Coastal Refining & Marketing Inc. - Executive Summary
RISK MANAGEMENT PLAN EXECUTIVE SUMMARY |
COASTAL REFINING AND MARKETING, INC.
I. ACCIDENTAL RELEASE PREVENTION & EMERGENCY RESPONSE POLICIES
Coastal Refining & Marketing has a longstanding commitment to both worker and public safety. Such commitment is demonstrated by the resources that we invest in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. Many policies are in place which act to guide our efforts in the areas of release prevention and emergency response. Individual policies may be found in the following documents:
1. Coastal Refining & Marketing Emergency Response Plan
2. PSM Compliance Manual
3. Safety Policies and Work Procedures
4. Standard Refinery Proce
5. Summarized Version: Oil Spill Response Plan OPA 90
II. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED
Primary Activities: refining crude oil; sulphur production;
manufacturer of benzene
Regulated Substances Handled: hydrogen; hydrogen sulphide;
saturated and unsaturated hydrocarbons with one to five carbon
atoms; hydrogen fluoride; chlorine; sulphur dioxide
Use of Regulated Substances: hydrogen sulphide used to make
sulphur; hydrogen used as fuel and to remove sulphur;
hydrogen fluoride used as catalyst for gasoline production;
light hydrocarbons used as fuel and for gasoline production;
chlorine used to treat wastewater and cooling water; sulphur dioxide produced as a product of combustion and used to produce sulphur
Quantities of Regulated Substances Handled or Stored:
Chlorine - 10,000 to 26,000 pounds
Hydrogen Sulphide - 50,000 to 100,000 pounds
Hydrogen Fluoride - 100,000 to 125,000 pounds
ide less than 10,000 pounds
Hydrogen - 25,000 to 45,000 pounds
Methane - 25,000 to 50,000 pounds
Ethane - 35,000 to 65,000 pounds
Ethene Less than 10,000 pounds
Propane 0.5 to 1.1 million pounds
Propene 400,000 to 700,000 pounds
Butanes 5.5 to 10.5 million pounds
Butenes 1.5 to 5.5 million pounds
Pentanes 2.0 to 5.1 million pounds
III. WORST-CASE AND ALTERNATE CASE RELEASE SCENARIOS
Two toxic worst case scenarios (WCS) were considered for the refinery since different populations were affected by each scenario.
One WCS is a catastrophic failure of the HF acid storage tank in the HF Alkylation Unit. Such a failure was assumed to release 85,000 pounds of HF vapor over a ten minute period. We have numerous controls to prevent such a release, however, no credit for administrative controls or safety systems was taken into account in evaluating this scenario. The distance to an ERPG 2 endpoint (20 ppm by volume) for this WCS is 3
The alternative case release scenario (ARS) for HF is a seal failure on the emulsion pump, resulting in a release of 800 pounds of HF 10.6 minutes. It was assumed that active mitigation measures, such as activating the water sprays, would be used within this time frame thus preventing further offsite consequences. The distance to ERPG 2 endpoint is 0.27 miles.
The second toxic WCS is a catastrophic failure of a chlorine cylinder at the Quintana Sulfolane/BTX cooling tower. This WCS assumes the entire contents of a full one-ton chlorine cylinder is released as a gas into the atmosphere in ten minutes. No credit for adminisstrative controls or safety systems was taken into account in evaluating this scenario. The distance to an ERPG 2 endpoint for this chlorine WCS is 2.5 miles.
The ARS for chlorine assumed a piping leak that released 100 pounds of chlorine in ten minutes. Controls were considered in evaluating this ARS. The distance to an ERPG 2 endpoint is 0.27 miles.
ARS for hydrogen sulphide is a pipe leak between the amine regenerator overhead and the thermal reactor, resulting in a release of 500 pounds of hydrogen sulphide in 21 minutes. Controls were considered in evaluating this ARS. The distance to an ERPG 2 endpoint (30 vol ppm) is 0.14 miles.
III. WCS AND ARS - continued
TWO WCS were considered for flammables since different populations were affected by each release scenario. Both cases were vapor cloud explosions (VCE) involving the full inventory of a storage tank and in both cases, no credit was taken for administrative controls, passive mitigation measures, or other safety systems.
One flammable WCS assumed 2.127 million pounds of Quintana Plant mixed butanes were released, completely vaporized, and ignited resulting in a VCE. The distance to the 1-psi end point for the mixed butanes is 1.03 miles. The other flammable WCS considered the release of approximately 1.3 million pounds of East Plant mixed butanes. The distance to a 1-ps
i endpoint for these mixed butanes WCS is 0.88 miles.
An ARS for flammables at the refinery is a VCE resulting from the release of 8000 pounds of mixed butanes from a pump seal at Quintana tanks 382 or 383. The release was assumed to last about 18 minutes before operators respond to mitigate the release. The distance to the 1-psi endpoint for this event is 368 feet. For the East Plant, an 8000 pound release will not have any significant effects on public receptor sites.
IV. FIVE YEAR ACCIDENT HISTORY
Coastal Refining and Marketing, Inc. has an excellent record of accident prevention. We investigate every incident very carefully to determine ways to prevent similar incidents from occurring. Over the last five years, there have been no releases which produced off-site effects. Unfortunately, there have been 4 accidental releases within the last five years that resulted in significant on-site effects. Of these 4, one was a fire that resulted in equipment damage - no injuries. A f
ire in December 1995 resulted in one employee fatality and one injury. Another fire in May 1999 resulted in 7 injuries. A sour naphtha release in December 1998 resulted in 10 injuries.
V. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
Coastal Refining & Marketing encourages refinery employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating technical documents to participating as a member of a process hazards analysis(PHA)team. Employees have access to all information created as a part of the refinery accident prevention program. In addition, the refinery has a number of initiatives underway that address process safety and employee safety issues. These initiatives include the Process Safety Management(PSM)Committee and the Safety Committee, which were created as part of the employee participation plan under the OSHA PSM standard. These teams typically have members
from the ranks of the hourly workers, representing various areas of the plant such as maintenance, operations, and oil movements and storage.
PROCESS SAFETY INFORMATION
Coastal's Corpus Christi, Texas refinery keeps a variety of documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters, maximum inventories for specific chemicals, and equipment design basis/configuration information. An electronic data base is used for much of the equipment design parameters. The Maintenance, Safety, and Technical Services departments have the primary responsibility for maintaining up-to-date process safety information.
Chemical-specific information is provided in material safety data sheets(MSDSs). For specific processes, the refinery has documented safe upper and lower operating limits for specific process parameters such as temperature, pressure, level, etc. the refinery insures
that the process is maintained within these limits using process controls and monitoring instrumentation, highly trained personnel, and protective systems such as automated shutdowns.
The refinery also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure/temperature ratings, electrical rating of equipment, etc. This information in combination with written procedures, established safe work practices, and trained personnel, provide a basis for inspection and maintenance activities, as well as for evaluating proposed process and facility changes to insure that safety features in the process are not compromised.
PROCESS HAZARDS ANALYSIS
Coastal Refining & Marketing, Inc.'s Corpus Christi, Texas refinery (CRMI), has a comprehensive program to help insure that hazards associated with the various processes are identified and controlled. Within this progra
m, each covered process is systematically examined to identify hazards and insure that adequate controls are in place to safely manage these hazards.
CRMI's refinery primarily uses the hazard and operability (HAZOP)analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. These analyses are conducted by a team of people who have experience in operating the unit as well as experience in the HAZOP technique.
The PHA team findings are forwarded to local management for resolution. The team assigns relative rankings to mitigation options to insure that the scenarios with the highest risk are addressed first. All approved mitigation options are tracked until they have been resolved. The final resolution of each finding 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 CRM
I refinery updates and revalidates the hazard analysis at least once every five years. These periodic reviews are conducted at this frequency until the process is no longer operating. The results and findings from these updates are treated the same as those from the first study.
CRMI's refinery maintains written procedures that address various modes of process operations, such as (1) unit start-up, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, (6) Initial start-up of a new process. These procedures can be used as a referenced by experienced operators and provide a basis for training new operators. These procedure are reviewed and annually certified as current and accurate.
The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process.
CRMI's refinery has a comprehensive training program for all employees involved in opera
ting a covered process. New employees receive basic operator training in refinery operations. Also a new operator is paired with an experienced operator to learn process-
specific duties and tasks. After operators demonstrate having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators receive refresher training at least once every three years to ensure that their skills and knowledge are maintained at an acceptable level. All of this training is documented for each
operator, including the means used to verify that the operator understood the training.
Because some contractors used by CRMI 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)unde
rstand and follow site safety rules, and (6)inform refinery personnel of any hazards that they find during their work. This is accomplished by providing contractors with a basic orientation conducted by the Contractor Safety Council and a site specific orientation conducted on-site by CRMI.
PRE-STARTUP SAFETY REVIEWS (PSSR)
The CRMI refinery conducts a PSSR for any new covered process or covered process modification that requires a change in the process safety information. For minor modifications, the management of change review serves as the PSSR. The purpose to the PSSR is to ensure that safety features, procedures, personnel, and the equipment are properly prepared for start-up prior to placing the equipment into service. A checklist is the primary means used by the PSSR team to verify readiness.
MECHANICAL INTEGRITY (MI)
The CRMI refinery has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and com
pressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this MI program include: (1)training, (2)developing procedures, (3)inspection and testing, (4) identifying and correcting deficiencies, and (5)applying quality assurance measures.
SAFE WORK PRACTICES
The CRMI refinery has safe work practices in place to help ensure both worker and process safety. Examples of these practices include (1)area entry/exit protocols, (2)lockout/tagout maintenance procedures, (3)hot work permit, and (4)confined space entry. These and other procedures, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
MANAGEMENT OF CHANGE (MOC)
The CRMI refinery has a comprehensive system in place to manage changes to covered processes. Changes to process equipment, chemicals, technology, and procedures must be reviewed and approved before being implemented. Affected chemical hazard informatio
n, process operating limits, equipment information, and procedures are updated to incorporate these approved changes. In addition, operating and maintenance personnel are provided any necessary training on the change.
The CRMI refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a catastrophic release of highly hazardous chemicals. Such incidents might include: fire, explosion, toxic gas release, major property damage on or off-site, damage to the environment, and personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent this or a similar incident from recurring. Corrective actions are tracked until complete and the investigation results are provided to all employees. Incident investigation reports are retained for at least five years.
The CRMI refiner conducts and audit at least once every three years to help insure that the accident pr
evention program is functioning properly. The audit team develops findings that are forwarded to refinery management for resolution. Correction actions are tracked until they are complete. The final resolution of each audit finding is documented, and the two most recent audit reports are retained.
CHEMICAL SPECIFIC PREVENTION STEPS
The steps in the previously summarized accident prevention program collectively act to help prevent the accident scenarios that could be caused by human errors and/or equipment failure. In addition to the accident prevention program activities, the CRMI refinery has safety features on many units to help (1)contain/control a release, (2)quickly detect a release, and (3)reduce the consequences of a release. Examples are: toxic gas detectors, relief valves, TV monitors, dump vessel, curbing and diking, uninterruptible power supply for process instruments, isolation valves, automatic shutdowns, fire suppression and extinguishing systems, water deluge system, t
rained emergency response personnel, and personal protective equipment.
EMERGENCY RESPONSE PROGRAM
The CRMI refinery maintains a written emergency response program. These procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after plant evacuation, notification of emergency responders and the public, and post incident clean-up and decontamination requirements. In addition, the CRMI refinery maintains and effective maintenance and inspection program for our emergency systems and equipment. Employees receive training in the emergency response procedure as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based upon modifications made to the refinery processes or facilities. The CRMI refinery has around-the-clock communications capability with the local emergency responders (e.g. Corpus Christi police and fire
departments, Refinery Terminal Fire Co,). This provides a means of notifying the public of an incident, when necessary, as well as facilitating quick response to an incident. Also, the CRMI refinery conducts drills and provides refresher training as necessary, to the emergency responders.
PLANNED CHANGES TO IMPROVE SAFETY
The CRMI refinery resolves all findings from PHAs, some of which result in modifications to the process(es). Some recent modifications are:
Add relief valve to GOT exchanger 44-E-26
Advanced control instrumentation for Coker Unit
Improve plant fire protection
Revamp East Plant flare
Tie PSV 10-PSV-02 into East Plant flare system
Also a plant task is working to help the plant safely manage any problems associated with the year 2000 date change.