the refinery, and the surrounding community. 
Williams Refining has implemented a comprehensive training program for all employees involved in operating a process. New em 
ployees first receive basic training in refinery operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) adequate knowledge to perform the duties and tasks in a safe manner, they can work independently.  
Employee training is an ongoing effort, and is carried out formally and informally, covering a variety of subjects. Depending upon the subject, training may be performed one-on-one, in a classroom setting, or using computer-based training modules. All training is documented and credited to the employee's personal record. Where required, employees are tested to document participation and to confirm the employee's understanding of the subject matter. Any employee may view his individual training record on the PSM database. 
The training program addresses: 
* Initial training, intended for new employees 
* OSHA-mandated trainin 
g for all employees, covering topics such as hazard communication, process chemistry, refinery terminology, etc. 
* Progression training for employees moving up in job classification 
* Refresher training for all employees, to cover new equipment and processes and to keep knowledge and expertise up-to-date. 
The Safety and PSM Department is responsible for implementing the training program. 
Paragraph (h) of the PSM standard specifies responsibilities of the employer (owner of the covered process) and the contract employer. A Contractor Safety Program was developed to satisfy and exceed these requirements. Williams Refining's Contractor Safety Program extends plant safety requirements to non-Williams employees working within the refinery. The Program is intended to maintain a plant-wide, consistent level of safe work performance. 
The Contractor Safety Program: 
* Requires contract bidders to provide information on accident rates and the contractor's safety program. 
* Require 
s the contractor to verify each employee's knowledge of job safety, craft skills, and equipment operation before the employee is assigned to onsite work. 
* Restricts bid requests to those contractors who have satisfied minimum requirements. Those requirements include a documented drug screening program, a comprehensive "Safety Action Plan," and English fluency for employees performing safety-sensitive work. 
* Establishes pre-job meetings, pre-job safety orientation conference, and site-specific orientation before actual work begins to ensure that the contractor and contract employees fully understand the safety policies and requirements of the Memphis Refinery. 
* Assigns ultimate responsibility to contractors for their employees' safety. Such responsibility covers maintaining safe work conditions, control of unsafe acts, holding safety meetings, and accident investigation. 
* Requires periodic audits to ensure that contractors are fulfilling their responsibilities under OSHA 1910.119. 

Establishes access control (card access system) for the process areas. 
The Safety and PSM Department is responsible for enforcing the Contractor Safety Program. Such enforcement involves not only the contractor's responsibilities, but also Williams Refining's obligations under paragraph (h) of the PSM standard. 
Pre-Startup Safety Reviews (PSSRs) 
Williams Refining conducts a pre-startup safety review (PSSR) any time new equipment or modifications to existing equipment change the process safety information pertaining to that equipment. The review is intended to verify and document that all aspects of the equipment's design, construction and operation have been evaluated, and to certify that the equipment can safely be placed in operation. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are prope 
rly implemented. The PSSR is the final step in the construction or installation of new or modified equipment before the equipment is placed in service. The review addresses: 
* Design and construction 
* Maintenance and inspection 
* Procedures 
* Training 
Under most circumstances, the lead engineer on the project is responsible for arranging and facilitating the PSSR, although any employee involved with the project may conduct the review. Participation in the PSSR depends upon the extent and complexity of the project. For large projects, process units for example, the PSSR team is composed of representatives from all involved departments. For small projects, such as the replacement of noncritical valves or pumps, an individual may conduct and document the review. 
Mechanical Integrity 
1910.119 (j) requires that employers must take specific measures to "maintain the ongoing integrity of process equipment."  These measures include written maintenance procedures, training in maintenance a 
ctivities, an inspection and testing program, safe and timely correction of equipment deficiencies, and quality assurance in fabrication, installation, and spare parts. The Memphis Refinery's mechanical integrity program accomplishes the following: 
* Establishes responsibility for various aspects of the mechanical integrity program, divided among three groups - mechanical, instrumentation/controls, and inspection. 
* Requires procedures for the management of each of the three mechanical integrity groups. The procedures must include a description of the group organization, standards for the development of procedures, a description of quality assurance measures, a written description of employee and contract employee training, a description of document controls, and requirements for periodic compliance audits. 
* Sets general operation and maintenance training requirements for maintenance employees. 
* Sets guidelines for the conduct and documentation of process equipment inspection and te 
* Requires safe and timely correction of equipment deficiencies. 
* Assures integrity and quality in the suitability, installation, and maintenance of equipment. 
The Maintenance and Engineering Departments are responsible for the administration of the mechanical integrity program of the Memphis Refinery. Responsibility for specific aspects of mechanical integrity rests with the appropriate group - mechanical, instrument/controls, or inspection. 
In addition, the Maintenance Planning Group administers the maintenance work order system. Work is performed under the supervision of a maintenance craft foreman. Operations and Safety Department personnel provide support to ensure that work is carried out safely. Technical support is provided by Process Engineering and the Engineering Project Group. 
Safe Work Practices 
Paragraph (k) of the PSM standard specifies permitting requirements for hot work (welding, cutting, etc.) on covered process equipment. Williams Refining has longstandi 
ng 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 prior to opening process piping or equipment, (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, help ensure that operations and maintenance activities are performed safely. 
The PSM database offers access to refinery Safe Work Practices and Refinery Safety Policies and Procedures. Both volumes were developed by the Safety and PSM Department in response to regulatory requirements and specific needs within the refinery. 
The Safety and PSM Department assumes overall respon 
sibility for the development and enforcement of Refinery Safe Work Practices and Safety Policies and Procedures. Front line enforcement of safe work practices is the responsibility of the area supervisors and craft foremen. Williams Refining expects each employee to exercise an appropriate degree of responsibility for his or her own safety, as well as the safety of his or her coworkers. 
Management of Change 
Any modification made in the refinery that necessitates a change in existing process safety information must go through a documented process of verification. The management of change (MOC) process is a system of checks and balances intended to ensure that each department involved in the planning, installation, and operation of the modified process has reviewed and approved the change. The process also ensures that all affected process safety information is updated to reflect the change, and that the safety of the modification has been evaluated before startup. 
The management of c 
hange process is initiated when an originator fills out an MOC form, which describes the change and provides justification for the project. The MOC form identifies and documents the following: 
* The technical basis for the change 
* The impact of the change on safety and health 
* The necessary revisions to process safety information 
* Completion of a pre-startup safety review 
* Approval from the appropriate departments 
The originator then secures approval from Maintenance and Engineering managers to proceed with the project. If the modification is a major upgrade to a process unit, a HAZOP study may be initiated. At this point, members of the HAZOP team may make recommendations to modify the original design or to correct safety concerns. Upon completion of the project, a pre-startup safety review is conducted. When all requirements have been met and all recommendations have been resolved, the new or modified equipment may be placed in service. 
Any employee may initiate the MOC proces 
s. Typically, the project or process engineer overseeing the change is responsible for verifying completion of the MOC process. Managers over the Operations, Engineering, Maintenance, and PSM departments must document their approval of the change by signing the MOC form. The Safety and PSM Department has ultimate responsibility for verifying that work has been completed, the appropriate approval has been granted, all process safety information has been updated, and that all required documentation is completed, thus closing out the MOC process. 
Incident Investigation and Event Notices 
29 CFR 1910.119(m) requires investigation of any incident "which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace." The policy of the Memphis Refinery is to promptly and thoroughly investigate PSM incidents, as well as events of a lesser nature. Personnel are required to report incidents or events to the area supervisor, or other pers 
on in charge, the same day that they occur. For each incident, the involved employee must fill out an event notice, which gives details concerning the incident.  The event notice is sent immediately to the Safety and PSM Department. Incidents involving contract employees are reported using the same guidelines as those for Williams employees. 
Events with potentially catastrophic consequences are PSM incidents, each of which is investigated. The refinery general manager, operations manager, or manager of Safety and PSM make the determination as to whether events classify as PSM incidents. Those individuals also establish the makeup of the investigation team, which should involve at least one member from Safety, the involved employee, and someone familiar with the process. A formal report is presented and distributed at the conclusion of the investigation. Each recommendation arising from the investigation will be assigned to a responsible individual, entered into the refinery's recommen 
dation tracking system, and followed until it is resolved. 
The Safety and PSM Department holds primary responsibility for administration of the event notice and incident investigation program. The Department ensures that investigations are conducted according to policy and that employees are appropriately involved in the investigation. 
Emergency Planning and Response 
The Memphis Refinery is required to establish and implement an emergency action plan to handle both large and small releases, to comply with federal law and to fulfill its responsibility to the community. The plan must meet the requirements for employee emergency and fire prevention plans found in 29 CFR 1910.38(a). 
The Memphis Refinery's Emergency Response Plan (ERP) contains specific procedures for prompt response to emergencies that impact property and personnel inside and outside the refinery. Refinery personnel developed the plan in cooperation with the United States Coast Guard, the Memphis Fire Department, the M 
emphis-Shelby County Emergency Management Agency, and other local officials. The plan specifies how the emergency is handled, including corrective procedures, coordination with outside response agencies, and communication with the public. 
Periodic compliance audits ensure that the plan is kept up-to-date. Copies of the plan are available at several locations, and an online version is accessible from the PSM database. 
The Environmental Department shares responsibility for the ERP with the Safety and PSM Department. Training required by the plan is conducted by the Safety and PSM Department. 
Compliance Audits 
The PSM standard requires that an employer conduct a compliance audit at least every three years to verify that their PSM program meets the regulatory standard. The Memphis Refinery conducts an audit at least once every three years. The self audit is conducted in accordance with the compliance guidelines and enforcement procedures in OSHA Instruction CPL 2-2.45A. The audit team  
includes at least one employee knowledgeable in the refinery and in the audit process. 
At the conclusion of the audit, the audit team submits a draft report to the refinery general manager for review. Upon acceptance and within 30 days, a final report is released to the general manager. Refinery management will return appropriate responses to each finding in the report, and will take steps necessary to correct any deficiencies detected by the audit. Upon resolution of the audit findings, the audit team and Safety and PSM manager sign the final report, certifying completion of the audit. As required by 29 CFR 1910.119(o), the Memphis Refinery retains the two most recent audit reports. 
The compliance audit is the responsibility of the Safety and PSM Department. 
Trade Secrets 
29 CFR 1910.119(p) requires employers to provide access to all information necessary to comply with the PSM standard to those persons responsible for compiling the information. Additionally, the employer is requi 
red to provide trade secret information that may be contained within a process hazard analysis, as specified in 29 CFR 1910.1200, the Hazard Communication standard.  
The Memphis Refinery withholds no information necessary for employees to safely carry out their assigned job tasks. However, refinery employees are required to enter into a confidentiality agreement as a condition of employment to protect trade secrets or other proprietary information. The confidentiality agreement may also be required of contractors or contract employees, if necessary. The Safety and PSM Department observes this policy in its development and administration of the PSM program. 
Recommendation Tracking 
PSM requirements for process hazard analyses, incident investigations, and compliance audits direct employers to develop some means of handling deficiencies discovered in the course of those activities. Additionally, there is a need to track MOC completion and pre-startup safety review issues. 
The Memphis  
Refinery has developed a tracking system to manage recommendations, MOC items, and other safety concerns arising as a result of PSM-related activities. Recommendations are handled similarly, regardless of their source. When a review team member makes a recommendation, it is recorded in the review documentation, and responsibility for evaluation and action is assigned. The recommendation is entered into the appropriate section of the PSM database. The team assigns a target date for resolution. The responsible individual then decides whether the recommendation is valid and requires action, or if no action is necessary. 
Safety and PSM Department personnel periodically review the status of the recommendation or MOC by performing a search in the PSM database. All aspects of recommendation tracking, from generation to resolution, are available for review, by any and all employees, in the PSM database. The database record may be searched according to: 
* Source of the recommendation 
* Unit o 
r location 
* Target date 
* Completion date 
* Status 
* Priority 
* Individual or departmental responsibility 
The Safety and PSM Department is responsible for administration of the recommendation tracking system. 
Chemical Specific Prevention Steps 
The processes at Williams Refining involve hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all RMP-covered processes at Williams Refining. Collectively, these activities help prevent potential accident scenarios that could be caused by equipment failure and/or human error. 
In addition to the accident prevention program activities, Williams Refining 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: 
Release Detection 
* Hydrocarbon detectors with alarms 
* HF detectors with alarms 
* H 
ydrogen Sulfide detectors with alarms 
Release Containment/Control 
* Process relief valves that discharge to a flare to capture and incinerate episodic releases 
* Valves to permit isolation of the process (manual or automated) 
* Emergency shutdown systems 
* Hydrofluoric acid dump tank 
* Curbing or diking to contain liquid releases 
* Redundant equipment and instrumentation 
* Atmospheric relief devices 
Release Mitigation 
* Fire suppression and extinguishing systems  
* Deluge system for Alky Unit 
* Trained emergency response personnel 
* Personal protective equipment  
* Blast-resistant buildings to help protect control systems and personnel 
Emergency Response Program Information 
Prevention is the best emergency plan. Refinery operations are always conducted to minimize the chance of encountering emergencies. When prevention fails, however, preparedness is the key to effective emergency response. The Memphis Refinery maintains a written emergency response plan to protect worker and publi 
c safety as well as the environment. The plan consists of procedures and guidelines for responding to various emergencies including release of a hazardous substance, fire or explosion. The emergency response program addresses the following: 
* Implementation of the Incident Command System (ICS) 
* Scope of incident - Level I vs. Level II 
* Level I incidents managed/controlled by the Area or Shift Supervisor 
* Level II incidents managed/controlled by the refinery General Manager. This level of incident will typically involve outside agencies such as the Memphis Fire Dept., Emergency Management Agency, U.S. Coast Guard, etc. A command center will be established as part of a Level II incident. 
* Responsibilities of personnel assigned emergency response duties. Duties are subdivided by the type of incident, the incident level, Incident Command positions, and pre-emergency, emergency, and post-emergency duties. 
* Written procedures are included for fire incidents, HAZMAT incidents, hydrofluo 
ric acid (HF) incidents, hydrogen sulfide incidents, and LPG incidents. 
* Fire incident procedures include sections for an exchanger fire, a process heater fire, and a pump fire. 
* HF, Hydrogen Sulfide, and LPG response procedures include properties/hazards of the substance, essential protective equipment, and first aid measures. 
* Guidelines for HAZMAT incidents, bomb threats, and civil disturbances. 
* Decontamination procedures 
* Incident communications tools 
* Evacuation plan and procedures to account for employees 
* Emergency alarms 
* Security 
* Emergency phone numbers such as 911, fire, police, ambulance, Coast Guard, hospitals, and doctors 
Employees receive annual training in PSM and emergency response. The emergency response program is updated whenever necessary due to changes in the refinery processes or refinery facilities. Any changes in the emergency response program are administered through the Management of Change (MOC) process, which includes informing affected personnel 
of the changes. 
The overall emergency response program for Williams Refining is coordinated with the Memphis-Shelby County Local Emergency Planning Committee (LEPC). This coordination includes monthly LEPC meetings, which consist of local emergency response officials, local government officials, and industry representatives. Williams Refining conducts periodic emergency drills that involve local, state, and federal emergency response organizations, and the refinery provides refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.  The refinery participates actively in the LEPC and maintains good relations with the Memphis Fire Dept. The refinery has 24-hour communications ability to notify appropriate emergency response organizations in the event of an emergency. Any public notifications will be coordinated through the Memphis-Shelby County Emergency Management Agency. 
Planned Changes to Improve Safety 
Williams Refining is comm 
itted to a high level of corporate citizenship, placing the highest priority on the safety of persons both within the refinery, and in the neighboring community. The Memphis Refinery strives to continually improve the safety program, and to reward employees for outstanding safety performance. To further emphasize safety awareness, the refinery has instituted a generous safety bonus incentive program for all refinery employees. 
Notes on RMP Information 
Possible inventories of RMP flammables in process units were estimated using a "conservative" technique that yields overstated process inventories. All of these processes are already managed under the OSHA PSM standard, which is essentially equivalent to RMP Program 3 management, regardless of estimated RMP flammables inventory. 
The sulfur recovery unit (SRU) was investigated to determine if a threshold quantity of hydrogen sulfide was present. The largest inventory of hydrogen sulfide in the refinery is found in the SRU. We determined 
that no threshold quantity of hydrogen sulfide was present in the SRU or elsewhere in the refinery. The PSM program addresses hydrogen sulfide hazards. 
The RMP Submit computer program generates a spurious error message relating to an ARS for hydrogen sulfide in the SRU (Process ID=10). Hydrogen sulfide is below the threshold limit, and therefore no ARS is required. 
RMP Submit generates a spurious error message stating that no chemicals are identified in the SRU (Process ID=10). No threshold quantity of an RMP-covered chemical is present in the SRU. 
RMP Submit generates a spurious error message relating to data element item 7.4.c for Process 6 under the Prevention Program 3 section. There were no PHA changes, therefore this field has appropriately been left blank.  
In the accident history data elements, release amounts are estimates. RMP Submit would not allow a value of less than one pound to be entered, so one pound was used to represent values of less than one pound. 
Release sc 
enario results were estimated using the RMPlanner software published by JBF Associates (now owned by ABS Group). The software calculates estimated distances to endpoint based on the Environmental Protection Agency (EPA) "Lookup" Tables.
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