Chevron Products Co., Perth Amboy Asphalt Facility - Executive Summary |
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FEDERAL RMP EXECUTIVE SUMMARY CHEVRON PERTH AMBOY ASPHALT FACILITY 1. Accidental Release Prevention and Emergency Response Policies The Chevron Perth Amboy Asphalt Facility is committed to designing, operating and maintaining all of its processes in a safe and responsible manner. Chevron's Policy 530 - Protecting People and the Environment requires that the Chevron Perth Amboy Asphalt Facility: * Complies with all safety, fire, health and environmental laws or regulations without regard to the degree of enforcement. * Integrates safety, fire and health protection into every aspect of business activities. * Conducts scientific hazard and risk assessments, as needed, to identify, characterize, and safely manage any present or future potential hazards associated with Chevron's products and operations. * Encourages employees to initiate and maintain an open dialogue within Chevron and with the public or its agents regarding safety, fire, health, and environmental matters. This in cludes recognizing and responding as appropriate to community concerns about such matters. A combination of accidental release prevention and emergency response planning programs are used to help ensure the safety of our employees, the public and the protection of the environment. 2. Stationary Source and Regulated Substances The Chevron Perth Amboy Asphalt Facility covers an area of 368 Acres. It consists of several processes, the largest being the Crude Unit, which is located in an area designated as the Main Yard of the property. The crude unit is the only regulated process under RMP. The crude unit has a maximum rated design capacity of 80,000 barrels per day of crude oil and produces asphalt products using a variety of processing operations. Its main purpose is to distill, or split, crude into naphtha, distillate, vacuum gas oil and asphalt, all of which are sold. Regulated flammable gases and liquids are generated in the process. The flammable gases are used as fuel for t he process furnaces. The maximum quantity of regulated flammable materials in this process is calculated to be 15,000 lbs., which occurs only under upset conditions. The flammable materials contain methane, ethane, propane, butane, iso-butane, pentane and iso-pentane. Accidental release prevention programs and contingency planning efforts are in place to effectively manage the hazards that are posed to employees, the public, and the environment by the use of these flammable materials. 3. Key Offsite Consequence Analysis Scenarios The RMP regulation requires that information be provided about the worst-case release scenario for the regulated flammable materials at the facility. Worst-case Scenario - Regulated Flammable Materials The worst-case scenario (WCS) involves a vapor cloud explosion (VCE) of the entire contents of the stabilizer reflux vessel in the crude unit, which contains a flammable mixture of primarily ethane, propane, and butane. This vessel could contain up to 9 ,800 lbs. of this mixture if completely full. This material is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to a 1-psi overpressure endpoint is 910 feet based on the EPA's Offsite Consequence Analysis Guidance document. No public receptors are located within the exposure distance. Although there are numerous controls in place to prevent such releases, no credit for mitigation was taken into account in evaluating this WCS. Some measures that are employed to reduce this exposure distance include level controls that maintain the vessel at 50% full or lower. In addition, a relief valve would vent excess material to a flare system in the event of over pressure. Regular inspections and maintenance on the vessel also help prevent a release from occurring. This Worst-case scenario information is used to help ensure that both the facility emergency response plan and the community emergency response plan address all reasonable contingency case s. 4. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps A systematic, proactive approach is taken to prevent accidental releases of hazardous chemicals. This involves visual inspections (daily, monthly, bimonthly, annual, etc.), maintenance and training programs. The facility's management systems address each of the key features of successful prevention programs, which include: Process Safety Information Process Hazard Analysis Standard Operating Procedures Environmentally Hazardous Substances (EHS) Operator Training Mechanical Integrity / Preventive Maintenance Management of Change Pre-Startup Safety Review Compliance Audits Environmentally Hazardous Substances (EHS) Accident Investigation Employee participation Hot Work Permits Contractors These individual elements of our prevention program work together to help prevent accidental chemical releases. The facility and its employees are committed to the standard that the se management systems set for the way business is conducted, and there are specific accountabilities and controls to ensure that the company's own high standards for accident prevention are met. The following is a summary of the general accident prevention program in place at the Chevron Perth Amboy Asphalt Facility. Because the process regulated at this facility by the RMP regulation is 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. 4.1 Process Safety Information The Chevron Perth Amboy Asphalt Facility keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific process areas within the facility are assigned the responsibility for maintaining up-to-date process safety information. A documentation table summarizing the reference documents and their location is readily available (under the Management System), 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 and exposure treatment considerations, is provided in material safety data sheets (MSDSs) maintained at the facility. For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in an Area Operating Manual/Procedures. The facility 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 facility also maintains numerous technical documents that prov ide 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 personnel training, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that process safety features are not compromised. 4.2 Process Hazard Analysis (PHA) The Chevron Perth Amboy Asphalt Facility has a comprehensive program to help ensure that hazards associated with the covered process are identified and controlled. Within this program, the process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The facility primarily uses the PHA Hazard and Operability Study (HAZOPS) methodology to perform this evaluation. HAZOPS analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analysis is conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The team identifies and evaluates hazards of the process, accident prevention and mitigation measures, operability and improvement measures, and makes suggestions for additional prevention and/or mitigation measures where the team believes such measures are necessary. The PHA team findings are forwarded to management for review and then assigned to specific individual(s) 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 addressed and receive target dates for completion. They are then tracked to resolution. The resolution of each finding is documented and retained for the life of the process. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Chevron Perth Amboy Asphalt Facility periodically updates and revalidates the hazard analysis results. Periodic revalidation is conducted at least every 5 years for the life of the process. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration and the resolutions of the findings are documented and retained. 4.3 Standard Operating Procedures (SOP) The Chevron Perth Amboy Facility maintains written procedures that address various modes of process operations, such as (1) emergency procedures, (2) normal procedures including normal start-ups and shutdowns, and (3) temporary procedures. The procedures contain and address consequences of deviation from safe uppe r and lower limits. Safety and health considerations are addressed in all developed procedures. The procedures are also used as a reference by experienced operators and provide a basis for refresher training and the 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 Area Operating Manual/Procedures provide guidance on how to respond to safe 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. 4.4 Extraordinarily Hazardous Substances (EHS) Operator Training To complement the written procedures for process operations, the Chevron Perth Am boy Asphalt Facility has implemented a comprehensive training program for all employees involved in the operation of a process. New employees receive basic training in plant operations. After successfully completing initial training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests and skills) adequate knowledge to perform the duties and tasks in a safe manner, they can work independently. In addition, all operators receive refresher training to ensure that their skills and knowledge are maintained at an acceptable level. Management consults with employees involved in operating processes to determine appropriate refresher training. This refresher training 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. 4.5 Mechanical Integrity / Preventive Maintenance Program The Chevron Perth Ambo y Asphalt Facility has practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, standby emergency equipment, electrical grounding systems, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training with affected employees/contractors, (2) developing written maintenance procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. Records of mechanical integrity and preventive maintenance activities are maintained. 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 t heir job in a safe manner. Written maintenance 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). The addition of a new process or modifications to an existing process and/or equipment is handled through the Management of Change (MOC) process to ensure the integrity of the equipment. If a deficiency is identified during the Pre-Startup Safety Review (PSSR) of the equipment, employees will correct the deficiency using the MOC/PSSR process. Another integral part of the mechanical integrity program is quality assurance. The facility incorporates quality 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. Monitoring mechanical integrity inspections and established deterioration rates determine the schedule or frequency of maintenance on all equipment. In addition, operational performance and Chevron's equipment inspection guidelines are used to determine preventive maintenance frequencies. The facility also follows a consistent maintenance schedule. 4.6 Management of Change (MOC) The Chevron Perth Amboy Asphalt Facility 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 inf ormation, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel affected by the change are provided with any necessary training on the change. If the change results in an increase in the rate, duration, quantity or frequency of a potential EHS release, a risk assessment is performed to determine if the release has significant offsite impacts. 4.7 Pre-Startup Safety Reviews (PSSR) The Chevron Perth Amboy Asphalt Facility conducts a PSSR for new facilities or facility modifications that require changes in the process safety information. The purpose of the PSSR is to ensure that safety systems, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment in service. This review provides a final 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 and document the aspects of readiness. A PSSR ensures that all pre-startup requirements of the MOC process have been met prior to start-up. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly in place and implemented. 4.8 Compliance Audits To help ensure that the accident prevention program is functioning properly, the Chevron Perth Amboy Asphalt Facility periodically conducts a compliance 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 reports of the audit methodologies and findings, which are forwarded to management for resolution. Corrective actions taken in response to the audit team's findings are tracked to completion. The resolution of each finding is documented, and the two most recent audit reports are retained. 4.9 EHS Accident Investigation The Chevron Perth Amboy Asphalt Facility promptly investigates (within 48 hours) all incidents that resulted in, or reasonably could have resulted in, a fire or explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to gather the facts, 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 assigns responsibility for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affec ted by the findings. Incident investigation reports are retained for at least 5 years. The reports are reviewed during PHAs and PHA revalidations. 4.10 Employee Participation The Chevron Perth Amboy Asphalt Facility encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from reviewing, updating and compiling technical documents and chemical information to participating as members of process hazard analysis (PHA) teams. Employees have access to all information created as part of the facility accident prevention program. Specific ways that employees are involved in the accident prevention program are documented in an employee participation plan that is maintained at the facility and addresses each accident prevention program element. In addition, the facility has a number of initiatives under way that address process and employee safety issues. These initiatives include an Incident Free Operat ion Committee, (IFOC) that besides other duties, encourages the formation of Quality Improvement Teams, QIT's, to promote both process and personal safety. The teams typically have members from various areas of the facility, including operations, maintenance, and management. There are also several programs that encourage and recognize employees for participation in process and personal safety issues. 4.11 Hot Work Permits (Safe Work Practices) The Chevron Perth Amboy Asphalt Facility 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, and exit of support personnel, (2) lockout/tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures 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 en sure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 4.12 Contractors The Chevron Perth Amboy Asphalt Facility uses contractors to supplement its workforce Because some contractors work on or near process equipment, the facility 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 facility personnel of any hazards that they find during their work. This is accomplished by providing contractors with a process overview, information about safety and health hazards, emergency response plan requirements, and safe work practices prior to thei r beginning work. In addition, the facility evaluates contractor safety programs and performance during the selection of a contractor. Operations personnel continuously monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Through the MOC process, contractors are made aware of and trained on any changes or modifications made to the process equipment that may affect them. 5. Chemical Specific Prevention Steps The processes at the Chevron Perth Amboy Asphalt facility have hazards that must be managed to ensure continued safe operation. The accident prevention program helps 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 facility has safety features on many units to help (1) contain and/or control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safety feat ures are used in various processes: 5.1 Release Detection * High liquid level detectors with alarms * High pressure detectors and alarms * Gas/vapor release detectors with alarms 5.2 Release Containment and Control * Process relief valves that discharge to a flare system to capture and incinerate episodic releases * Valves to permit isolation of the process (manual or automated) * Automated shutdown systems for specific process parameters (e.g., high temperature) * Vessels to permit the partial removal of the process inventory in event of a release * Curbing or diking (secondary containment) to contain liquid releases * Redundant equipment and instrumentation (e.g. uninterruptible power supply for process control system, backup firewater pump) 5.3 Release Mitigation * Fire suppression and extinguishing systems * Deluge system for critical equipment * Highly trained operators to handle incipient situations * Personal protective equipment (e.g., protective clothing, self -contained breathing apparatus) * Blast-resistant building to help protect control systems and personnel 6. Five-year Accident History Records are kept for all accidental chemical releases that occur at the facility. There have been no accidental releases of regulated or extremely hazardous substances (EHS) with onsite or offsite impacts (as defined in 40 CFR 68.42) from the process covered under the RMP rule during the past five years (as defined in 40 CFR 68.42). If an accidental release does occur, formal investigations will be conducted to identify and correct the root causes of the events. 7. Emergency Response Program The Chevron Perth Amboy Asphalt Facility maintains a written emergency response program, which is in place to protect employees, the public, as well as the environment. Copies of the facility's Preparedness, Prevention and Contingency Plan (PPCP) have been provided to the Perth Amboy Office of Emergency Management (PA OEM) and other organizations. The prog ram consists of procedures for responding to the accidental release of a regulated substance, including the possibility of a fire or explosion if it involves a flammable substance. 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 required, post-incident cleanup and decontamination requirements. In addition, the facility 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 plant processes. Changes in the emergency program are administered through the MOC process, which includes informing and/or training affected personnel on the changes. The overall emergency response program for the Chevron Perth Amboy Asphalt Facility is coordinated with the Perth Amboy Fire Department and the Perth Amboy Office of Emergency Management (OEM). The facility also sends a copy of its annual chemical inventory to the OEM and other organizations (under the New Jersey 'Right-to-Know' Act) and has around-the-clock communications capability with appropriate OEM officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an EHS accident, as well as facilitating quick response to an accident. In addition to periodic OEM meetings, the facility conducts periodic emergency drills that involve the OEM and emergency response organizations. The facility has in the past, also sponsored annual refresher fire fighting training courses for the members of the Perth Amboy Fire Department. 8. Planned Changes to Improve Safety The Chevron Perth Amboy Asphalt Facility continuously strives to resolve all findings from Process Hazard Analyses, some of which result in modifications to the process. The following is a list of improvements planned or implemented at the facility to further help prevent and/or better respond to accidental chemical releases: * Decrease in process inventory involving extremely flammable material at the Crude Unit (maintain vessel volume at 50% or below) * Improved liquid level detection systems in the Crude Unit. * Improved design of written operating procedures for the Crude Unit process is in progress * Review and update Safe Work Practices (Marketing Operating Procedures, MOPs) * Update/improve procedures in the facility's Preparedness, Prevention and Contingency Plan (PPCP) document * Added guard for additional security and evacuation * Upgrade Incident Command Center * Implement behavior based safety programs (Loss Prevention System) |