Borger Refinery and NGL Center - Executive Summary |
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BORGER REFINERY AND NGL CENTER RISK MANAGEMENT PLAN EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Borger Refinery and NGL Center has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training and consideration of 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 and have the ability to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Borger Refinery and NGL Center, located in Borger, Texas, operates a variety of processes to produce motor fuels, heating oils and solvents. The NAICS Code is 32411. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevent ion program in place at the Borger Refinery and NGL Center. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject to the OSHA Process Safety Management (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 Borger Refinery and NGL Center encourages employees to participate in all facets of risk management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information, participating as members of audit teams, 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 the Borger Refinery and NGL Center Employee Safety Process man ual and the Process Safety Management manual. Employee participation is a key element in Phillips Petroleum's Process for Safety and Environmental Excellence, for which goals are set, tracked and reviewed on a semi-annual basis. In addition, the refinery has a number of initiatives under way that address process failures, process safety and employee safety issues. These initiatives include forming teams including; Root Cause Failure Analysis, Total Involvement Committee and PSM committee. In addition, a hazard reporting system has been developed and administered by hourly personnel to identify, report and track employee reports of specific safety hazards. Two key areas for employee participation include the employee behavioral safety process and OSHA's Voluntary Protection Program. POWER, People Observing Work Eliminating Risks, is an employee driven process designed to eliminate behaviors, which could result in employee injuries. The OSHA VPP Steering committee is a group of hou rly and management personnel working toward having the site obtain VPP STAR status. An OSHA VPP site inspection team is scheduled for a site visit and walk-thru mid summer 1999. Induction of the plant into the OSHA VPP STAR program will take place as soon as the VPP team items are resolved. PREVENTION PROGRAMS Process Safety Information The Borger Refinery and NGL Center keeps a variety of technical documents that are used to 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. Process safety information reference documents are 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, emergency response medical treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, the refinery has documented safety related limits for specific process parameters (e.g., temperature, level, composition) in the unit specific Process Safety Information (PSI) document. 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 Borger Refinery and NGL Center 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 a nd 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 Borger Refinery and NGL Center 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 Borger Refinery and NGL Center 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 and risk 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 when the t eam 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 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. All findings are resolved within 2 years. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Borger Refinery and NGL Center 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 r esults 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 Borger Refinery and NGL Center 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 revisiting them as necessary to reflect changes made through the management of change process. Unit emergency drills are conducted regularly to evaluate emergency procedures. In addition, the Borger Refinery a nd NGL Center maintains a Process Safety Information document 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 Borger Refinery and NGL Center has implemented a comprehensive 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 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 Borger Refinery and NGL Center 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 plant personnel of any hazards that they find du ring 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 Borger Refinery and NGL Center evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance, through audits and regular work site visits, to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSR's) The Borger Refinery and NGL Center 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 const ruction 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 Borger Refinery and NGL Center 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. Mainten ance 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 (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 Borger Refinery and NGL Center incorporates quality assura nce 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 Borger Refinery and NGL Center 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 in operating areas, (2) a lockout/tagout procedure 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 open flame or spark-producing activities (i.e., hot work), (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space and (6) a Safe Work Checklist procedure which requires operations to positively identify the equipment to be worked on, the hazards of the materials which could be present and the hazards associated with the process which is still in operation. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Borger Refinery and NGL Center 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 maint enance personnel are provided any necessary training on the change. Incident Investigation The Borger Refinery and NGL Center 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 plant 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 ret ained 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 Borger Refinery and NGL Center periodically conducts self-audits to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance self-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 plant 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. Additionally, The Borger Refinery and NGL Center is the subject of a Corporate Safety and Health compliance audit. The audit, which includes OSHA's PSM elements, also includes a n extensive look at risk management systems. The audit is conducted by a team of safety and other element specialists from other Phillips facilities to ensure an independent audit. The facility is also the subject of third-party fire insurance audits, internal employee perception and industry safety management system audits conducted by Phillips and non-Phillips personnel. The Process for Safety and Environmental Excellence In addition to the OSHA PSM elements described above, the Borger Refinery and NGL Center incorporates the elements of Phillips Petroleum's Process for Safety & Environmental Excellence, and OSHA's Voluntary Protection Program to form a complete Health, Environmental and Safety (HES) system, which can involve more employees and well defines each employee's roles and HES responsibilities. The elements of these two management processes are: OSHA VPP ELEMENTS (VOLUNTARY PROTECTION PROGRAM) PSEE ELEMENTS (PROCESS FOR S/E EXCELLENCE) VPP (1) MANA GEMENT COMMITMENT AND PLANNING PSEE (1) ROLES AND RESPONSIBILITIES VPP (2) ACCOUNTABILITY SYSTEMS PSEE (2) TRAINING VPP (3) DISCIPLINARY PROGRAM PSEE (3) INDUSTRIAL HYGIENE & HEALTH VPP (4) INJURY RATES PSEE (4) EMPLOYEE OWNERSHIP VPP (5) EMPLOYEE PARTICIPATION PSEE (5) BEHAVIOR MODIFICATION VPP (6) SELF INSPECTIONS PSEE (6) STANDARDS & PROCEDURES VPP (7) EMPLOYEE HAZARD REPORTING SYSTEMS PSEE (7) ENGINEERING DESIGN VPP (8) ACCIDENT/INCIDENT INVESTIGATION PSEE (8) MEASUREMENT VPP (9) JSA/PROCESS REVIEW PSEE (9) AUDITS VPP (10) SAFETY & HEALTH TRAINING PSEE (10) CONTRACTOR PERFORMANCE VPP (11) PREVENTATIVE MAINTENANCE PSEE (11) INCIDENT INVESTIGATION VPP (12) EMERGENCY PROGRAMS/DRILLS PSEE (12) RISK MANAGEMENT VPP (13) PERSONAL PROTECTIVE EQUIPMENT PSEE (13) MECHANICAL & OPERATING INTEGRITY VPP (14) HEALTH PROGRAMS PSEE (14) COMMUNITY INVOLVEMENT VPP (15) SAFETY & HEALTH STAFF INVOLVED WITH CHANGES PSEE (15) REGULATORY ASSESSMENT AND ADVOCACY VPP (16) CONTRACTOR SAFETY PSEE (16) PRODUCT STEWARDSHIP VPP (17) MEDICAL PROGRAM PSEE (17) POLLUTION PREVENTION VPP (18) SAFETY AND HEALTH STAFF RESOURCES VPP (19) ANNUAL EVALUATION These elements, combined with the OSHA PSM elements, ensure a comprehensive accident prevention program. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the Borger Refinery and NGL Center have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP covered process at the plant. Collectively, these prevention program activities help prevent potential release scenarios that could be caused by (1) equipment failures and/or (2) human errors. In addition to the accident prevention program activities, the Borger Refinery and NGL Center 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 (mitigate) a release. The following types of safety features are used in various processes: Release Detection * Hydrocarbon detectors with alarms * Hydrogen Sulfide (H2S) detectors with alarms * Closed-circuit television cameras Release Containment/Control Process relief valves that discharge to a flare to capture and incinerate episodic releases Scrubber 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, release detection) Vessel to permit partial removal of the process inventory in the event of a release (e.g., 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 Release Mitigation * Fire suppression and extinguishing systems * Deluge system for specific equipment * Trained emergency respons e personnel * Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) * Blast-resistant buildings to help protect control systems and personnel FIVE-YEAR ACCIDENT HISTORY Over the past 5 years there have been two (2) releases, resulting in odor complaints, which met the RMP definition of events with offsite consequences. EMERGENCY RESPONSE PROGRAM INFORMATION The Borger Refinery and NGL Center 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 agenc ies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the Borger Refinery and NGL Center 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 or other plant 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 Borger Refinery and NGL Center is coordinated with the Hutchinson County Local Emergency Planning Committee (LEPC) and the Panhandle Emergency Response System (PERS). This coordination includes periodic meetings of the com mittee, which includes local emergency response officials, local government officials, and industry representatives. The Borger Refinery and NGL Center 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 Borger Refinery and NGL Center conducts periodic emergency drills that involve the LEPC and emergency response organizations. PLANNED CHANGES TO IMPROVE SAFETY The Borger Refinery and NGL Center resolves all findings from PHA's, some of which result in modifications to the process. The following types of changes are planned: * The facility will continue it's plans to upgrade process instrumentation. * Emergency isolation valves will be installed on vessels storing larger quantities of flammable substances. * Additional gas detection is planned for some processes. * Process operator training will continue to be improved to include; additional classroom, hands-on skill development and a more specific examination process. * A risk-based approach to equipment inspection is being implemented to oversee vessels and piping systems. * Mechanical flow diagrams and electrical classification drawings are being updated and placed "on-line", for use by operating and maintenance personnel. HAZARD ASSESSMENT SUMMARY1 The worst-case scenario (WCS) associated with a toxic release in the Borger Refinery and NGL Center, would be the catastrophic failure of a Methyl Mercaptan storage tank. Upon failure, the tank would release its entire contents (350,400 lbs.), which would vaporize and form a plume. The storage tank is designed to withstand significant overpressure scenarios, as well as, vacuum scenarios. Although several design and administrative controls exist to prevent such releases and manage their consequ ences, no administrative controls or passive mitigation measures were taken into account while evaluating this scenario. The maximum distance to the toxic endpoint of 0.049 mg/L (ERPG-2) was 16.7 miles. The alternative release scenario (ARS) for Methyl Mercaptan is the failure of a pump/flange gasket, resulting in an equivalent 1/4 inch release orifice open to the atmosphere. The 10-minute release duration is the estimated time needed by operating personnel to isolate the affected area of the process. Approximately 12 pounds/minute of material would be released. The installation of gas detection equipment, operator's rounds and digital control software will all act in concert to provide early detection of such a release. The distance to the toxic endpoint of 0.049 mg/L (ERPG-2) was 0.18 miles, which would result in no off-site consequence impacts upon the local community. The WCS associated with a release of a flammable substance is a vapor cloud explosion (VCE) involving the maximum intended inventory of the isobutane/olefins sphere, used as a feed tank to the HF Alkylation Unit. This tank was selected based upon its size and it's location nearest to off-site receptors. The maximum inventory of 708,750 pounds of isobutane/olefins is released, vaporizes and is ignited, resulting in a VCE. The maximum distance to the 1-psi endpoint is 0.07 miles (per PHAST model). Although a number of engineering, administrative and engineering reliability controls exist to safeguard employees and the public, none were considered in the development of the WCS. The alternative release scenario (ARS) for the isobutane/olefins sphere involves a subsequent fire after the failure of a transfer pump flange gasket resulting in a release of 7888 pounds of material over a 10-minute period. This scenario is expected to be isolated by unit operators within 10 minutes (active mitigation). The distance to the toxic endpoint is calculated1 at 0.10 miles, using the RMPComp modeling software.(PHAST model results did not identify enough product released to result in a VCE scenario). 1 The Borger Refinery and NGL Center chose the conservative method for hazard assessment by utilizing EPA's RMP*Comp model in almost all cases. The results of RMP*Comp may not closely match the results you obtain running the same release scenario in a more sophisticated air dispersion model. RMP*Comp is a planning tool designed to help you to easily identify high priority hazards. It relies on very simplified and generalized calculations. In contrast, models like PHAST, ALOHA, TRACE and DEGADIS are intended to give as accurate an estimate as possible of the extent of the area that might be placed at risk by a particular chemical release. |