Fina Oil and Chemical Port Arthur Refinery - Executive Summary |
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Executive Summary ('68.155) ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Fina Oil and Chemical Port Arthur 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 SUBSTANCES The Port Arthur Refinery, located in Port Arthur, TX, operates a variety of processes to produce petroleum products (e.g., natural gas, propane, butane, condensate) from raw crude oil. The refinery has several regulated flammables, such as propane, butane, etc. In addition, the refinery uses and/or processes chlorine and H2S, which a re also regulated substances. HAZARD ASSESSMENT RESULTS The worst-case scenario (WCS) associated with toxic substances in Program 3 processes at the refinery is a rupture of a one-ton chlorine cylinder, resulting in a release of 2,000 lb of chlorine over a 10-minute period. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating this scenario. The maximum distance to the toxic endpoint of 0.087 milligrams per liter for this WCS is 5.4 miles. No Program 1 or 2 processes containing regulated toxic substances were identified at the refinery. The alternative case scenario (ARS) for Chlorine is failure of the <" tubing. The tubing was sheared off), resulting in a release of 500 lb of Chlorine over a 60-minute period. The release is expected to be isolated by the operators ( active mitigation). No other mitigation measures were taken into accou nt in evaluating this scenario. The maximum distance to the toxic endpoint of 0.0087 milligrams per liter for this ARS is 0.30 miles. The WCS associated with a release of flammable substances in Program 3 processes at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing butane. No administrative controls are in place to limit the storage inventory in the tank; therefore, the full tank inventory of 1,898,628 lb is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is .99 miles. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this WCS. The ARS for flammable substances at the refinery is a VCE resulting from the release of butane from a pump failure (1,632,000lb released over a 60-minute period). The release is expected to be isolated by the operators within 60 minutes (active mitigation). The maximum distance to the 1-psi endpoint for this event is 0.63 mile. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Port Arthur 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. Employee Participation The Port Arthur Refinery encourages employees to participate in all facets 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 pr ogram. 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 under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. Process Safety Information The Port Arthur 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. Software summarizing the reference documents and their location 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 and emergency response exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the refinery has documented safety-related limits for specific process parameters (e.g., temperature, level, composition). 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 technic al 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 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 The Port Arthur 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 Port Arthur Refinery primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one o f 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 suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local management for resolution. 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 immediate attention. 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 Port Arthur 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 is documented and retained. Operating Procedures The Port Arthur 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 an d annually certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. In addition, the Port Arthur Refinery maintains documents that provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, the Port Arthur Refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees 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., thr ough tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training 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 understood the training. Contractors The Port Arthur Refinery uses contractors to supplement its work force during periods of increased maintenance or construction activities. 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 Port Arthur Refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) The Port Arthur 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. 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 properly implemented. Mechanical Integrity The Port Arthur Refinery has well-established practices and procedures 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, these activities form a system that maintains the mechanical integrity of the pr ocess 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 function as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, 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 Port Arthur Refinery incorporates qual ity 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. Safe Work Practices The Port Arthur 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 opened, (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 safe ly. Management of Change The Port Arthur Refinery has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), 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 changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The Port Arthur 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 (including contractors) 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. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Port Arthur Refinery periodically conducts an audit to determine whether the procedures and pract ices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. 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. 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 Port Arthur Refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA RMP-covered processes at the Port Arthur 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 Port Arthur Refinery has safety features on many units to he lp (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 7 Hydrocarbon detectors with alarms Release Containment/Control 7 Process relief valves that discharge to a flare to capture and incinerate episodic releases 7 Scrubber to neutralize chemical releases 7 Valves to permit isolation of the process (manual or automated) 7 Automated shutdown systems for specific process parameters (e.g. high level, high temperature) 7 Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank) 7 Curbing or diking to contain liquid releases 7 Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 7 Atmospheric relief devices Release Mitigation 7 Fire suppression and extinguishing systems 7 Deluge system for specific equipment 7 Traine d emergency response personnel 7 Personal protective equipment (e.g. protective clothing, self-contained breathing apparatus) 7 Blast-resistant building to help protect systems and personnel. FIVE-YEAR ACCIDENT HISTORY The Port Arthur Refinery has an excellent record of accident prevention over the past 5 years; the frequency of accidental releases has decreased. Fina Oil and Chemical does not have any accidental releases from regulated covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. EMERGENCY RESPONSE PROGRAM INFORMATION The Port Arthur 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 sub stance 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 postincident cleanup and decontamination requirements. In addition, the Port Arthur 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 Port Arthur Refinery is coordinated with the Port Arthur Local Emergency Planning Committee (LEPC). This coordination inc ludes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Port Arthur 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 Port Arthur Refinery conducts periodic emergency drills that involve the LEPC and emergency response organizations |