Ferndale Terminal - Executive Summary |
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Risk Management Plan Ferndale Terminal Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Texaco Ferndale Terminal has a long-standing commitment to worker and public safety. This commitment is demonstrated by our efforts 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, facility trained personnel will evaluate the situation, take actions within the capabilities of the facility, and/or notify the necessary outside agencies. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Ferndale Terminal is located west of Ferndale, Washington along the Straight of Georgia waters. The Terminal serves as a storage facility for Liquefied Petroleum Gas (propane and butane), receiving and sending these products via railca r, truck, pipeline and ship. The Terminal is able to store enough of both propane and butane to meet the minimum RMP reporting quantities. OFFSITE CONSEQUENCE ANALYSIS RESULTS The worst-case scenario (WCS) associated with a release of flammable substances at the Terminal occurs if the largest refrigerated storage vessel fails catastrophically, releases the contents and the contents are subsequently ignited. This vapor cloud explosion would create a 1-psi overpressure at a maximum distance of 3.6 miles. 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. Three alternative release scenarios (ARS) for flammable substances at the Terminal are developed as more realistic events and are practical for use in emergency planning and response. The first ACS assumes the ship loading connection fails catastrophically and it takes 1 minute for the emergency valve to close and stop the release. The butane that has leaked out in that minute is ignited and the ensuing fire generates a heat radiation endpoint of 5-kilowatts/square meter at a distance of 0.18 miles away. Precautions are taken to prevent this event. Once activated, the emergency valve is designed to close in less than 30 seconds and this closure is tested prior to the loading of each ship. The loading arm is pressurized with a benign gas, such as nitrogen, before each ship to check for leaks or potential problems. The second ACS assumes the largest non-refrigerated storage tank at the facility catastrophically fails, releases its contents and the vapors are then ignited in a vapor cloud explosion. The endpoint of 1-psi overpressure is calculated to be 0.31 miles away from the point of ignition. Our vessels are inspected regularly for signs of corrosion and are designed under the ASME code to be capable of containing the propane. The third ACS assumes one of the pipelines ente ring the facility completely fails and releases its contents for 10 minutes before the flow can be shut off. The released propane is vaporized and then ignited in a Vapor Cloud Explosion. The endpoint of the 1-psi overpressure is 0.28 miles away. All of the cases were modeled using RMP Comp. RMP Comp was recommended by the EPA for calculating the release scenarios. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the Terminal. Because processes at the facility that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation The Terminal encourages employees to participa te in all facets of process safety management and accident prevention, including process hazard analyses, incident investigations, and the development of operating and maintenance procedures. Employees also participate in safety meetings, resolving certain safety concerns, and updating and compiling technical documents and chemical information pertaining to the process and critical equipment. Employees have access to all information created as part of the facility's accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in a written employee participation plan that is maintained at the facility and addresses each accident prevention program element. In addition, the facility 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 facility, including operations, maintenance, engineering, and facility management. Process Safety Information The Terminal 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 inventories; safety interlocks; suppression systems; vent and relief studies; and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the equipment specifications and operating procedures. The facility maintains the process within these limits by using process controls and monitoring instruments, trained personnel, and pr otective instrument systems (e.g., automated shutdown systems). The facility 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, and electrical rating of equipment. This information, in combination with procedures and equipment operating history, provides a basis for inspection and maintenance activities, as well as for evaluating proposed process and facility changes so safety features in the process are not compromised. Process Hazard Analysis (PHA) The Terminal has a comprehensive program to identify and control hazards associated with the various processes that are identified and controlled. Within this program, each process is systematically examined to identify potential hazards and controls in place to manage these hazards, and recommend additional controls, as appropriate. The Terminal uses a variety and comb ination of applicable methodologies to conduct PHAs. These PHAs address: facility siting; human factors; qualitative evaluation of a range of the possible safety and health effects of failure of controls on personnel; and one or more of the following methodologies appropriate to determine and evaluate the hazards of the process: What-if; Checklist; Hazard and Operability (HAZOP); Failure Mode and Effects Analysis (FMEA); Fault Tree Analysis; or an appropriate equivalent methodology. PHAs are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates potential hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures. 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 risk ranking as signed by the PHA team. The approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained. The facility periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures The Terminal 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 provi de a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. In addition, the Terminal maintains information 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 Terminal has implemented a comprehensive training program for employees involved in operating a process. New employees receive basic training in process operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate adequate knowledge to perform the duties and ta sks 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, or more frequently upon request. All of this training is documented for each operator, including skills demonstration used to verify that the operator understood the training. Process maintenance personnel are trained in their perspective duties for maintaining the mechanical integrity of critical process equipment and systems. Operational and maintenance personnel also receive training on the procedures for conducting hot work permitting; management of change; and other appropriate safe work practices. Contractors The Terminal uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the facility 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 facility 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 Terminal evaluates contractor safety programs and performance prior to selection of a contractor. Facility personnel periodically monitor contractor performance with regard to their safety obligations. Pre-startup Safety Reviews (PSSRs) The Terminal conducts a PSSR for any new facility or facility modification that requires a change i n the process safety information. The purpose of the PSSR is to see that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check that construction is in accordance with the design specifications and that all supporting systems are operationally ready. A PSSR also verifies that appropriate safety, operational and maintenance procedures are in place, and adequate training has been provided to the appropriate personnel. 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. When new facilities are commissioned, a PHA is included in the PSSR. Mechanical Integrity The Terminal has established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, an d 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, and correcting identified deficiencies. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures provide that work is performed in a consistent manner and serve as basis for training. Inspections and tests are performed to help verify that equipment functions as intended and 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 situation presents an immediate safety concern), Safe Work Practices The Terminal has long-standing safe work practices in place to help provide worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to isolate energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to verify 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 perform operations and maintenance activities safely. Management of Change The Terminal has a comprehensive system to manage changes to all covered processes. This system requires that cha nges 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) determine 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. Incident Investigation The Terminal promptly investigates all incidents related to a covered process 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 p revent 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 facility 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 determine that the accident prevention program is functioning properly, the Terminal 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 lea st every 3 years. Both hourly and staff personnel participate in these audits. The audit team develops findings that are forwarded to facility 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. SPECIFIC PREVENTION STEPS The processes at the Terminal have hazards that must be managed for continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program summarized previously is applied to all RMP-covered processes at the Terminal. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The Terminal 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 the covered processes: Release Detection Hydrocarbon detectors with alarms. Release Containment/Control 1. Process relief valves that discharge to a flare to prevent overpressure of the large storage vessels. 2. Excess Flow Valves that automatically close to isolate loading connection failures. 3. Automated shutdown systems for specific process parameters (e.g., high temperature) 4. Diking to contain liquid releases. 5. Redundant equipment and instrumentation and backup systems for system failures (e.g., uninterruptible power supply for process control system, two diesel powered firewater pumps, emergency flare) 6. Atmospheric relief devices. Release Mitigation 1. Fire suppression and extinguishing systems 2. Coordination with eme rgency response personnel with practice drills and education. 3. Personal protective equipment (e.g., fire retardant clothing) FIVE-YEAR ACCIDENT HISTORY The Terminal has an excellent record of accident prevention over the past 5 years. The following table is a summary showing we have had no incidents that have occurred during the past 5 years. 1994 1995 1996 1997 1998 1999 Number of RMP Events with Onsite Effects 0 0 0 0 0 0 Number of RMP Events with Offsite Effects 0 0 0 0 0 0 EMERGENCY RESPONSE PROGRAM INFORMATION The Terminal maintains a written emergency action plan, which is in place to help protect worker and public safety as well as the environment. The plan identifies steps to be taken in case of an accidental release including: proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies. E mployees receive training in these procedures as necessary to perform their specific emergency duties. The emergency action plan is updated when necessary based on modifications made to processes or other Terminal facilities. The emergency action plan 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 Terminal has been coordinated with the Whatcom County Fire District No. 7. This coordination includes periodic emergency response drills and meetings with the Fire Departments personnel. The Terminal is manned 24 hours a day and has around-the-clock communications capability with the Fire Department. This interface provides the means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. |