BPAmoco Mandan Refinery - Executive Summary |
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BP Amoco Mandan Refinery, Mandan, ND EPA Risk Management Plan - Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The BP Amoco Mandan Refinery, located in Mandan, North Dakota has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training of personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our refinery adheres to federal and state regulations, industry standards and practices, Amoco process safety policies and guidelines, and best practices that have been developed based on years of company and industry experience. Examples of specific resource material are: the Amoco Process Safety Booklets, the Amoco Process Safety Standards and Guideline Manual, the Amoco Refining Business Group Implementation Guidelines for OSHA 1910.119 and RMP, the Amoco Recommended Good Practices Manuals, and the Amoco Corporate Engi neering Specifications. Our policy is to implement controls to prevent foreseeable releases of regulated substances. If an accidental release does occur, our trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Mandan Refinery is located at Mandan Avenue and Old Red Trail in Mandan, ND. The refinery is owned by BP-Amoco, p.l.c. The refinery processes 58,000 barrels of crude oil per day in a variety of processes to produce petroleum products such as gasoline, diesel fuel, jet fuel, home heating oil, liquefied petroleum gas (LPG), etc. The refinery has ten (10) processes that contain materials above the threshold quantity and are, therefore, covered by the RMP rule. These processes are all classified as Program level 3 processes. All covered processes contain regulated flammable mixtures above the threshold quantity of 10,000 pounds. The flammable mixtures typically contain various regulated su bstances such as but not limited to hydrogen, methane, ethane, propane, butane, and pentane. In addition, one process contains hydrogen fluoride above the 1,000 pound threshold quantity. HAZARD ASSESSMENT RESULTS Flammable Worst Case Scenarios (WCS): The worst case scenario (WCS) for flammable substances is a vapor cloud explosion (VCE) with an overpressure endpoint of 1 pound per square inch (psi). The WCS endpoint is based on the instantaneous release of the entire contents of the largest vessel in a process filled to capacity resulting in a VCE. The effects of administrative controls, mitigation systems, and safety systems are not included in determining the effect of the WCS. Based on the distances to the endpoint, calculated using the methodology outlined in the EPA?s RMP Offsite Consequence Analysis Guidance, effects from the WCS would reach offsite. BP Amoco has calculated the WCS as required by the rule, and has provided detailed information to the EPA and the Morton C ounty and Burleigh County LEPC?s. Flammable Alternative Release Scenarios (ARS): The alternative release scenario (ARS) for flammable substances at the refinery is a VCE resulting from a release of flammable liquids (primarily butane) from a 2 inch piping leak. Under this scenario, the release is isolated by operators within 20 minutes. The distance to the endpoint, calculated using the methodology outlined in the EPA?s RMP Offsite Consequence Analysis Guidance, would reach offsite. This release scenario was selected based on industry history, and because it is a practical scenario for use in emergency planning and response. Details concerning the ARS analysis have been provided to the EPA, and the Morton County and Burleigh County LEPC?s. Toxic WCS: The toxic WCS for the refinery involves the chemical Hydrogen Fluoride. BP Amoco has calculated the WCS as required by the rule and has provided detailed information to the EPA and the Morton County and Burleigh County LEPC?s. The distance to the ERPG-2 endpoint of 20 ppm (0.016 mg/l) would reach offsite. The distance was calculated using the HEGADAST model (EPA Guideline, Appendix 2). The effects of administrative controls, mitigation systems, and safety systems are not included in determining the distance to the endpoint. The quantity of HF used in the WCS calculation would only be present in the deinventory drum during an emergency situation or when the unit is shut down. During routine operation, the HF acid is contained in multiple smaller vessels where the potential quantity for release is substantially less. The deinventory drum, which is normally empty, is used for storage during maintenance shutdowns at a frequency of about 4 weeks every three years. However, the quantity of HF stored during maintenance shutdowns is minimized by using administrative controls and would be significantly less. Toxic ARS: The toxic ARS for the refinery is a release of HF from a 0.75 inch hole in the acid recycle piping. The affects of automatic water spray mitigation and rapid isolation/deinventory is included for this scenario. Taking these into account, the distance to the 20 ppm ERPG-2 endpoint would reach offsite. This distance was calculated using the HEGADAST model. Details concerning the ARS analysis have been provided to the EPA and the Morton County and Burleigh County LEPC?s. ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS Following is a summary of the accident prevention program in place at the Mandan Refinery. 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 carry out the accident prevention program. Employee Participation The Mandan Refinery encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee particip ation 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 teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. Examples of these are the Joint Health and Safety Committee and the Area Safety Committees. The Mandan Refinery also participates in OSHA?s Voluntary Protection Program which i s based largely on participation from all employees in the facility. The refinery was awarded OSHA STAR status in 1997. Process Safety Information The Mandan 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. Asset divisions 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 process safety overview information for each process to help employees and visitors quickly 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). T his 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 documented safety-related operating limits for specific process parameters (e.g., temperature, level, composition) in a Safe Operating Limits Table. 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). In addition, tables summarizing the consequences of deviation from these limits and the corrective actions to take are readily available. The refinery also maintains 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, piping and instrum ent drawings, 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 (PHA) The Mandan 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 Mandan refinery 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 evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifi es 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 recommendations are forwarded to management for resolution. Implementation of mitigation options in response to PHA recommendations 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 prompt attention. All approved mitigation options being implemented in response to PHA team recommendations are tracked until they are complete. The final resolution of each recommendation 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 Mandan Refinery periodically updates and revalidates the hazard analysis results. These periodic revie ws are conducted at least every 5 years and will be conducted at this frequency for the life of the process. The results and recommendations from these updates are documented and tracked. Once again, the team recommendations are forwarded to management for consideration and their final resolution is documented and retained. Operating Procedures The Mandan 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 are developed by experienced operators as needed 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 in accordance with the management of change process. In addition, the Mandan Refinery maintains a Safe Operating Limit 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 Mandan Refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery 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 written and/or oral tests, skills demonstration) adequate knowledge to perform the duties and tasks in a safe manner, 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 Mandan Refinery uses contractors to supplement its workforce generally 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) infor mation about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the Mandan 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 Review (PSSR) The Mandan Refinery 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 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 read iness. A PSSR involves field verification of the construction and provides the quality assurance that accident prevention program requirements are properly implemented. Mechanical Integrity The Mandan 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 and plans, (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 e nsure 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 a management of change (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 Mandan 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 W ork Practices The Mandan 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 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 entering 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 Mandan 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 opera ting 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 on the change. The system ensures that all documentation is updated and training completed prior to the commissioning of the change. Incident Investigation The Mandan Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire or explosion, toxic release, property damage, environmental incident, 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 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 Mandan 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 le ast every 3 years. Both hourly and management 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 Mandan Refinery have potential hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all RMP-covered processes. 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 Mandan Refinery has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) re duce the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release Detection 1. Hydrocarbon detectors with alarms 2. Hydrogen Fluoride detectors with alarms that activate automatic spray mitigation Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases 2. Scrubber to neutralize chemical releases 3. Valves to permit isolation of the process (manual or automated) 4. Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 5. Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank) 6. Curbs and dikes to contain liquid releases 7. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 8. Atmospheric relief devices Release Mitigation 1. Fire suppression and extinguishing systems 2. Deluge systems for speci fic equipment 3. Remote monitoring equipment 4. Trained emergency response personnel 5. Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 6. Mobile fire fighting equipment 7. Blast-resistant buildings to help protect control systems and personnel FIVE YEAR ACCIDENT HISTORY The Mandan Refinery 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 occurring. The Mandan Refinery has not had any incidents covered by the RMP rule in the past five years. EMERGENCY RESPONSE PROGRAM INFORMATION The Mandan 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 Mandan 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. 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. Personnel are trained on or informed of all changes to the refinery emergency response program that affect them. The overall emergency response program for the Mandan Refinery is coordinated with the Mort on and Burleigh County Local Emergency Planning Committees (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Mandan Refinery 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 Mandan 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. PLANNED CHANGES TO IMPROVE SAFETY The Mandan Refinery resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned: ? Install additional surveillance cameras in the area of the Crude Unit and FCU/VRU ? Install additional excess flow valves in the LPG loading/unloading area ? Improve relief valve maintenance program with new procedures ? Install new equipment to facilitate testing of Alkylation Unit (HF) relief valves ? Install HF detection equipment in the Alkylate/propane rundown system ? Install improved access platforms/stairways in the Alkylation Unit Acid Settler area ? Upgrade purge system on the Alkylation Unit Relief Valve Header to improve reliability of relief valves |