Murphy Oil USA, Inc. Meraux Refinery - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES |
The Murphy Oil USA, Inc. (Murphy) 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 monitor and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Murphy refinery, located in Meraux, Louisiana, operates a variety of processes to produce petroleum products (e.g., natural gas, propane, butane, and gasoline) from raw crude oil. The refinery has several regulated flammables, such as propane, butane, etc., as well as hydrogen fluoride (HF), which is a regulated toxic substance.
HAZARD ASSESSMENT RESULT
The worst-case scenario associated with toxic substances at the refinery is a catastrophic failure in the Alkylation Unit, resulting in a release of 525,000 lb of HF gas over a 10-min period. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures is taken into account in evaluating this scenario in accordance with the regulation. In addition, the HF acid storage drum, on which this scenario is based, is only filled to this capacity approximately once every 2 years. Thus, even if this unlikely event did occur, it is even more unlikely that the vessel would be as full as we have assumed. The maximum distance to the toxic endpoint of 20 ppm for this scenario is 25 miles according to the EPA's lookup tables.
The worst-case scenario associated with a release of flammable substances at the refinery is a vapor cloud explosion involving the full inventory of the largest storage ta
nk containing normal butane. No administrative controls are in place to limit the storage inventory in the tank; therefore, the full tank inventory of 1.7 million lb is assumed to release, completely vaporize, and ignite, resulting in a vapor cloud explosion. The maximum distance to the 1-psi overpressure endpoint for this scenario is 0.96 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 scenario in accordance with the regulation.
The alternative scenario for hydrofluoric acid is a rupture of an unloading hose downstream of a hydrogen fluoride (HF) tank truck, which leads to the release of HF to the atmosphere. The HF spills from the tank truck to the ground at a rate of 344 lb/min for the 1 min before the flow is stopped. This release rate is based on the normal unloading rate adjusted for the sudden decrease in the terminal point pressure. LPO
OL estimates that the HF forms a pool with a maximum area of 168 sq ft and evaporates at a maximum rate of 15 lb/min. HEGADAS estimates that the resulting cloud disperses downwind to the toxic endpoint of 20 ppm approximately 0.14 miles from the unloading area. The LandView III software program estimates a population of 160 people within this distance.
The alternative scenario for flammables is a rupture of a 1.5-inch diameter pipe connected to the high pressure receiver. We assume that it takes our operators 15 min to stop the release, even though they would likely complete this task much more quickly. In addition, we assume that all of the material released during the 15 min stays in the cloud and explodes. In reality, only a small fraction of the material would still be flammable after this amount of time. The maximum distance to the 1-psi overpressure endpoint for this scenario is 0.15 miles. Murphy has never experienced a release of this magnitude.
GENERAL ACCIDENTAL RELEAS
E PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program in place at the Murphy 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 Murphy 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 program. 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 a
nd 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 Murphy 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 response/exposure treatment considerations, is provided in mate
rial 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. The refinery has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the operating procedures for each process. 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 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 maintena
nce activities, as well as for evaluating proposed process and facility changes to monitor that safety features in the process are not compromised.
Process Hazard Analysis
The Murphy 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 the controls that are in place to manage these hazards.
The Murphy 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 suggestions for additional prevention and/or mitigation measu
res when the team believes such measures are necessary.
The PHA team findings are forwarded to local and corporate 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 attention first. 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 verify that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Murphy 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 a
nd retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.
The Murphy 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 revising them as necessary to reflect changes made through the management of change process.
In addition, the operating procedures at the Murphy refinery provide 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.
To complement the written procedures for process operations, the Murphy refinery has implemented a thorough training program for all employees involved in operating a process. New employees receive basic training in refinery operations if they are not already familiar with such 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) 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 verify 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.
The Murphy 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 Murphy refinery evaluates contr
actor 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 Murphy refinery conducts a PSSR for any 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.
The Murphy 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 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 identified, employees will correct the deficiency before placing the equipment back into service, or a management of change (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 Murphy refinery incorporates quality assurance measures into equipment purchases and repairs. This verifies 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 Murphy refinery has long-standing safe work practices in place to manage worker and process safety. Examples of these include (1) monitoring the entry/presence/exit of support personnel, (2
) a lockout/tagout procedure which requires 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 monitor spark-producing activities (i.e., hot work), and (5) a permit and procedure which requires 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 which promotes the safe performance of operations and maintenance activities.
Management of Change
The Murphy 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) verify that adequate controls are in place to mana
ge 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 appropriate training on the change.
The Murphy refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire, explosion, or toxic gas release, that caused 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 and 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.
To verify that the accident prevention program is functioning properly, the Murphy 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. Both hourly and management personnel 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. 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 Murphy refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the Murphy 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 Murphy refinery has safety features on many units to help (1) contain and control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safety features are used in various processes:
* Hydrocarbon detectors with alarms
Release Containment and Control
* Process relief valves that discharge to a flare to capture and incinerate episodic releases
to neutralize chemical releases
* Valves to permit isolation of the process (manual or automated)
* Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
* Vessel to permit partial removal of the process inventory in the event of a release (e.g., a dump tank)
* 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
* Fire suppression and extinguishing systems
* Deluge system for specific equipment
* Trained emergency response personnel
* Personal protective equipment (e.g., protective clothing, self-contained breathing
* Blast-resistant buildings to help protect control systems and personnel
FIVE-YEAR ACCIDENT HISTORY
The Murphy refinery has an excellent record of accident prevention over the past 5 years. In July 1995, a fire in the ROSE Unit injured one employe
e and caused damage to our facility; however, the fire did not lead to any offsite physical damage to property. In fact, no incident in the last 5 years led to offsite physical damage to property. One reason for our success at preventing accidents is that we investigate every incident very carefully to determine ways to prevent similar incidents from occurring.
EMERGENCY RESPONSE PROGRAM INFORMATION
The Murphy 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 postincident cleanup and decontamination requirements. In addition, the Murphy 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 Murphy refinery is coordinated with the St. Bernard Parish Office of Emergency Preparedness, the fire department, and the sheriff's office. This coordination includes periodic meetings of the committee, which includes local emergency response officials,
local government officials, and industry representatives. The Murphy refinery has around-the-clock communications capability with appropriate community officials and emergency response organizations (e.g., the fire department). This provides a means of facilitating quick response to an incident, as well as notifying the public of an incident if necessary. In addition to periodic local emergency planning committee (LEPC) meetings, the Murphy 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 Murphy refinery resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned:
The Meraux Refinery has recently purchased a 3000 gpm trailer mounted fire water pump. This equipment greatly en
hances emergency response efforts by giving personnel the mobility to produce high volumes of emergency response water nearer to potential incident sites.
Murphy Oil Meraux Refinery employees have recently completed twenty-four hours, three days, of annual fire fighting, HAZMAT and incident command refresher training. Sixty-six employees attended this training program. The training consisted of; chemistry of hazardous materials, incident command, dry chemical fire extinguishers, LPG fire suppression, flammable liquids fire suppression, fire fighting foam applications, Level "A" HAZ MAT simulated leak response, fire truck water hydraulics and application of Hired Gun, 2000 gpm nozzle.
Quarterly training for all emergency response team personnel will continue as usual. Quarterly training will consist of oil boom deployment, hazardous materials review, fire fighting hose handling, basic life support (CPR) and fire truck operations.