BPAmoco Yorktown Refinery - Executive Summary
BPAmoco Yorktown Refinery, Virginia |
EPA Risk Management Plan - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The BPAmoco Yorktown Refinery in Virginia 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, internal 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 American Petroleum Institute Standards and Recommended Practices, the National Board Inspection Code, the Amoco Process Safety Booklets, the Amoco Process Safety Standards and Guideline Manual, the Amoco Refining Business Group Implementation Guidelines for OS
HA 1910.119, the Amoco Recommended Good Practices Manuals, the Amoco Corporate Engineering Specifications, and the Yorktown Refinery Fire and Safety Manual. 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 BPAmoco Yorktown refinery is located at 2201 Goodwin Neck Road, Grafton, VA, 23692. The refinery is owned by BP-Amoco, p.l.c. The refinery processes 58.5 thousand barrels of crude oil per day in a variety of processes to produce petroleum products such as gasoline, #2 burner fuel, liquefied petroleum gas (LPG), etc. The refinery has 10 processes that contain materials above the threshold quantity and are, therefore, covered by the RMP rule. Of these processes, 2 qualify for Program 1 coverage and 8 qualify for Program 3 coverage. All covered processes contain
regulated flammable mixtures above the threshold quantity of 10,000 pounds. The flammable mixtures typically contain various regulated substances such as but not limited to hydrogen, methane, ethane, propane, butane, and pentane. There are no regulated toxic substances present above a threshold quantity in any process.
HAZARD ASSESSMENT RESULTS
Flammable Worst Case Scenario
The BPAmoco Yorktown refinery has performed worst case scenario (WCS) analyses as required by the rule, and has shared this information with local emergency responders as well as the surrounding communities.
Flammable Alternative Release Scenario
The alternative release scenario for the refinery is a rupture of a loading hose while loading a butane railcar. Under this scenario, the release is isolated within 5 minutes. The maximum distance to the 1 psi overpressure endpoint is .24 miles which reaches off-site. This scenario is based on industry history and is a practical scenario for emergency respons
ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
Following is a summary of the accident prevention program in place at the BPAmoco Yorktown 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. Please see Appendix 1 for clarifications regarding "blank" dates for certain Prevention Program Level 3 data elements for specific processes.
The BPAmoco Yorktown refinery 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. 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 such teams at the refinery include the Joint Union/Management Health and Safety Committee, the Refinery Process Safety Committee, and the Safety Audit Team.
Process Safety Information
The 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 inven
tories, 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). 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 sy
stems). 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 instrument 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 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 adequat
e controls are in place to manage these hazards.
The 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 experience as well as 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 recommendations are forwarded to management for resolution. 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 refinery 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 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.
The 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 (when necessary). These procedures are developed by experienced operators or supervisors 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 m
aintained current and accurate by revising them in accordance with the management of change process.
In addition, the refinery maintains Safe Operating Limit Tables 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.
To complement the written procedures for process operations, the 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.
The refinery uses contractors to supplement its workforce at varying staffing levels depending on 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 hazar
ds 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 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 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 supp
orting systems are operationally ready. A PSSR involves field verification of the construction and provides the quality assurance that accident prevention program requirements are properly implemented.
The 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 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 (MOC) team will review the use of the equipment and determine what actions will be implemented to ensure the safe operation of the equipment.
Another integral part of the mechanical integrity program is quality assurance. The 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 repair
s are made.
Safe Work Practices
The 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/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 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 refinery has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including p
rocess operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. The system ensures that required training and documentation updates are completed prior to the commissioning of the change.
The 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.
To help ensure that the accident prevention program is functioning properly, the refinery periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at
least every 3 years. Both hourly and management personnel participate in audits. 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 refinery have potential hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA 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 refinery has safety features on many processes to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce th
e consequences of (mitigate) a release. The following types of safety features are used in various processes:
1. Hydrocarbon detectors with alarms
2. Video cameras for remote monitoring
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases
2. Valves to permit isolation of the process and pieces of equipment (manual and automatic)
3. Automated shutdown systems for specific process parameters (e.g., high-high level)
4. Curbing or diking to contain liquid releases
5. Redundant equipment and instrumentation (e.g., backup firewater pump)
6. Atmospheric relief devices
7. Fire detectors with alarms
1. Fire suppression and extinguishing systems
2. Deluge systems for specific equipment
3. Trained emergency response personnel
4. Personal protective equipment (e.g., protective clothing, self-contained br
5. Mobile fire fighting equipment
FIVE YEAR ACCIDENT HISTORY
The BPAmoco Yorktown 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 refinery has not had any incidents covered by the RMP rule in the past five years.
EMERGENCY RESPONSE PROGRAM INFORMATION
The BPAmoco Yorktown 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 res
ponse agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the 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 refinery is coordinated with the York County Department of Fire and Life Safety. This coordination includes periodic meetings with York County emergency response officials. The refinery has around-the-clock communications capability with appropriate York County and emer
gency 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 meetings, the refinery conducts periodic emergency drills that involve the York County Department of Fire and Life Safety, and the refinery provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.
PLANNED CHANGES TO IMPROVE SAFETY
The BP Amoco Yorktown refinery resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned:
7 Improved blast-resistance of control rooms
7 Revisions to personnel training programs
7 Revised written operating procedures
7 New instrumentation and alarms for enhanced process monitoring
7 Relief system upgrades
Certain data elements for specific Prevention Program Level 3 processes were lef
t blank in our RMPlan submission. Specifically, the following data elements do not contain the requested dates:
Process Data Elements Containing No Date Entry
Tank 812 date of most recent MOC; date of most recent PSSR; date of last incident investigation; date when incident investigation items were/are to be completed
Tanks 800/801 date of most recent MOC; date of most recent PSSR; date of last incident investigation; date when incident investigation items were/are to be completed
F-1709 Drum date of most recent MOC; date of most recent PSSR; date of last incident investigation; date when incident investigation items were/are to be completed
Propane Storage date of last incident investigation; date when incident investigation items were/are to be completed
Propane Railcar date of last incident investigation; date when incident investigation items were/are to be completed; date of last inspection/test
Butane Railcar date of most recent MOC; date of most rec
ent PSSR; date of last incident investigation; date when incident investigation items were/are to be completed; date of last inspection/test
Explanations for each of the items listed is provided below.
Tank 812, Tanks 800/801, and F-1709 Drum
There have been no identified changes to these processes in the previous 5 years that have triggered management of change procedures; therefore, no date was entered. Prestartup safety reviews have not been required because there were no identifiable changes; therefore, no date was entered. Also, there have been no identified significant releases of regulated substances from these processes in last last 5 years; therefore, no date was entered for either item associated with incident investigations.
Propane and Butane Railcars
There have been no identified changes to these processes in the previous 5 years that have triggered management of change procedures; therefore, no date was entered. Prestartup safety reviews have not been requ
ired because there were no identifiable changes; therefore, no date was entered. Also, there have been no identified significant releases of regulated substances from these processes in last last 5 years; therefore, no date was entered for either item associated with incident investigations. In addition, we do not perform inspections or tests of railcars; however, as part of our railcar loading procedure we do conduct a visual inspection to assure the container is fit for service and to verify that the last date of inspection /test stenciled on the railcar is still valid (i.e., not past due).
There have been no identified significant releases of regulated substances from this process in last last 5 years; therefore, no date was entered for either item associated with incident investigations.