Tesoro Northwest Company - Anacortes Refinery - Executive Summary |
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TESORO NORTHWEST COMPANY ANACORTES REFINERY RISK MANAGEMENT PLAN EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Tesoro Northwest Company Anacortes 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 Tesoro Anacortes Refinery, located in Anacortes, Washington, U.S.A., operates a variety of processes to produce petroleum products (e.g., natural gas, propane, butane, gasoline, jet, diesel, and residual fuels) from raw crude oil. The refinery has several regulated fla mmables, such as propane, butane, pentane, etc. In addition, the refinery uses and/or processes chlorine, ammonia, and hydrogen sulfide, which are also regulated substances. HAZARD ASSESSMENT RESULTS The Worst-Case Scenario (WCS) associated with a release of flammable substances at the Tesoro Anacortes Refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing a mixture of normal pentane (n-pentane) and iso-pentane (i-pentane). No administrative controls are in place to limit the storage inventory in the tank; therefore, the full tank inventory of 6,800,000 lbs is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is 1.5 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 Alternative Release Scenario (ARS) for fla mmable substances at the refinery is a VCE involving the full inventory of a butane railcar (n-butane). No administrative controls are in place to limit the storage inventory in the railcar; therefore, the full tankcar inventory of 150,000 lbs is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this ARS is 0.29 miles. Although we have numerous controls to prevent such releases and to manage its consequences, no credit for passive nor active mitigation measures were taken into account in evaluating this ARS. This event was selected as being a practical scenario for communicating the potential hazards of our operations with the local community and improving emergency planning and response programs. Graphical representations of the WCS and ARS hazard assessment results are attached in Section 4, Item 4.11 and Section 5, Item 5.12, respectively. The Tesoro Anacortes Refinery is not required under the RMP regulation to report a Toxic WCS nor Toxic ARS scenario because there are no RMP regulated toxic substances stored at our facility that exceed the RMP threshold quantity. However, the following toxic RMP substances are present at our facility, stored below the RMP threshold quantity: hydrogen sulfide, chlorine, and anhydrous ammonia. Although we are not required to evaluate the effects of a toxic release under the RMP regulation, we went ahead and evaluated imaginary scenarios to better understand the potential affects an accidental, toxic release might have on our community. This information, along with other RMP information, has been shared with our community and local responders through meetings and brochure publications. FIVE-YEAR ACCIDENT HISTORY We are justifiably proud of our safety performance at the Tesoro Anacortes Refinery. There are no releases of RMP-regulated substances in the last five years that resulted in injuries or property damage. Since the start of operation in 1955, there has never been an explosion that impacted people or property outside of the refinery. In addition, we have not had a toxic release that has required people outside the refinery to shelter-in-place or evacuate. The likelihood of a flammable or toxic release adversely impacting people outside of the refinery is extremely low, given the programs we have in place to prevent this type of accident. However, every incident or near-miss at the facility is carefully investigated to determine ways to prevent similar incidents from occurring. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Tesoro Anacortes 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 OSHA PSM program is administered by the Washington State Department of Labor and Industries under Washington Administrative Code 296-67. Employee Participation The Tesoro Anacortes 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 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 t eams typically have members from various areas of the plant, including operations, maintenance, safety, engineering, and plant management. Process Safety Information The Tesoro Anacortes 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 A table 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 informa tion 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) in a Key & Critical Variable List 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 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, trained personnel, and regulated inspection frequencies, provides a basis for establishing insp ection 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 Tesoro Anacortes 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 Tesoro Anacortes Refinery uses a combination of the hazard and operability (HAZOP) analysis technique and a Checklist 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 mitigatio n 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 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 Tesoro Anacortes 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 i s 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 Tesoro Anacortes 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 Tesoro Anacortes Refinery maintains a Key & Critical Variable List Docume nt 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 Tesoro Anacortes Refinery 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 periodi cally 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 Tesoro Anacortes Refinery uses contractors to supplement its workforce 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 Tesoro Anacortes 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 Tesoro Anacortes Refinery conducts a PSSR for new facility or facility modification that requires a change in the process safety information and prior to start-up of facilities after a maintenance turnaround. 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 tha t 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 Tesoro Anacortes 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 (if possible), and/or a 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 Tesoro Anacortes Refinery 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. Safe Work Practices The Tesoro Anacortes 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 safely. Management of Change The Tesoro Anacortes Refinery has a comprehensiv e 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 required training on the change. Incident Investigation The Tesoro Anacortes 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 dete rmine 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 Tesoro Anacortes 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 staff 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 Tesoro Anacortes 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 Tesoro Anacortes 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 Tesoro Anacortes Refinery has safety featu res on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release Detection 1. Hydrocarbon and H2S detectors on control house air intakes. Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases 2. Valves to permit isolation of the process (manual or automated) 3. Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 4. Curbing or diking to contain liquid releases 5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 6. Atmospheric relief devices Release Mitigation 1. Fire suppression and extinguishing systems 2. Deluge and water flooding systems for specific equipment 3. Trained emergency response personnel 4. Personal protecti ve equipment (e.g., protective clothing, self-contained breathing apparatus) EMERGENCY RESPONSE PROGRAM INFORMATION The Tesoro Anacortes 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. In addition, the Tesoro Anacortes 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. All employees receive training in t hese 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 an approval process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Tesoro Anacortes Refinery is coordinated with the Skagit County Local Emergency Planning Committee (LEPC) of Washington State. This coordination includes periodic meetings of the committee, which includes local industry representatives. In addition to periodic LEPC meetings, the Tesoro Anacortes 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. The Tesoro Anacortes Refi nery has around-the-clock communications capability with the emergency response officials, local government officials, and 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 coordinating with the LEPC, the Tesoro Anacortes Refinery, as a member of the March Point CAER (Community Awareness/Emergency Response) Group, has joined with other nearby chemical and refining companies to plan, work, and drill with local emergency responders and local authorities to improve our emergency response plans. The CAER Group also has taken an active role in communicating the hazards, prevention programs, and emergency response programs of the March Point industries with the local community. We also participate in the Western States Petroleum Association (WSPA) Mutual Aid Agreement. If necessary, we can call on part icipating members to help supply additional specialized emergency response equipment and resources. PLANNED CHANGES TO IMPROVE SAFETY The Tesoro Anacortes Refinery is committed to continuous improvement of our safety procedures, practices, and process equipment. We learn from previous incidents and near misses that occur not only within our own facility, but of incidents that occur at other industry facilities. One way we accomplish continuous improvement of our safety program is by applying a multi-level, multi-disciplined approach to surfacing safety improvement ideas. This includes an open safety culture that encourages safety issues to be raised and addressed on a daily basis. The culture allows everyone the flexibility to elevate issues through their Operating Team, Operating Area, Plant Safety Committees, Supervisors and Managers with the goal to share and resolve safety issues. Other safety improvement initiatives include: 1. Resolving findings generated by PHA teams, Incident Investigations, and PSM Compliance Audits. 2. Improving emergency response procedures 3. Promoting on-going community outreach programs via the March Point CAER (Community Awareness/Emergency Response) Group 4. Continuously improving our safety procedures and practices via ideas generated by teams that promote process and personal safety. |