Puget Sound Refining Company - Executive Summary |
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Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Puget Sound Refining Company 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 Puget Sound Refining Company, located in Anacortes, Washington, operates a variety of processes to produce petroleum products (e.g., natural gas, propane, butane, gasoline) from raw crude oil. The refinery has several regulated flammables, such as propane, butane, etc. In addition, the refinery uses and/or processes ammonia and hydrogen sulfide, which are also regulated substances. HAZARD ASSESSMENT RESULTS The worst-case scenario (WCS) associated with toxic substances in Program 3 processes at the refinery is a catastrophic failure in the Boiler House/Cogeneration Anhydrous Ammonia Tank, resulting in a release of 103,000 lb of Anhydrous Ammonia gas over a 10-minute period. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures were taken into account in evaluating this scenario. The toxic endpoint for this substance is 0.14 milligrams. No Program 1 or 2 processes containing regulated toxic substances were identified at the refinery. The alternative release scenario (ARS) for the Ammonia is a failure of the same tank resulting in a release of 103,000 lb of Ammonia gas over a nine minute period. The nine minute release duration is the approximate time necessary to depressurize the tank through a four inch hole in the vessel. Th e water deluge system was taken into account in evaluating this scenario. There are no offsite consequences expected with this scenario. The WCS associated with a release of flammable substances in Program 2 and 3 processes at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing normal Butane. No administrative controls are in place to limit the storage inventory in the tank; therefore, the full tank inventory of 2,340,000 lb is assumed to release, completely vaporize, and ignite, resulting in a VCE, with a 1-psi overpressure. 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 ARS for flammable substances at the refinery is a VCE resulting from the release of n-butane from a rail car located at the railcar loading rack facility (154,000 lb released over a 10-minute period). This event was selected as being a practical scenario for use in emergency planning and response. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls were taken into account in evaluating this scenario. FIVE-YEAR ACCIDENT HISTORY Puget Sound Refining Company has had one RMP-related accident over the past 5 years; a fire on its Delayed Coking Unit. There were six worker fatalities due to a November 25, 1998 Delayed Coking Unit fire. That event did not result in injuries or other offsite impacts as defined by the RMP beyond the refinery fence line. For the previous five years, there has not been any other injury inside or outside of the refinery caused by an RMP-covered accidental release of RMP-listed materials. We investigate accidents to determine ways to help prevent similar accidents from occurring. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident pre vention program in place at Puget Sound Refining Company. 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. Employee Participation Puget Sound Refining Company 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 PSM program element. In addition, the refiner y has a number of initiatives under way that address process safety and employee safety issues. Through the BEST (Behavioral Education for a Safer Today) Program, employees have designed and implemented a behavior based safety program which encourages modifications to behavior to work safer. This program utilizes peer observations of work practices and participation on safety teams. The program has the stated goal that "We all return home healthy and safe." The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. Process Safety Information Puget Sound Refining Company 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, chemical inventories, and equipment design basis/configuration information. Specific departments within the refinery are assigned responsibility for maintaining up-to-dat e 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. The refinery process uses controls and monitoring instruments, 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 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 compro mised. Process Hazard Analysis Puget Sound Refining Company has a comprehensive program to help identify and control recognized hazards associated with the various processes. Within this program, each process is systematically examined to recognize hazards and to verify that adequate controls are in place to manage these hazards. Puget Sound Refining Company primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as a systematic and thorough hazard evaluation technique. The analyses are conducted using a team of people who have operating and engineering expertise. This 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 a variety of departments for consideration and resolution. Implementat ion of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. 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 that documentation is retained. It is Puget Sound Refining Company's policy to resolve all open findings in a timely manner. The time necessary to resolve a finding varies, depending on the nature of the finding and circumstances. For example, as a general rule, findings are resolved within two years or less, unless the resolution of the finding requires a unit or plant shutdown to complete, or other conditions limit the ability of the plant to resolve the open finding. Puget Sound Refining Company 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. An electronic tracking system is used to manage and document the results and findings from these updates. The team findings are forwarded to various departments for consideration and resolution. Operating Procedures Puget Sound Refining Company 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. Training To complement the written procedures for process operations, Puget Sound Refining Company has implemented a comprehe nsive training program for all employees involved in operating a process. There is a training program that is designed to provide new operators with basic training in refinery operations if they are not already familiar with such operations. After attending the training program, new operators are 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, operators periodically receive refresher training on the operating procedures to help maintain their skills and knowledge. This refresher training is conducted at least every three years. Contractors Puget Sound Refining Company 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 so 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, Puget Sound Refining Company evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor various contractor's safety performance to confirm that such contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) Puget Sound Refining Company 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 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 Puget Sound Refining Company 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 inc lude: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) addressing findings identified, if any, during inspections and tests, 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 b efore 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 verify the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. Puget Sound Refining Company 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 Puget Sound Refining Company has long-standing safe work practices in place to help maintain 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 Puget Sound Refining Company 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 reviewed pursuant to the MOC process 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, affected personnel are provided any necessary training on the change. Incident Investigation Puget Sound Refining Company 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 to develop action items that may help prevent a recurrence of the incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to refinery management for review. 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 affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable. 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, Puget Sound Refining Company 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 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 Puget Sound Refining Company have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized in this d ocument is applied to all Program 2 and 3 EPA RMP-covered processes at Puget Sound Refining Company. 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, Puget Sound Refining Company has safety features 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 detectors with alarms 2. Hydrogen sulfide detectors with alarms 3. Ammonia detectors with alarms 4. Sulfur dioxide detectors with alarms 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. A utomated 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 6. Curbing or diking to contain liquid releases 7. Redundant equipment and instrumentation (e.g., un-interruptible power supply for process control system, backup firewater pump) 8. 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. Oil spill response equipment (e.g. boom, absorbent pads) EMERGENCY RESPONSE PROGRAM INFORMATION Puget Sound Refining Company maintains a written emergency response program, which is designed to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substanc e, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address different aspects of emergency response, including proper first-aid and medical treatment for exposures, refinery 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, Puget Sound Refining Company 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. Changes to the emergency response program are communicated to the personnel a ssigned to emergency response and training is provided if necessary. The overall emergency response program for Puget Sound Refining Company is coordinated with the Skagit 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. Puget Sound Refining Company 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, Puget Sound Refining Company conducts periodic emergency drills that involve the LEPC and emergency response organizations. In addition, as a participant of the local CAER group, CAER provides periodic refresher training to local emergency responders regarding t he hazards of regulated substances in the refinery and neighboring industries. PLANNED CHANGES TO IMPROVE SAFETY Puget Sound Refining Company resolves findings from Process Hazard Analyses, some of which result in modifications to the process. PSRC is implementing the Paper, Allied-Industrial, Chemical and Energy Workers International Union (PACE) Triangle of Prevention (TOP) program to improve safety. Major elements of TOP are 8 hours of safety training for all employees, a root cause incident investigation program, an expanded safety metric for tracking progress, and a full time Union Health & Safety Representative. PSRC is also in the process of implementing several Process Safety Management initiatives to incorporate best practices and enhance safety programs. |