MI RefiningDivision - Detroit Refinery - Executive Summary |
MARATHON ASHLAND PETROLEUM LLC MICHIGAN REFINING DIVISION DETROIT REFINERY Risk Management Program Plan 1. Executive Summary The Marathon Ashland Petroleum LLC, Michigan Refining Division (MRD) is committed to operating in a manner that is safe for employees, contractors, the public and the environment. It is MRD's policy to conduct its operations in accordance with the highest standards of environmental stewardship, employee and contractor safety and community responsibility. As part of this policy, MRD has established systems to help ensure safe operation of the processes at this facility. One part of these systems is a risk management program (RMP) that helps manage the risks at MRD and that complies with the requirements of the Environmental Protection Agency's (EPA's) rule 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at MRD. This document is intended to satisfy the RMP Plan executive summary requirement of the RMP rule and to provide the public with a description of the risk management program at MRD. 1.1 Accidental Release Prevention and Emergency Response Policies MRD has a long-standing commitment to the safety of the public, its employees and contractors and to the preservation of the environment. One primary element of this commitment is the prevention of accidental releases of hazardous substances in and around the refinery. MRD utilizes engineering controls, inspection programs, and detailed procedures to reduce the probability of an accidental release. In the event of a release, the MRD has a well trained emergency resp onse team to contain, mitigate, monitor, and stop the release. The emergency response team is fully trained for fire fighting, medical emergencies, hazardous material releases and spills and for ambient air monitoring. MRD evaluates each situation, responds based on our capabilities and training, and if necessary, requests assistance from outside emergency responders including local fire departments to help control and contain the release and to prevent and/or reduce the consequences of a release. In conjunction with the Wayne County and Detroit local emergency planning committees (LEPCs), the refinery has the ability to notify the local community through media broadcasting systems. The Michigan Refining Division Manager has overall responsibility for the development and implementation of the risk management program for EPA-regulated processes at MRD. However, th e specific responsibilities for certain aspects of that program have been delegated to other personnel who report either directly, or through other management personnel, to the Division Manager. Those relationships are depicted on the division organization chart. Specific responsibility for the implementation of the division process safety management (PSM) and accident prevention program has been delegated to the Division's Environmental and Safety Manager. Similarly, responsibility for the RMP hazard assessment and risk management plan has been delegated to the Division's PSM Coordinator. The division's emergency response program, including compliance with the RMP aspects of that effort, is the responsibility of the Division Environmental and Safety Manager. In keeping with our policy that safe operation is part of everyone's job, many other division personnel are also in volved in RMP activities on an ongoing basis. 1.2 MAP Regulated Substances MRD is a petroleum refinery and petroleum products facility located principally in Detroit, Michigan with a tank farm in Melvindale, Michigan and a marine terminal in Dearborn, Michigan. MRD uses crude petroleum as its primary feed material and makes a variety of petroleum-based products, including gasoline, diesel fuel, and liquefied petroleum gases such as propane and butane. Many of these products are flammable substances that EPA has specifically listed in the RMP rule and are present in the refinery process units above the EPA threshold quantity of 10,000 pounds. In total, MRD has 14 process units that are covered by the RMP rule because of their flammable process materials. These units are listed in the RMP data included with this summary (Section 1.17 of the RMP Data Elements). MRD has no toxic substance regulated by the RMP rule in sufficient quantity to be covered by the RMP rule. 1.3 Offsite Consequence Analysis MRD performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance that could affect the public or the environment. The offsite consequence analysis consisted of evaluating both worst-case scenarios and alternative release scenarios. MRD does not expect a worst-case release scenario to ever occur. An alternative release scenario represents a release that might occur during the lifetime of a facility like the refinery. Alternative release scenarios can be used to help the LEPC improve the community emergency response plan. We have submitted release scenario analyses to EPA and have shared that information with the LEPC and other organizations involved in emergency response activities. It is also available to local residents and businesses. If you are interested in this information, please contact the Detroit Refinery receptionist at (313) 843-9100 and request to speak with the Environmental and Safety Manager. The paragraphs below briefly describe the worst case and alternate release scenarios included in our risk management plan. Please recognize that none of these events have occurred at our facility. Also, for some of these events, MRD has emergency mitigation systems to help reduce the consequences of the event if it occurred. In all cases, if such events occurred, MRD would actuate its emergency response plan to respond to the event, notify local authorities and take appropriate actions to protect both our employees and people in the community. Worst-case Release Scenarios Because MRD has no toxic substance regulated by the RMP ru le in sufficient quantity to be covered by the RMP rule, the risk management plan does not include a worst-case scenario associated with toxic substances. The worst-case scenario associated with a release of flammable substances in RMP-covered processes at the refinery is a vapor cloud explosion, involving the full inventory of the largest vessel containing butane. The analysis assumes that the maximum possible inventory of 3,100,000 pounds is released, completely vaporizes, and ignites, resulting in a vapor cloud explosion. Because there are some public receptor locations just outside the refinery property, this event could affect members of the public at those closest locations. There are no Program 1 processes at the refinery. Therefore, no additional worst-case analyses are reported for such processes. Also, the refinery did not identify any worst-case scenarios that would affect public receptors other than the receptors affected by the scenarios reported above. Alternative Release Scenarios Because MRD has no toxic substance regulated by the RMP rule in sufficient quantity to be covered by the RMP rule, the risk management plan does not include an alternate release scenario associated with toxic substances. The alternative release scenario in our risk management plan for flammable substances at the refinery is from a failure of the largest vessel containing butane The failure would release 840,000 pounds of flammable material. The analysis assumed that all of this material would be involved in a boiling liquid expanding vapor Explosion (BLEVE) and showed that the fire hazard resulting from the explosion would affect public receptor locations outside the refinery. As stated previously, details regarding these scenarios have bee n included in the additional information submitted to EPA with this executive summary, and the information has been shared with the LEPCs, other organizations involved in emergency planning, and members of the local community. If you are interested in this information, please contact the MRD receptionist at (313) 843-9100 and ask for the Environmental and Safety Manager. 1.4 Accidental Release Prevention Program The following is a summary of the general accident prevention program in place at MRD. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject to the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, and because the OSHA PSM requirements are very similar to the EPA RMP requirements for refineries, this summary addresses each of the OSHA PSM elements. The PSM program at this facility has been extended by the refinery, where necessary, to satisfy EPA's Program Level 3 accident prevention program requirements. Employee Participation MRD 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, incident investigation, and compliance audit teams. Employees have access to all information created as part of the refinery's 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. Process Safety Information The refinery keeps a variety of technical d ocuments that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the refinery are assigned responsibility for maintaining up-to-date process safety information. 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 documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the operation manuals for each process unit. The refinery ensures that the process is maintained within these limits by using process controls and monitoring instruments, operating procedures, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). MRD 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 MRD has a comprehensi ve Process Hazard Analysis (PHA) program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each existing covered process and future processes are systematically examined to identify hazards and ensure that adequate controls are in place to manage those hazards. The refinery primarily 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 available. The analyses are conducted using a team of people who have operating experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as recommends accident prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team recommendation s are forwarded to local management for resolution. All approved safety improvements being implemented in response to PHA team recommendations are tracked until they are complete. The final resolution of each recommendation is documented and retained by the Environmental and Safety Department. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the refinery periodically updates and revalidates its process hazard analyses of affected units. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The PHA Team has considered offsite effects of potential releases as part of all PHA updates completed after August, 1996. The results and recommendations from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the recommendations is documented and retained. Operating Procedures MRD 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. Procedures are periodically reviewed and annually certified as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made to the process. In addition, the refinery operating procedures provide guidance on how to respond to events that result in exceeding safe ope rating limits for specific process or equipment parameters. The written operating procedures are readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, MRD has a training program for all employees involved in operating a process. New employees receive basic training in refinery operations and specific training on the process they will operate. After a new operator demonstrates through tests and skills demonstration 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 at least every 3 years. Operators are given the opportunity to take part in more frequent refresher training if desired. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors MRD uses contractors to supplement its work force 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 MAP personnel of any hazards that they find during their work. This is accomplished by provid ing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, (4) safe work practices, and (5) a work permit process (i.e., for hot work, confined space, etc.) prior to their beginning work. In addition, the refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to insure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews MRD conducts a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information (not required for replacement in kind). The purpose of the review is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to pl acing 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 review uses checklists to verify all aspects of readiness. A review involves field verification of the construction and serves a quality assurance function. Mechanical Integrity MRD has well-established practices, programs 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 sy stem 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 a management of change team will review the use of the equipment and determine what actions ar e necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. MAP 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 MRD has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control welding and other spark-producing activities, 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 MRD 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 technology information, and equipment informatio n, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change. Incident Investigation MRD 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, which may include contractors, 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 fi nal 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 refinery periodically conducts audits to confirm the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. These audits may be led by a third party contractor with assistance by refinery employees as required. The findings are forwarded to refinery management for resolution. Corrective actions taken in response to the audit team's findings are tra cked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. 1.5 Chemical-specific Prevention Steps The processes at the refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the refinery. Collectively, these prevention program activities help prevent potential accident scenarios of flammable substances caused by equipment failures or human errors. In addition to the accident prevention program activities, the refinery has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safety features are used in various processes: Release Detection Hydrocarbon detectors with alarms in the pressurized LPG storage and rail car loading area Hydrogen sulfide detectors are worn by all employees in all areas where hydrogen sulfide is present Release Containment/Control Process relief valves that discharge to a flare to capture and incinerate process materials to prevent over pressure damage to equipment; Manual and automatic valves to permit isolation of the process; Automated shutdown systems for specific process parameters (e.g., high level, high temperature); Curbing or diking to contain liquid releases; Redundant equipment and instrumentation where needed (e.g., uninterruptible power supply for some critical process control system, redundant firewater pumps); Release mitigation systems (water spray systems); Deluge system for LPG storage vessels; Trained emergency response personnel; Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus); and Blast-resistant central control building to help protect control systems and personnel. 1.6 Five-year Accident History No releases of RMP regulated substances have occurred from MRD in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site. 1.7 Emergency Response Program Information MRD maintains a written Emergency Response Plan (ERP), which aims to protect employees, public health, and the environment. The purpose of the ERP is to protect personnel and to minimize the impact on the refine ry and surrounding areas in the event of an emergency situation. The plan consists of procedures for responding to such emergencies as fires, explosions, hazardous gas or liquid releases, natural disasters, medical incidents and bomb threats. The plan addresses all aspects of emergency response including responsibilities of the Emergency Response Team, coordination of clean-up activities, timely notification of authorities, maintenance of proper documentation, and guidelines for compliance with applicable government regulations. Furthermore, the refinery has procedures that address proper use, maintenance, inspection, and testing of emergency response equipment. All employees receive annual safety training to instruct them in proper emergency response procedures. The Emergency Response Team participates in additional training sessions so that they can safely handle potenti al emergency situations. The overall ERP for the refinery is coordinated with the Wayne County LEPC, Detroit LEPC, and local community fire and police departments. These organizations form part of MRD's Incident Command System (ICS), which permits all involved parties to work together safely and effectively in order to bring a favorable outcome to an emergency situation. In order to keep the plan up to date, the emergency response procedures are reviewed at least every three years by the emergency preparedness subcommittee which includes both salaried and hourly personnel. Any changes implemented are updated in the ERP. Affected personnel are trained in regards to the changes in the ERP. 1.8 Planned Changes to Improve Safety The refinery constantly strives to improve the safety of its operations through periodic safety reviews, the incident investigati on program, and a program soliciting safety suggestions from the workers. The refinery resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned during the next 5 years: Establishment of a perimeter monitoring team; Activation of an additional emergency alarm to provide improved geographical coverage; Continuous improvements of personnel training programs; and Establishing a behavior based safety program |