4.08 PublicSafety

7/28/2019 4.08 PublicSafety

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4. ENVIRONMENTAL SETTING, IMPACTS AND MITIGATION

ConocoPhillips ULSD/Strategic Modernization Project Draft EIR

4.8-1

4.8 PUBLIC SAFETY

4.8.1 INTRODUCTION

Refinery operations involve the processing and handling of substances that are classified

combustible and/or flammable with the potential for fires and explosions. Refinery operations

also involve the processing and handling of substances that are acutely toxic with the potential ofreleasing toxic vapors. The risk to the public is measured in terms of the likelihood or probability

of an accident and the severity of the consequences of an accident. Refinery practices that handle

these substances are subjected to strict process safety management programs to prevent and

mitigate potential accidents.

In addition, the Refinery generates hazardous wastes that are subject to regulations covering the

safe storage and disposal of these wastes.

4.8.2 SETTING

The ConocoPhillips Refinery is in an area with buffer zones around sources of hazardoussubstances. It is bounded by undeveloped open space to the east. Northeast of the Refinery are

industrial and open spaces. Immediately south of the active area of the Refinery is a 300- to

600-foot undeveloped area which is maintained as a buffer area between the Refinery and the

Bayo Vista residential area. This area contains the nearest sensitive receptors to the active area of

the Refinery (e.g., schools, day care centers, libraries). The closest such sensitive receptor is a

day care center, located approximately 0.4 mile south of the site of the nearest Project element.

The Hillcrest School in Rodeo, which overlooks the Refinery site, will be relocated farther away

as a result of a bond issue that was passed in 2002. This relocation is likely to occur before the

Project facilities begin operation.

4.8.2.1 GENERAL REFINERY HAZARDS

Oil refineries handle, store and process large quantities of flammable materials and acutely toxic

substances. Accidents related to these substances can result in public exposure to heat radiation

from a fire, blast overpressure from an explosion, or airborne exposure to acutely hazardous

substances. These hazards can occur from operations at the Refinery or from transportation of

hazardous materials to and from the Refinery.

The risks to public safety from potential accidents from the proposed ULSD/Strategic

Modernization Project are low, and the impacts from plausible accidental releases would be

less than significant.

No additional mitigation measures would be needed.


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Fires, which are caused by ignition of flammable materials, can result in exposure to heat

radiation. The heat decreases rapidly with distance from the flame. Refinery fires generally pose

little risk to the public, mainly because they are typically confined to the vicinity of the

equipment from which the flammable release would occur.

Explosions can occur if flammable vapors and gases are ignited or when a flammable substance

is released at high temperatures, and usually under elevated pressure. Impacts of an explosion are

expressed in terms of a sudden increase in pressure above ambient pressure, resulting from a blast

or shock wave. The types of explosions associated with refineries can include a vapor cloud

explosion (VCE) and a boiling liquid vapor cloud explosion (BLEVE). A VCE occurs when a

flammable gas is mixed with air and then encounters an ignition source. VCEs are very rare,

because they require that sufficient air be combined with the flammable gas before ignition, thus

resulting in an explosive mixture. Instead, a more common event would be a flash fire in which

ignition occurs before mixing with atmospheric air. Such fires do not result in an explosion

which could cause damaging overpressure. A BLEVE would occur when a confined flammable

liquid vessel ruptures from excess pressure because of heating. The result is a rapid expansion ofthe material as it is exposed to ambient pressure and subsequent ignition of the released liquid

aerosol and vapors. Such an event can occur if there is an external fire that engulfs a vessel

containing a flammable liquid. BLEVEs are also very rare.

Airborne exposure can occur with a release of a substance from the Refinery that is acutely

hazardous, such as ammonia, hydrogen sulfide or sulfur dioxide, or any harmful byproducts

which may occur from a fire. A release can be a threat if a harmful concentration of the gas

reaches offsite receptors.

4.8.2.2 EXISTING CONDITIONS

Hazardous Substances Handled at the Refinery

The ConocoPhillips Refinery is on the Government Code 65962.5 of the Resources

Conservation and Recovery Information System (RCRIS) of hazardous waste generators. Wastes

generated are stored and disposed of in accordance with applicable regulations. Hazardous

wastes are manifested and shipped to approved, permitted facilities. The Refinery generates

approximately 30 tons of non-RCRA Hazardous Waste (e.g., oily trash, sand blast grit), over the

period between turnarounds. The period between turnarounds is approximately two to three

years. The facility generates approximately 800,000 pounds of spent nickel/molybdenum catalyst

and 30,000 pounds of cobalt/molybdenum type spent catalyst, which are removed every 30 to 36

months (at the end of the useful life of the material). These materials are considered hazardousunder RCRA. However, the spent catalyst is sent offsite where it is processed to reclaim and

regenerate the material, and thus is not considered a waste.

Existing Safety Management Systems

The ConocoPhillips Refinery stores and processes materials classified as acutely toxic and

flammables, which could pose hazards during process upset conditions. Historically, the


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petroleum industry has addressed concerns about potential catastrophic accidents by developing

design standards intended to minimize either the likelihood of these events or consequences. In

recent years, federal and State regulations have taken an increasingly active role in requiring

facilities to assess and document these risks as well as take further action to reduce them.

Following is a brief description of the how the Refinery addresses safety issues.

Design

As an industrial facility handling hazardous chemicals, the ConocoPhillips Refinery must be

constructed and operated to certain codes and standards, which are enforced via administrative

mechanisms such as internal audits, design reviews, and building inspections. Some of the main

design standards include: the American Petroleum Institute Recommended Practice 750, Codes of

Management Practices of the Chemical Manufacturers, American National Standards Institute

B31.1: Power Piping, American National Standards Institute B13.3: Petroleum Refinery Piping,

National Fire Prevention Association 30, and the Uniform Building Codes.

Inspections

In order to ensure integrity, safety and regulatory compliance, the ConocoPhillips Refinery

maintains and conducts various inspection programs. These programs are carried out by the

Engineering Inspection Department using techniques recognized and accepted by the petroleum

industry. Also, Operations, Maintenance, and Staff Departments conduct various safety and

regulatory compliance inspections and audits.

The Engineering Inspection Program utilizes visual and non-destructive testing methods to

inspect affected equipment for damage and deterioration. In addition, the program requires the

maintenance of written records of all inspections of affected equipment. The Program covers a

variety of plant equipment including tanks, pressure vessels, piping, relief valves, and otherrelated components. The program provides for a planned inspection of new equipment prior to

Refinery acceptance, as well as of existing onsite equipment.

Training

The Refinery conducts a safety-training program for all employees. New employees are given

safety indoctrinations, and affected employees receive annual refresher training in the following

areas:

Injury reporting procedures; Emergency reporting procedures; Safety hazard reporting procedures; Use of personal protective equipment; The companys Emergency Plan and Organization; Location and use of respiratory equipment; Use of hand-held fire extinguishers; Location and use of fire hoses; Safety procedures to be used in the event of a release or potential release of a hazardous material; Chemicals and wastes present at the facility and their associated hazards; Information labels, forms, and Material Safety Data Sheets (MSDS);


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Proper methods of handling hazardous materials; Reporting of adverse health and environmental effects; Use, capabilities, and locations of emergency response equipment and supplies; The facilitys Emergency Response Plan; Procedures for the control of a toxic and hazardous materials release; Reporting and notification procedures; Procedures for coordinating with emergency response organizations; and OSHA HAZWOPER trainingIn addition to safety training, the Refinery conducts an operator-training program to ensure

operator competence. The program provides training in policies and procedures, safety and

health hazards, and task specific procedures and practices. All operator trainees must

successfully complete a Basic Training Program, prior to working as an operator. The program

includes basic training in the areas of distillation, refining, chemistry, physics, environmental

screening, maintenance, instrumentation, and specific safety hazards. Once a trainee has

completed the Basic Training Program, assignment to an operating area is made and the Process

Foreman continues the instruction of the trainee.

When new equipment or processes are installed, the Process Foreman conducts training sessions

similar to those given to operator trainees, to familiarize the trainees with the new equipment

and/or processes. It is the responsibility of the Process Foreman to maintain training records for

all operators.

Process Safety Management (PSM)

The Federal Occupational Safety and Health Administration (OSHA) adopted a rule in 1992

known as Process Safety of Highly Hazardous Chemicals which addresses the prevention of

catastrophic accidents. The requirements of the PSM rules are directed primarily at protecting

workers within the facility. One of the key components of the required PSM systems is theperformance of process hazard analyses, which are assessments to anticipate causes of potential

accidents and to improve safeguards to prevent these accidents.

Management of Change (MOC)

In order to comply with the Process Safety Management requirements, the ConocoPhillips

Refinery has established procedures for the Management of Change (MOC). The purpose of

these procedures is to ensure that changes to process chemicals, technology, equipment, facilities,

or critical procedures do not cause plant facilities to be operated outside of their design limits or

introduce new hazards to plant operations.

Applicable requirements of the MOC may include an environmental review, health & safety/loss

control review, process hazards analysis, project field safety check, HAZCOM Review/MSDS

update, new or revised procedures, operator training, operating manual update, maintenance

records update, equipment inspection update, process flow diagram update, piping and

instrumentation diagram (P&ID) update, electrical drawing update, instrument loop sheet update,

or other requirements deemed necessary by the reviewing engineers.


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Spill Prevention and Countermeasure Control Plan (SPCC)

In compliance with the U.S. Pollution Prevention Act of 1990, the Refinery maintains a Facility

Response Plan and SPCC Plan for existing operations. This Plan is updated every three years.

Risk Management PlanThe 1990 Clean Air Act Amendments require that facilities utilizing Extremely Hazardous

Materials in amounts over specific threshold quantities prepare a Risk Management Plan. The

Refinerys Risk Management Plan (RMP) includes three main components: (1) hazard

assessment; (2) release prevention planning; and (3) emergency response planning. The

California Accidental Release Prevention (CalARP) Program was finalized in 1997 as

Californias version of the Federal Risk Management Program. This Plan is updated when there

are changes that would affect the use or storage of acutely hazardous substances. Upon

completion of this project, the RMP will be updated. In addition, the Hazardous Materials

Business Plan will have to be updated.

County Industrial Safety Ordinance

Because incidents have occurred at industrial facilities in Contra Costa County since the adoption

of state and federal safety programs, Regulation 450-8 has been added to the County Code of

Regulations. This regulation requires reviews, inspections, and audits that supplement existing

federal and state safety programs and the imposition of additional safety measures to protect

public health and safety from accidental releases. Modifications to this regulation are being

considered by the County to require worker skills training and testing for onsite contract workers,

oil refinery safety training and skill testing, drug and alcohol testing, and reporting of contractor

safety records.

Emergency Response Capabilities

The Conoco Phillips Refinery has an Emergency Response Plan in place to ensure that, in the

event of a fire, hazardous material release, medical emergency, or rescue situation, refinery

personnel will be able to respond to the emergency quickly and effectively so that personal

injuries, environmental damage, and/or property damage can be minimized. The Emergency

Response Plan describes the responsibilities of all facility personnel in the even of an emergency.

Additionally, the plan defines the types of actions that personnel with different levels of training

may take in response to an emergency. Furthermore, the plan describes and defines the chain of

command to be followed by personnel in an emergency. The primary responsibility for

implementing the plan rests with the Refinery, not an outside agency.

The Refinery has emergency response teams that are trained and equipped to respond to fires,

rescues, hazardous material releases, and other emergencies that could occur at the Refinery.

These teams are managed by the Supervisor of Fire Protection, whose responsibility it is to ensure

that the Emergency Response Plan is implemented and followed in the preparation for, and

response to plant emergencies.


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In the event of a release of hazardous materials, the emergency coordinator identifies the nature,

source, amount, and affected area of the release. Additionally, the coordinator assesses the

hazards to both human health and the environment, as a result of the release. It is the

responsibility of the coordinator to notify local authorities, as needed, and regulatory agencies, as

required by law and the County General Plan, which requires that all facilities adopt an

emergency response plan that includes immediate notification of the public.

The Refinery is also a member of a mutual aid organization under which facilities with

emergency response capabilities agree to assist each other.

In order to maintain readiness, the Refinery participates in monthly meeting and regular response.

These drills test notification procedures and the system of sharing emergency response

equipment. In addition, drills and/or simulations with Contra Costa County Health Services

Emergency Response Personnel are conducted at least once a year.

4.8.2.3 ACCIDENT HISTORY

Accidents that have occurred at the Refinery in the past five years are summarized below:

1/7/98, 9:02 AM, A nozzle failure at Unit 229, a Diesel Hydrotreater Unit, releasedHydrogen, hydrocarbons and Hydrogen Sulfide. The unit was immediately depressurizedto the flare system causing visible smoke from the MP-30 ground flare. No injuries on oroffsite were reported. This was a Community Warning System Level 1 event. The groundflare was replaced in September 2000 and slope deficiencies have been corrected. Thisaccident, and all accidents described below that involved flaring of waste gas and thatoccurred before the replacement of the ground flare with an elevated flare, would havereduced impacts after the existence of the elevated flare.

12/16/99, 4:10 AM, Flaring from the MP30 flare resulted in visible smoke forapproximately 2.5 hours, a Community Warning System Level 2 event. There were noinjuries reported on or offsite. Corrective actions resulting from this investigation includereplacing the MP30 flare with a smoke-free design, and to survey the fourteen inch headerfor slope problems and correct any that are found.

1/11/00, 12:35 PM, Flaring from the MP30 flare resulted in visible smoke forapproximately 5 minutes, a Community Warning System Level 2 event. A partial powerfailure caused the flaring. There were no injuries reported on or offsite. Corrective actionsresulting from this investigation include replacing the MP30 ground flare with a smoke-freedesign, review and revision of procedure, conduct refresher training of the operators onprocedure and conduct refresher training of electrical engineers on spacing requirements inhigh wind conditions.

1/15/00, 4:00 AM, Flaring from the MP30 flare resulted in visible smoke for approximately2 hours, a Community Warning System Level 2 event. There were no injuries reported onor offsite. Corrective actions resulting from this investigation include replacing the MP30flare with a smoke-free design, and to survey the fourteen inch header for slope problemsand correct any that are found.

2/7/00, 4:50 AM, A Catacarb leak and Hydrogen Fire at the Unicracking Unit (Unit240, Plant 4). The Hydrogen fire lasted approximately 10 minutes. The unit was


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immediately depressurized and the catacarb leak was isolated. There were no injuriesreported on or offsite. All appropriate agencies were notified. A Root Cause Analysisinvestigation failed to conclusively determine the cause of the highly localized corrosion incertain pipe systems in this unit. Efforts were made, however, to address contributingcauses and thus reduce the probability of reoccurrence. These include changes to thesampling and analysis schedule, development of a comprehensive resource manual andadditional training on rapid corrosion causes.

3/17/00, 11:25 AM, Sour Naphtha vapor from Tank 271 caused odors in the community.The odors were caused by sweet fuel gas from Unit 248 (the Unisar) leaking into Tank 271,which contained Sour Naphtha. The actual leak to the tank was isolated within 25 minutes,however odors lingered for several hours in the community. No injuries were reported on oroffsite. Odor complaints were received from the community. Corrective actions resultingfrom this investigation include: modifying refinery procedures, investigation ofalternatives for degassing boundary valves to blowdown prior to sending to tankage andreplacing the valves at the next turnaround.

6/27/01, A 1.2 barrel gasoline leak from line 101 was the result of localized external

seawater corrosion on the underside of the pipe. All appropriate agencies were notified.The entire low lying section of line 101 has been replaced.

5/31/02, between 5:00 AM and 7:00 AM, a process upset occurred at the HydrogenPurification section of the Unicracker Unit 240. A spray of liquid catacarb solution(approximately 388 lbs) was released in the form of aerosol droplets to the atmospherefrom the B-401 stack. Contra Costa Health Services and Phillips H/S staff found noevidence to indicate any health or significant off-site impact. There were no injuriesreported. 7/10/02 at approximately 3:36 PM, The A turbine located at the Steam PowerPlant unexpectedly shutdown. This was followed by an unexpected shutdown of the CTurbine. The Refinerys other Turbine B had shutdown unexpectedly earlier in themorning and was being prepared for restart. The Refinerys other source of steam, the B-1Boiler, had previously been taken out of service to complete NOx Reduction project work.

The outage of all 3 turbines in this situation resulted in a refinery-wide loss of steamproduction. When this occurred, a plant wide shut down of all operating units was initiatedin accordance with procedures. A Community Warning System level 2 was initiated. As aprecautionary measure Phillips requested an upgrade of the Community Warning System toa level 3, Shelter in Place for the Crockett area only, due to the smoke direction from theflare. No injuries were reported within 24 hours of the end of the flaring event.

4.8.2.4 APPLICABLE REGULATIONS

There are a number of federal and state regulations that focus on reducing the risks from chemical

hazards, some of which include:

California Accidental Release Prevention (CalARP) Program, U.S. Occupational Safety and Health Administration (OSHA) Process Safety Management

(PSM) Rule,

U.S. EPA Accidental Release Prevention/Risk Management Plan (RMP) Rule, California OSHA Injury and Illness Prevention Program, and Contra Costa County Industrial Safety Ordinance.


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These regulations require that facilities assess the potential for accidental releases of acutely

hazardous substances, and programs must be established to minimize the frequency and extent of

accidental releases. The regulations are geared to protect both workers and the general public.

After the proposed Project components are installed at the Refinery, a revised RMP will be

carried out to satisfy the CalARP Program. The RMP requires that a detailed hazards and

operability study (HAZOP) of the changed components be carried out. The RMP also requires a

revised offsite consequence analysis of plausible accidents. The new RMP will also include a

revised accident prevention and training program as well as pre-startup safety reviews and safety

requirements for contractors conducting hot work activities. The RMP will cover accidents that

might happen from the Project by building on the risk analyses carried out for the existing

equipment.

4.8.3 SIGNIFICANCE CRITERIA

Impacts would be considered significant if:

The Project would create a significant hazard to the public or the environment through theroutine transport, use or disposal of hazardous materials or reasonably foreseeable upset andaccident conditions involving the release of hazardous materials into the environment.

The Project would emit hazardous emissions or handle hazardous or acutely hazardous,substances or waste within one-quarter mile of an existing or proposed school.

The Project is identified on a list of hazardous material sites and, as a result, would create asignificant hazard to the public or the environment.

The Project would impair the implementation of or physically interfere with an adoptedemergency response plan or emergency evacuation plan.

The Project would expose people or structures to a significant risk of loss, injury or deathinvolving wild fires.

The Project would be in noncompliance with any design code or regulation ornonconformance with National Fire Protection Association standards.

The Project would be in nonconformance with regulations or generally accepted industrypractices related to operating policies and procedures concerning design, construction,security, leak detection, spill containment or fire protection.

The Project would result in an increased risk of fatality or serious injury or significantexceedance of the EPA risk management exposure endpoints off site.

With regard to accidental releases of acutely hazardous materials, the significance of any

potential upset or accident is judged both by the severity of the impact and its likelihood of

occurrence. Methods used by regulatory agencies to evaluate risks, including the California

Accidental Release Program are used, in which the likelihood (probability) of an accidental

release is combined with the severity of the offsite consequence to determine if the event would

be significant. Figure 4.8-1 shows a matrix that combines likelihood with offsite consequence.


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FIGURE 4.8-1

RISK MATRIX FOR RANKING SCENARIOS

Frequent More than once

per year (0 to 1 years)

Periodic Once per decade

(1 to 10 years)

Occasional During facilitylifetime (10 to 100 years)

ProbabilityofRelease

Improbable(over 100 years)

Very Low

(no injury or damage)Low

(minor injury or

damage)

Moderate

(moderate injury or

damage)

High

(severe injury or fatality)

Consequence of Release

These combinations of severity and likelihood identify situations of majorconcern that are considered significant

An accidental release is judged to be significant if both the likelihood of the event and the offsite

consequence are in the moderate or high category.

4.8.3.1 SEVERITY OF AN ACCIDENT

Severity criteria must be defined separately for each type of consequence due to the physical

differences in the effect of each. The types of accidents considered in this evaluation include

toxic releases, fires, and explosions. These hypothetical accidents could result in potential toxic

gas exposure, heat impacts, and blast consequences. In qualitative terms, the severity of these

consequences can be described as very low, low, moderate, and high. A very low severity

includes consequences that can be detected but are not expected to result in even minor injury to

the surrounding community. A low severity level corresponds to minor irritation or injury. A

moderate level of severity corresponds to moderate property damage or injury. A high level of

severity corresponds to major damage, serious (i.e., irreversible) injury, or fatality.

Specific criteria have been established to categorize impact severity for the types of consequencesthat could occur with this proposed Project. These criteria are defined for toxic gas exposure; for

exposure to thermal radiation, and explosion effects. The severity criteria are applied to

consequences determined for persons at or beyond the Refinery fence-line. The hazard

evaluation criteria for these types of consequences are summarized in Table 4.8-1. As stated

above, those impacts that are determined to be moderate to high in frequency and in offsite

consequence would be considered to be significant.


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TABLE 4.8-1

HAZARD EVALUATION CRITERIA

Criteria

Hazard

Very Low(no injury or

damage)

Low(minor injury or

damage)

Moderate(moderate injury

or damage)

High(severe injury or

fatality)

Blast (psi) < 0.5 0.5 to < 1.0 1.0 to < 2.3 2.3

Thermal Impact(kW/m

2)

< 1.0 1.0 to < 5.0 5.0 to < 12.5 12.5

Ammonia (ppm) < 75 75 to < 200 200 to < 1,000 1,000

SO2

(ppm) < 0.3 0.3 to < 3 3 to < 15 15

NOTE: The lower threshold for a Moderate hazard is set at the RMP significance threshold for blast and thermalimpacts and at the Emergency Response Planning Guideline (ERPG-2) concentration level for ammonia andSO

2. The ammonia stored is aqueous ammonia, and the exposure limits are for gaseous ammonia that

evaporates from the solution. The ERPG exposure durations are one hour. ERPG levels may be replaced bynew Acute Exposure Guideline Levels (AEGLs) which are under development by the National ResearchCouncils Committee on Toxicology. AEGLs will be developed for the 300+ extremely hazardoussubstances listed in Title III of the Superfund Amendment and Reauthorization Act, including ammonia andSO

2, and will establish levels for each of five exposure periods: 10 minutes, 30 minutes, 1 hour, 4 hours, and

8 hours

4.8.3.2 LIKELIHOOD OF AN ACCIDENT

The likelihood or probability of an occurrence, shown in Figure 4.8-1, is expressed as Frequent,

Periodic, Occasional, Improbable, and Remote. In qualitative terms, a Frequent likelihood is an

event that is expected to occur about once a year. A Periodic likelihood is one that might occur

once per decade. An Occasional likelihood is defined as an event that may occur once during the

lifetime of a project. An Improbable event is one that may occur once every 100 to 10,000 years,

and a Remote event is one that is unlikely to occur at all. The expected frequency for each type

of hazard is given in Table 4.8-2, based on references that are footnoted in the table. The Table

deals with the various types of failures that can occur for equipment associated with refineries.

These failure rates form the basis upon which specific risk scenarios related to the Project can be

evaluated. The expected failure frequencies identified in Table 4.8-2 were applied to the accident

scenarios that are described in the Operations Impacts Section to determine significance.

4.8.4 IMPACTS AND MITIGATION MEASURES

4.8.4.1 CONSTRUCTION IMPACTS

Risk of accidents during the construction phase can be minor accidents confined to actual

construction events. Although no major structural demolition is required for the Project, minor

demolition (e.g., pipe supports, piping) would be required. These demolition activities would

generate asbestos containing materials (ACM) consisting of approximately 8,400 cubic yards of


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4. ENVIRONMENTAL S

TABLE 4.8-2 (Continued)

QUALITATIVE AND QUANTITATIVE ESTIMATES OF FAILURES THAT MAY CONTRIBUTE TO


4.8-12

Rail car accidentbutane

Improbable Approximately 3% of train accidents involve hazardous materialsfwhile the serio

accident rate is approximately 7 accidents per one million train-miles (computed

risk is for train-miles and not car-mile, adding additional butane tank cars to exisrisk of a rail accident when transporting additional butane from the facility.). SerAccident Frequency = 7.1 / million train miles

Truck connect/disconnect accident

Improbable Human error rateh

is about one per 2,000 operations. For an additional ammonia24 additional connect/disconnects per year. A bad connect/disconnect would the83 years. The likelihood of any connection release (small spill) is one in ten andone in 40.

hThe approximate release rate for a bad hookup releasing a large quan

one per 3,300 years. Accident Frequency = 3.0 E-04 / year

aSeismic Shaking Hazard Maps of California, Map Sheet 48, 1999. California Division of Mines and Geology.

bA.I.Ch.E. Chemical Process Quantitative Risk Analysis, 2000

cF. Lees, Loss Prevention in Process Industries, Vol 1, 1992

dA.I.Ch.E. Process Equipment Reliability Data, 1989

eComputed using data from U.S. DOT 2000 National Transportation Statistics

fU.S. DOT, Hazardous Materials Safety, Hazardous Materials Information System, 2002

gFWHA-RD-89-013, Present Practices of Highway Transportation of Highway Materials, Harwood and

hT. Kletz, An Engineers View of Human Error, 1985

Frequent: More than once per year (0 to 1 years)

Periodic: Once per decade (1 to 10 years)

Occasional: During the facility lifetime (10 to 100 years)

Improbable: 100 to 10,000 years

Remote: Not likely to occur at all


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insulation and approximately 2,000 gaskets. The removal, handling, transport, and disposal of

the ACM would be performed in accordance with established procedures and the applicable

regulatory requirements (National Emission Standards for Hazardous Air Pollutants or NESHAP,

and BAAQMD rules and regulations). The work would be performed and overseen by certified

ACM workers. The removal methods may include the use of negative pressure, glove bags, wet

methods, or other acceptable methods that are geared to minimize airborne concentrations of

ACM. The ACM would be transported in covered vehicles and disposed at appropriately

licensed facilities. Project construction activities also would generate approximately

2,000 pounds of lead paint-contaminated blasting grit from paint removal activities and several

hundred paint containers (e.g., 5-gallon containers and spray cans) from paint application

activities. As with ACM, these waste materials would be handled, stored, transported, and

disposed in accordance with applicable regulatory requirements. Since the construction activities

would be conducted under the above regulatory constraints, which are geared to protect both

onsite workers and the offsite public, the impacts to hazards would be less than significant.

4.8.4.2 OPERATIONS IMPACTS

Impact PSA-1: Possible accidental releases of acutely hazardous substances that might

result from the Proposed Project were evaluated, and none were found to cause an

unhealthful offsite impact and occur within the expected 30 year life of the plant. The

impacts would therefore be less than significant.

Mitigation: None Required.

Although no significant Project hazardous materials-related impacts have been identified, the

Project will be incorporated into the Refinery Process Safety Management System. As part of

this, a Process Hazard analysis will be performed when the Project modifications are installed Inaddition the RMP will be revised to incorporate the Refinery changes, and applicable training

programs and plans dealing with emergencies will be modified to include the Project. These

actions will ensure that the risk of accidents will be minimized.

Additionally, as is currently the case, Project hazardous materials/wastes truck traffic will be

routed to and from the Refinery via Cummings Skyway to avoid traveling through the community

of Rodeo.

Hazardous Materials from Proposed Project Operation

Petroleum refining operations inherently involve the routine use, transport, and disposal ofhazardous materials. Table 4.8-3 summarizes the existing hazardous materials associated with

the Project and the increase as a result of the Project. The Department of Transportation hazard

category and the mode of transportation is also given for each substance. These estimates are

consistent with the Project Description. The primary chemicals generated by the Project are spent

catalyst and spent sodium hydroxide. Both materials are not hazardous. The spent catalyst will

be returned to the manufacturer for recycle and reuse. Maintenance turnaround activities will

generate a small amount (approximately 40 cubic yards per turnaround) of a variety of hazardous


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TABLE 4.8-3

EXISTING AND PROJECT HAZARDOUS MATERIALS

USE AND TRANSPORTATION

Material

Department of

TransportationHazard Category

TransportationMode

Present EstimatedAverage Project Increase

LiquidOxygen

Non-Flammable Gas Truck Not used presently 1 trip/day

LiquidNitrogen

Non-Flammable Gas Truck 10 trips/month 2 trips/month

SodiumHydroxide

Corrosive Liquid Truck 3 trips/month 1 trip/month

AqueousAmmonia

Corrosive Liquid Truck 5 trips/month 1 trips/month

Amine Corrosive Liquid Truck 5 trips/year 2 trips/year

Additives Flammable Liquid Truck 3 trips/month 2 trips/month

Gasoline Flammable Liquid Pipeline

Marine

36,000 barrels/day

15,500 barrels/day

500 barrels/day

ProductDiesel and JetFuel

Combustible Liquid Pipeline

Marine

29,000 barrels/day

3,000 barrels/day

3,200 barrels/day

Gas Oil andFuel Oils

Flammable Liquid Marine 13,500 barrels /day 4,000 barrels perday

Coke Solid Truck 48 trucks/day

1,100 tons/day

8 trucks per day

186 tons per day

ProductSulfur

Molten Truck 9 trips/day

207 Long tons/day

2 trips per day

Butane Flammable Gas Rail rail cars per day

3,500 barrels/day

1 railcar/ per day

700 Barrels/day

Fuel Gas Flammable Gas Pipeline Used in refinery Used in refinery

Feed CrudeOil

Flammable Liquid Pipeline

Marine

1,350,000 barrels/mo.

900,000 barrels/mo.

300,000 barrels/mo.

No change

Waste

Seleniumcake

Regulated Waste Truck 1 ton/day 0.3 tons/day

Copper cake Regulated Waste Truck 1.9 tons/day 0.5 tons/day

Catalyst Regulated Waste Truck 40 cubic yards perturnaround (approxevery 5 years)


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wastes (e.g., exchanger sludge, iron sulfides, hydrocarbon-contaminated solids). Since there will

be no discharges from the normal use of hazardous materials, the impacts would be less than

significant.

Risk of Accidents from Proposed Project Operation

The Risks to Public Safety from accidents addresses the processes that are being added or

modified as a result of the Proposed Project, and the steps include:

Define Process modifications; Identify potential hazards; Select representative accident scenarios; Conduct an offsite consequence analysis; and Compare impacts to significance criteria.

The Proposed Project involves a number of modifications to existing Refinery processes, along

with the addition of some new processes. Specific process hazards were identified by combining

the knowledge of the equipment proposed with an analysis of the potential hazards that could

occur with these changed processes. Consequence modeling was then performed for the accident

scenarios following EPAs RMP Guidance.

The following accident scenarios were considered in the analysis, and the offsite impacts from

changes resulting from the Project are reported:

Case 1: A catastrophic failure of the 10,000 barrel (typical throughput) existing dieselhydrotreater (Case 1a) at the Refinery (baseline) resulting in an explosion and blast wave. Inthe proposed Project, this hydrotreater will be converted to naphtha service, but will maintainthe same throughput (10,000 barrels per day). The catastrophic failure was assumed to becaused by a major external event like an earthquake. The risk posed by 10,000 barrels ofdiesel in the existing hydrotreater is the baseline against which the modified naphthahydrotreater (also 10,000 barrels per day as part of the Project) is compared. (Case 1b).

Case 2: A catastrophic failure of the existing 10,000 barrels per day diesel hydrotreater(Case 2a) at the Refinery (baseline) resulting in a pool fire. The catastrophic failure wasassumed to be caused by a major external event like an earthquake. The risk posed by 10,000barrels of diesel in the existing hydrotreater is the baseline against which the modifiednaphtha hydrotreater (also 10,000 barrels per day as part of the Project) will be compared(Case 2b).

Case 3: A catastrophic failure of the existing 10,000 barrels per day diesel hydrotreater(Case 3a) at the Refinery (baseline) resulting in a BLEVE. The catastrophic failure was

assumed to be caused by a major external event like an earthquake. The risk posed by 10,000barrels of diesel in the existing hydrotreater is the baseline against which the modifiednaphtha hydrotreater (also 10,000 barrels) would be compared (Case 3b).

Case 4: A catastrophic failure of the new 35,000 barrels per day ULSD hydrotreaterresulting in an explosion and blast wave. The catastrophic failure was assumed to be causedby a major external event like an earthquake. The incremental risk of was compared with azero baseline.


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Case 5: A catastrophic failure of the new 35,000 barrels per day ULSD hydrotreaterresulting in pool fire. The catastrophic failure was assumed to be caused by a major externalevent like an earthquake. The incremental risk was compared with a zero baseline.

Case 6: A catastrophic failure of the new 35,000 barrels per day ULSD hydrotreaterresulting in a BLEVE. The catastrophic failure was assumed to be caused by a major externalevent like an earthquake. The incremental risk was compared with a zero baseline.

Case 7: A catastrophic failure of an 80,000 barrel barge containing gas oil, releasing 10% ofthe barge capacity onto water and resulting in a pool fire. A marine accident was assumed tobe the cause of the catastrophic failure of the barge. The incremental risk was compared witha zero baseline even though this is an existing risk. Only the frequency of barge departure isslightly increased due to the Project (four additional barge shipments per year), not thepotential impact of a hazardous spill.

Case 8: A transportation accident involving a molten sulfur truck resulting in the spilling ofsulfur, with a subsequent fire generating SO

2emissions. Five percent of the sulfur load

(5,100 pounds) was assumed to be combusted in one hour. The spill was assumed to occur

during the daytime. The incremental risk was compared with a zero baseline, even thoughthis is an existing risk. There would be approximately three extra sulfur trucks per day (1,095per year) associated with the project.

Case 9: A transportation accident involving an aqueous ammonia truck resulting in thespilling of its entire contents (8,500 gallons of 19.5% aqueous ammonia). The spill wasassumed to occur during the daytime. The incremental risk was compared with a zerobaseline, even though this is an existing risk. There would be approximately one extraammonia truck per month (12 per year) associated with the project.

Case 10: An unloading accident involving the aqueous ammonia truck resulting in thespilling of 400 gallons of 19.5% aqueous ammonia. The spill was assumed to occur duringthe daytime and was contained within the truck unloading area. A sump collection system

was assumed to limit the exposed ammonia surface to one square meter. The incrementalrisk was compared with a zero baseline even though this is an existing risk. There would beapproximately one extra ammonia truck per month (12 per year) associated with the project.

Case 11: A process unit accident releasing hydrogen sulfide (H2S) from the new USLD

hydrotreater. This accident scenario assumes a complete break in an H2Sline from the

recycle compressor. A one inch line containing gas with an H2S concentration of 1.5 percent

and under pressure of 1,000 pounds per square inch is assumed to break completely, releasinggas for 10 minutes before shutting down. The emissions were computed, assuming ahorizontal jet. Another scenario related to an H

2Srelease would involve a line break in the

overhead stripper. Although the H2S concentration in this line may be as high as 3%, the line

pressure would be only 100 psi, and the emissions would be lower than the other accidentscenario.

Additional release scenarios were considered but were not analyzed further for the reasons

described below. These scenarios are:

Failure of the liquid nitrogen (LN2) storage trailer;

Failure of the liquid oxygen (LOX) storage trailer;


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Failure of a 1,000-barrel butane railcar; Failure of piping associated with the new ULSDhydrotreater, and

Additional barge trips.Liquid nitrogen is currently used onsite. The project will increase usage of LN

2, resulting in two

additional trips by LN2 tank trucks per month (24 per year). As nitrogen is a non-flammable gas,

the risk posed by LN2is a cryogenic risk of burns due to contact with the skin and potential for a

suffocation hazard in a confined space if liquid or dense vapor nitrogen were to enter a confined

space. Both of these risks would occur in the immediate vicinity of any spilled LN2

and would

potentially affect emergency responders only. As these individuals will have protective

equipment and training, there is little potential for significant risk to these individuals due to a

spill of LN2. No qualitative analysis was performed for a breach of the LN

2tank.

Liquid oxygen will be a new chemical in use onsite. While LOX is a non-flammable gas, it is a

strong oxidizer and an accelerator for fires. There is no confined space hazard for oxygen, but

there is a cryogenic risk of burns due to skin contact with LOX. In itself, a LOX spill is not

hazardous except in the presence of an ignition source and fuel. If there were a simultaneous

release from the LOX tank and a nearby vessel containing petroleum products, the presence of the

oxygen could produce a more hazardous situation leading to a fire, explosion, or spontaneous

combustion. However, the probability of simultaneous, independent breaches of the LOX tank

and a nearby process vessel or tank is highly improbable. Therefore, a hazard due to a breach of

the LOX tank was not assessed. If the foundation upon which LOX would be spilled is made of

asphalt, then it could be a source of fuel and could burn in the presence of oxygen. However, the

oxygen tanks will be stored over a concrete pad, and any spilled oxygen would not contact

substances that could burn.

There will be approximately one additional butane rail car shipment per day from the Refinery,but no additional trains. Risk from rail accidents is computed on a per-train basis, not a per

railcar basis. Thus, the probability of a rail accident due to butane shipments from the facility is

not increased by the addition of one railcar per day to the train. Since the consequence of a

release of butane from a railcar breach remains unchanged, there is no added risk from the export

of additional butane from the facility. Therefore, this scenario was not analyzed.

The volume of liquids in piping to and from the new ULSD hydrotreater will be less than that

contained within the hydrotreater itself and the fluids involved are the same (diesel and naphtha).

Since a catastrophic failure of the hydrotreater was examined, there was no need to assess a

smaller nearby release associated with failure of piping in the hydrotreater unit. The hydrotreater

that is changing service from diesel to naphtha was modeled before and after the change.Although naphtha is a more hazardous substance than diesel, the capacity will remain the same.

There will be a slight increase in the number of barge loading operations at the Refinery because

of the increase from 55 to 59 annual barge shipments of gas oil. This slight increase of 4

shipments per year would result in only a very small increase in the probability of an accident.

An actual release during an accident when a barge is underway was analyzed as a pool fire and

can be considered the same as Case 7.


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Model Results for Accident Scenarios

The modeled distances to the threshold for toxic impacts are presented in Tables 4.8-4 and 4.8-5,

where Table 4.8-4 presents the results for blast and thermal hazards and Table 4.8-5 presents the

results for an inhalation hazard due to toxic gases. The modeling results for the accident

scenarios are ranked in the Risk Matrix in Figure 4.8-2. This figure shows ranking for the tenrelease scenarios in a matrix of four hazard severities and five release probabilities.

TABLE 4.8-4

PEAK IMPACT AT NEARBY RECEPTOR DUE TO HAZARD

Case Event

Distance to

Receptor (m)Explosion

(psi)Pool Fire

(kW/m2)

BLEVE

(kW/m2)

Significance Criteria

1a, 2a, 3a Catastrophic failure of existinghydrotreater (10,000 barrels perday diesel)

100 290 80 42

1b, 2b, 3b Catastrophic failure ofconverted existing hydrotreater(10,000 barrels per daynaphtha)

100 240 92 29

4, 5, 6 Catastrophic failure of newhydrotreater (35,000 barrels perday diesel)

700 3 6 2

7 Catastrophic failure of gas oilbarge resulting in a pool fire

of 8,000 barrels

100 NA 1,550 NA

Impacts are rounded to two significant figures.NA means not applicable.

All the release scenarios analyzed have extremely low probabilities (less than one release in

100 years, or


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TABLE 4.8-5

PEAK CONCENTRATION (PPM) AT NEARBY RECEPTOR DUE TO

RELEASE OF TOXIC GAS

Case Event

Distance to

Receptor (m)

Peak Offsite

Impact (ppm)

ERPG-2

(ppm)

8 Transportation accident involving moltensulfur truck, releasing 5,100 pounds ofsulfur that burns and releases SO

2

100 680 3

9 Transportation accident involvingaqueous ammonia truck releasing entire8,500-gallon contents of truck.

100 4,600 200

10 Unloading accident involving aqueousammonia truck release 400 gallons ofammonia into unloading containmentsystem.

700 49 200

11 Process unit accident involving a line

break from the recycle compressor in theULSD hydrotreater unit releasing H

2S at a

rate of 13.4 pounds per minute for10 minutes

700 1 30

NOTE: Impacts are rounded to two significant figures

FIGURE 4.8-2

SCENARIO HAZARD MATRIX FOR THE

ULSD / STRATEGIC MODERNIZATION PROJECT

Frequent More than once

per year (0 to 1 years)

Periodic Once per decade

(1 to 10 years)

Occasional During facilitylifetime (10 to 100 years)

ProbabilityofRelease

Improbable

(over 100 years)4, 6, 10, 11 5 1, 2, 3, 7, 8, 9

Very Low(no injury or damage)

Low

(minor injury or

damage)

Moderate

(moderate injury or

damage)

High(severe injury or fatality)

Consequence of Release

These combinations of severity and likelihood identify situations of major concern that

are considered significant


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Terrorism

Sabotage is one of the Public Safety issues that are evaluated when a Risk Management Plan is

updated. To minimize sabotage or terrorism, various precautionary measures have been adopted.

The standard security for the refinery to minimize these events includes a chain link fence

surrounding the entire facility with controlled gate entrances, third party security guards at all

entrance locations, roving security guards, identification badges required for entry by all

personnel, refinery personnel must authorize visitors before entry onto the facility, and general

awareness training for all employees.

Since the September 11, 2001 terrorist attacks, a security protocol program has been developed

and adopted for the Rodeo Refinery consistent with the national alert color code system.

Dependent upon the current alert level certain additional security measures are activated. These

activities may include, stationing additional security guards at critical locations, additional sheriff

patrols, restricted parking, restricted access, additional vehicle searches, and other sensitive

security measures to protect the facility.

_________________________

4.8.5 CUMULATIVE IMPACTS

Impact PSA-2: Other industrial projects in the region are located too far away from the

Refinery to cause potential cumulative public safety impacts. In most cases, impacts from

fires, explosions, or from toxic gas releases are limited to the property fence line or near the

fence line. Also, the probability of an accidental release occurring from a cumulative

project at the same time that an accident would occur at this Project would be extremely

low. Therefore, cumulative impacts would be less than significant.

_________________________

REFERENCES PUBLIC SAFETY

A.I.Ch.E. Chemical Process Quantitative Risk Analysis (2000)

A.I.Ch.E. Process Equipment Reliability Data, 1989

California Division of Mines and Geology, Seismic Shaking Hazard Maps of California, MapSheet 48, 1999.

Contra Costa County. Safety Elements of the General Plan (1995 2010). July 1996.

Harwood, 1989. Present Practices of Highway Transportation of Materials, FWHA-RD-89-013.

Kletz, T, An Engineers View of Human Error, 1985.

Lees, F, 1992. Loss Prevention in Process Industries, Vol 1, 1992


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U.S. DOT, 2000 National Transportation Statistics

U.S. DOT. 2002. Hazardous Materials Safety, Hazardous Materials Information System, 1/23/02.

4.08 PublicSafety

Documents

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