Chevron USA Production Mckittrick 17Z Gas Plant - Executive Summary |
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CHEVRON USA PRODUCTION McKITTRICK 17Z GAS PLANT SAN JOAQUIN VALLEY BUSINESS UNIT McKITTRICK, CALIFORNIA RISK MANAGEMENT PLAN EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Chevron USA Production McKittrick 17Z Gas Plant has a long-standing commitment to workers 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, gas plant trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Chevron USA Production McKittrick 17Z Gas Plant, located near McKittrick, California, operates a variety of processes to produce petroleum products (e.g., natural gas, propane, natural ga soline) from natural gas. The Chevron USA Production McKittrick 17Z Gas Plant has several regulated flammables, such as propane and natural gasoline. Additionally, the Chevron USA Production McKittrick 17Z Gas Plant uses sodium hypochlorite, ethylene glycol and ethyl mercaptan, which are also regulated substances but these chemicals are under threshhold limits. OFFSITE CONSEQUENCE ANALYSIS RESULT The WCS associated with a release of flammable substances in the Program Level 1 process at the gas plant is a vapor cloud explosion of the largest storage tank containing propane. A written procedure is in place to limit the storage inventory to 90% of the maximum tank capacity (190,000 lbs.) however the likelihood of filling the storage tank to 100% capacity (210,000 lbs.) still exist and is assumed to release and ignite, resulting in a vapor cloud explosion. 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 evaluation. The resulting endpoint extends offsite however there are no public receptors within the distance to the endpoint. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the plant. Because processes at the gas plant that are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) 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. It is our policy at the Chevron USA Production McKittrick 17Z Gas Plant to adhere to all Federal, State and Local laws. If emergency were to occur, it is part of our training and a company policy to notify the Kern County Fire Department by dialing the 911 number. Employee Participation The Chevron USA Production McKittrick 17Z Gas Plant 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 gas plant 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 gas plant and addresses each accident prevention program element. In addition, the gas plant has a number of initiatives under way that address process safety and employee safety issue. 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 pla nt management. Also all plant operators are encouraged to participate in company Safety Suggestion program to provide operator's input to improve safety in plant operations, to be involve in Near Miss program which provides operator's personal situation in preventing accidents, and Behavorial Based Safety Training program which gives operators an opportunity to observe other operators in work situations and discuss safety suggestion for at risk behavior or commend operator's safe conduct. Process Safety Information The Chevron USA Production McKittrick 17Z Gas Plant 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 individuals within the gas plant 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 information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the gas plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in a Key Process Parameter Document. The gas plant 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 gas plant also maintains numerous te chnical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) The Chevron USA Production McKittrick 17Z Gas Plant 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 Chevron USA Production McKittrick 17Z Gas Plant primarily uses the hazard and operability (HAZOP) analysis techn ique and the "What If" methodology to perform these evaluations. HAZOP analysis and the "What If" methodology are recognized to be 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. The team then makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local and/or 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 in response to PHA team findings are tracked unt il they are completed. 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 plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures The Chevron USA Production McKittrick 17Z Gas Plant 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 through Job Safety Analysis (JSA) program by two or more operators to analyzed tasks, to identify possible hazards, to ensure safeguards in place and follow through with recommendations and modifications to improve job safety. Standard Operating Procedures (SOP) are certified as current and accurate annually. The procedures are also kept current and accurate by revising them as necessary to reflect changes made through the management of change process. Upper and lower operating limits and consequence of deviation and how to correct deviation on most of the critical equipment most particularly the fractionation section are incorporated in the written standard operating procedures. This information is readily available to operators in the process unit and for other personnel to use as necessary to safely perform th eir tasks. Training To complement the written procedures for process operations, the Chevron USA Production McKittrick 17Z Gas Plant has implemented a refresher training program for all employees involved in operating a process. New employees receive basic training in gas plant 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 oral and written 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 every year. All of these training is documented for each operator, including the mean s used to verify that the operator understood the training. Contractors The Chevron USA Production McKittrick 17Z Gas Plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the gas plant 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 gas plant 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 and the issuance of work permits that include general work permit, confined space entry permit and hot work permit for any welding work. In addition, the Chevron USA Production McKittrick 17Z Gas Plant evaluates contractor safety programs and performance during the selection of a contractor. Gas plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Documentations of these evaluations are kept in the PSM binder. Pre-startup Safety Reviews (PSSRs) The Chevron USA Procudtion McKittrick 17Z Gas Plant conducts a PSSR for any new unit 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 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 te am 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 Chevron USA Production McKittrick 17Z Gas Plant 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. Also the new MP2 program (Maintenance Tracking System) has been developed and is in place to handle any request for repairs, serv ice and maintenance of equipment. It's also maintains a good record of equipment repairs and preventative maintenance record. 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 jobs 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 a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the eq uipment. Another integral part of the mechanical integrity program is quality assurance. The Chevron USA Production McKittrick 17Z Gas Plant 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 Chevron USA Production McKittrick 17Z Gas Plant has a 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 substances 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 befor e 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 Chevron USA Production McKittrick 17Z Gas Plant has a comprehensive system to manage changes to all covered 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, (2) verify that existing controls have not been compromised by the change and (3) ensure the change is communicated to affected personnel. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operat ing and maintenance personnel are provided any necessary training on the change. Incident Investigation The Chevron USA Production McKittrick 17Z Gas Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, significant toxic gas release, major property damage, significant environmental damage, 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 gas 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 findi ng 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 Chevron USA Production McKittrick 17Z Gas Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits (Level I PSM Audits) are facilitated by corporate staff and 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 gas plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final re solution of each finding is documented, and the two most recent audit reports are retained. Also Level II and Level III PSM Audits are initiated locally to ensure continous compliance. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the Chevron McKittrick 17Z Gas Plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. All Chemicals newly introduced to the Chevron McKittrick 17Z Gas Plant has to have MOC document, Product Acceptance certification approved by the Facilities Engineer, Environmental Safety Specialist, Chevron Chemical Group and the Operations Supervisor. All Chemicals delivered to the facility must be accompanied by a Material Safety Data Sheet (MSDS). Chemical truck drivers are required to follow Plant Entry Procedures which involve signing of the Sign In/Sign Out log and safety orientation overv iew training. Operator on duty has to check the area with gas detectors before letting the truck into the Gas Plant. Operator has to supervise the driver during the unloading process to ensure that chemical will go to the right storage or container. Universal Prevention Activities The accident prevention program summarized previously is applied to all RMP-covered processes at the Chevron USA Production McKittrick 17Z Gas Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The Chevron USA Production McKittrick 17Z Gas Plant has safety features on many units to help contain/control a release, and reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes: Release Containment/Control 1. Process relief valves discharge to a stack line, and in some cases pressure could be manu ally bled down to the high and low pressure blow down system. 2. Valves to permit isolation of the process (manual or automated) 3. Automated high pressure shutdown system that will shutdown the excessive high pressure feed to the plant. 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. 7. Emergency Shut Down (ESD) system that will isolate the plant from both intake and discharge in the event of an uncontrolled gas release. Release Mitigation 1. Fire suppression and extinguishing systems 2. Deluge system for specific equipment (storage tanks south of the loading rack) 3. Trained emergency response personnel 4. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus, fire fighting turnouts) 5. Blast-resistant buildings to help protect control systems and personnel. FIVE-YEAR ACCIDENT HISTORY The Chevron USA Production McKittrick 17Z Gas Plant has an excellent record of accident prevention over the past 5 years. We investigate every incident very carefully to determine ways to prevent similar incidents from recurring. We have never had an accident involving propane that caused deaths, injuries, property or environmental damage, evacuation or shelterings in place. There have been no reportable incidents in last five years involving a regulated substance that are above threshold quantity. EMERGENCY RESPONSE PROGRAM INFORMATION The Chevron USA Production McKittrick 17Z Gas Plant 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 post incident cleanup and decontamination requirements. In addition, the plant 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 the Chevron USA Production McKittrick 17Z Gas Plant processes or other third party facilities that may affect the operations at the gas plant. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in t he changes. The overall emergency response program for the Chevron McKittrick 17Z Gas Plant is coordinated with the Kern County Fire Department at McKittrick California. This coordination includes periodic meetings, which includes local emergency response officials and industry representatives. The Chevron USA Production McKittrick 17Z Gas Plant has around-the-clock communications capability with appropriate Public Safety officials and/or 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 monthly safety meetings, the Chevron McKittrick 17Z Gas Plant conducts periodic emergency drills that involve the Chevron DOT representatives and Chevron Safety Specialists. In addition, the gas plant operators are given annual refresher training for emergency response regarding the hazards of regulated substances in the gas plant. All gas plant personnel have undergone hazardous material training and are classified as LEVEL 5 Hazwoper. This covers the First Responder, First Responder Operational and Incident Commander training. PLANNED CHANGES TO IMPROVE SAFETY The Chevron USA Production McKittrick 17Z Gas Plant resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned over the next few years in response to PHA, safety audit, and incident investigation findings: ? Decrease in the amount of chemicals stored on site for cooling water chemical treatment ? Upgraded process control system to use distributed computerized control system ? Hydrocarbon release detection system in the liquefied petroleum gas (LPG) loading rack area ? Revisions to personnel training programs ? Upgraded fire protection system throughout the gas plant area. ? New MP2 program to keep and provide mechanical integrity and preventative maintenance records of equipment (e.g., v ibration shutdown switch for Refrigeration Compressors) |