Valero Refining Company - CA - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Valero Benicia Refinery operates under a concept of structured safety management systems entitled Operations Integrity Management System (OIMS). In 1997, Lloyd's Register Quality Assurance reviewed OIMS and evaluated it against the international standard for Environmental Management Systems (ISO 14001) to determine if OIMS meets the requirements of ISO 14001. After an extensive review, which included a number of facility audits, they concluded that the "environmental components of OIMS are consistent with the intent and meet the requirements of the ISO 14001 Environmental Management Systems Standard." The Valero Benicia Refinery has a long-standing commitment to worker and public safety and protecting the environment. This commitment is demonstrated by the resources invested in accident prevention, such as personnel training and considering safety in the design, installation, operation, and maintenance of our proc esses. Our objective 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, contain and mitigate the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Valero Benicia Refinery, located in Benicia, California, U.S.A., operates a variety of processes to produce petroleum products (e.g., propane, butane, gasoline products, jet fuels, diesel fuels, asphalt and coke) from raw crude oil. The refinery has several regulated flammables, such as propane, butane, etc. In addition, the refinery uses and/or processes anhydrous ammonia and aqueous ammonia (>20%), which are toxic regulated substances. The Refinery contains a total of seven covered processes for the purposes of this plan. HAZARD ASSESSMENT RESULTS The hazard assessments were done using the EPA supplied "look up tables" which have been incorporated into a computer program supplied by the National Oceanic and Atmospheric Administration (NOAA). This program is called RMP*Comp (version 1.04). This program uses all the parameters required by the RMP rule for both worst case (WCS) and alternate release (ARS) scenarios. The WCS associated with toxic substances in Program 3 processes at the Benicia Refinery is a release of Anhydrous Ammonia from a truck trailer which causes an off-site impact. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating this scenario. The WCS associated with a release of flammable substances in Program 3 processes at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest storage sphere containing butane. The full vessel inventory is assumed to release, completely vaporize, and ignite, resulting in a VCE. Although we have numerous controls to prevent such rel eases and to manage their consequences, no credit for administrative or passive mitigation measures was taken into account in evaluating this WCS. This WCS has an off-site impact. The ARS for Anhydrous Ammonia is a failure of a loading hose during transfer operations. This ARS has an off-site impact. The ARS for Aqueous Ammonia is a failure of a large pipe flange during transfer operations. This scenario was also reported as a part of the 1993 Environmental Impact Report when the storage tank was first installed. This ARS has an off-site impact. The ARS for flammable substances at the refinery is a pool fire in and around one of the refrigerated storage tanks. This ARS has an off-site impact. EXTERNAL EVENTS ANALYSIS The refinery is subject to external events, which may cause the release of hazardous materials. The refinery is designed and operated in such a way as to minimize the probability and the impact of such events. External events considered in the design and oper ation of the refinery include, but are not limited to: security; temperature extremes; earthquake; winds; precipitation; utility disruption; and wildland fires. Of particular interest is the earthquake susceptibility. The refinery was built in the late 1960's to the best ground motion technology available at the time. Additionally, the refinery processing and storage areas are on solid rock, which limits the severity of ground motion. Additions and significant modifications to the Refinery since that time have been done using the codes and technology applicable at the time of construction of those projects. Even prior to the 1989 Loma Prieta Earthquake, the refinery had conducted independent assessments of risks associated with lateral ground motion. Although there will be damage to refinery equipment from a worst credible earthquake, studies have indicated that catastrophic loss of containment should not be a concern. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Valero Benicia Refinery. EPA's Program 3 prevention requirements are met because all Program Level 3 processes at the refinery are also subject to the OSHA Process Safety Management (PSM) standard. In addition, the Valero Benicia Refinery operates under the Operations Integrity Management Systems (OIMS) that includes the aspects of EPA's prevention program. This summary describes OIMS. Further, as already mentioned, OIMS has been recognized as equivalent to ISO 14001 as a valid management system to oversee the implementation of the risk management activities. The refinery is focused on fuels production and most of the light hydrocarbons are used in mixtures and are not recovered as pure components. Isomers and olefins of propane and butane origin are mixed without regard to the specific components, because they all behave similarly in their use as fuel. Where we had specific gas chromatograph infor mation on the species of the hydrocarbon compounds, these have been marked in the inventory. If these data were not readily available, only the normal paraffinic component (propane, butane) is listed. In all cases, the normal paraffinic component is heavier and has a higher energy value than the olefins or isomers, and therefore, represents a more conservative case. Additional details are included in the Data Element section of this RMPlan. Due to the ongoing nature of our safety program, the dates associated with the various activities in our accident prevention program are constantly changing. To minimize rework, we selected March 1, 1999 as the date to begin collecting this information. Consequently, most of the reviews/updates conducted after that date are not reflected in the Data Element information. Employee Participation The Valero Benicia Refinery encourages employees to participate in all facets of process safety management and accident prevention. Examples of employ ee participation range from updating and compiling operating and maintenance procedures 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 teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. Process Safety Information The Valero Benicia Refinery keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documen ts address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific groups 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 OIMS documentation 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 refinery has identified Operating Envelopes; i.e. documented safety-related limits for specific process parameters such as temperature, level , and compositions. The refinery ensures that the process is maintained within these limits using computerized process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems, alarm systems). The refinery also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and 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 Valero Benicia Refinery has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlle d. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Valero Benicia Refinery primarily uses the Knowledge Based Hazard and Operability (HAZOP) study that is an adaptation of widely used industry methodologies 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 experience and engineering expertise on the process to be evaluated. This PHA team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative ri sk evaluation done by the PHA team. This evaluation helps ensure that potential accident scenarios assigned greater risk receive attention first. Some mitigation options, though, may involve process modifications that can only be implemented during a complete downtime of the covered process. Implementation of such modifications, therefore, may extend well into the future and are subject to change. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The resolution of each finding is documented and retained. To ensure that the process controls and/or process hazards do not deviate significantly from the original design safety features, the Valero Benicia Refinery periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years for the life of the process. The results and findings from these updates are documented and retained. The team findings are forw arded to management for consideration, and resolution of the findings is documented and retained. Operating Procedures and Safe Work Practices The Valero Benicia Refinery maintains written procedures that address various modes of process operations, such as (1) startup, (2) shutdown, (3), normal and (4) emergency operations. These procedures can be used as a reference by experienced operators and provide a consistent basis for training of new operators. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. These procedures are periodically reviewed and annually certified as current and accurate. The refinery has identified Operating Envelopes; i.e. documented safety-related limits for specific process parameters such as temperature, level, and compositions. This information, along with written operating procedures, is readily available to operators in the process unit and for other person nel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, the Valero Benicia 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 an experienced operator to learn process-specific duties and tasks. After employees 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 operations technicians 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 fo r each operator, including the means used to verify that the operator understood the training. Contractors The Valero Benicia 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 Valero Benicia Refinery evaluates contractor safet y 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 Valero Benicia Refinery conducts a PSSR for any new facility or facility modification that requires a change in the process safety information and therefore, is controlled by management of change (MOC). The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification t hat accident prevention program requirements are properly implemented. Mechanical Integrity The Valero Benicia 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), 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 Valero Benicia 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. Hot Work & Other Safe Work Practices The Valero Benicia Refinery has long-standing safe work practices in place to help ensur e worker and process safety. These include orientations for visitors/contractors, control of the entry/presence/exit of personnel, energy isolation for equipment being worked on, procedures for the safe removal of hazardous materials before opening of process piping/equipment, hot work permit/procedure to safely manage spark-producing activities, vehicle entry into process area, confined space entry permit/procedure to help ensure precautions are taken before entering confined spaces, and job safety analyses to identify and mitigate hazards associated with maintenance tasks. These practices, along with related procedures and training of affected personnel, form a system to help ensure operations and maintenance activities are performed safely. Management of Change The Valero Benicia Refinery has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions) , procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) 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 necessary training before the change is implemented. Incident Investigation The Valero Benicia 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 determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to refinery management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The 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 Valero Benicia 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. The audit team develops findings that are forwarded to refinery management for resolut ion. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The resolution of each finding is documented, and the two most recent audit reports are retained. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the Valero Benicia Refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all covered processes at the Valero Benicia 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 Valero Benicia Refinery has safety features on many units to help, (1) quickly detect a release, (2) contain/control 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 d etectors with alarms 2. Hydrogen sulfide (H2S) detectors with alarms 3. TV surveillance cameras 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 system for specific equipment 3. Trained emergency response personnel 4. Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 5. Blast-resistant buildings to help protect control systems and personnel FIVE-YEAR ACCIDENT HISTORY The Valero Benicia Refinery has an excellent r ecord of accident prevention over the life of the refinery. There have been no accidents for the past 5 years, which are reportable under this regulation. EMERGENCY RESPONSE PROGRAM INFORMATION The Valero Benicia Refinery maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the Valero Benicia Refinery has procedures that address maintenance, inspection, and testing of emergenc y response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to refinery processes or other refinery facilities. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Valero Benicia Refinery is coordinated with the Solano County Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Valero Benicia Refinery has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., City of Beni cia Fire Department). This provides a means of notifying the public of an incident as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Valero Benicia Refinery conducts periodic emergency drills that involve the City of Benicia Fire Department. PLANNED CHANGES TO IMPROVE SAFETY Our Operations Integrity Management Systems form the cornerstone for continuous improvement in our safety-related systems. These systems are evergreen and are in a continuous state of improvement, usually through many small improvement steps. Some examples are the recommendations from our hazard reviews and any incident investigations. Other examples are the improvement steps that result from our operating and mechanical procedures systems that are tightly integrated with our training programs. Specific plans that are related to this submission include an evaluation of steps to reduce the inventory of ammonia that is used within the refinery, and consulting w ith the City of Benicia on their new emergency warning system. |