Hunt Refining Company, A Corporation - Executive Summary

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                    Hunt Refining Company Risk Management Plan 
 
                              Executive Summary  
 
Table of Contents 
 
 
 
1. Accidental release prevention and response policies 
2. Description of the stationary sources and regulated substances 
3. Hazard assessment results 
4. Five year accident history 
5. Accidental release prevention program steps 
a. Employee participation 
b. Process Safety Information 
c. Process Hazard Analysis 
d. Operating Procedures 
e. Training 
f. Contractors 
g. Pre-startup Safety Reviews (PSSRs) 
h. Mechanical Integrity 
i. Safe Work Practices 
j. Management of Change 
k. Incident Investigation 
6. Compliance Audits 
7. Chemical Release Containment and Control 
a. Release Detection 
b. Release Containment/Control 
c. Release Mitigation 
8. Emergency Response Program Information / Community Awareness 
9. Changes to Improve Safety 
10. Review and Update 
 
 
 
 
 
 
 
1. ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES 
 
 
The HUNT REFINING COMPANY, TUSCALOOSA REFINERY has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested 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. 
 
 
 
 
 
 
2. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES 
 
The HUNT REFINING COMPANY, TUSCALOOSA REFINERY, located in Tuscaloosa, AL, operates a variety of processes to produce petroleum products (e.g., gasoline, jet fuel, diesel fuel, butane,) from raw crude oil.  The refinery has several  
regulated chemicals. Two LPG ( Liquefied Petroleum Gas) products, Propane and   
Butane, are flammables from that list. 
 
3. HAZARD ASSESSMENT RESULTS 
 
The worst-case scenar 
io (WCS), associated with a release of flammable substances in an RMP covered processes at the refinery, is a vapor cloud explosion (VCE) involving the full inventory of one of the largest LPG storage tanks containing Butane. No administrative controls are in place to limit the storage inventory in the tank; therefore, the full tank inventory of 202,256 lbs. is assumed to release, completely vaporize, and ignite, resulting in a VCE.  The maximum distance to the l-pound per square inch (psi)overpressure endpoint for this WCS is 0.47 miles and might affect residences and businesses beyond the boundaries of the facility.  Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this WCS.  The chance of this occurring is  
extremely remote. 
 
There is one Alternative Release Scenario (ARS) for flammable substances at the refinery. This is a VCE resulting from the release of  Pr 
opane from a relief valve (32,189 lbs.released over a 30-minute period).  The LPG release is expected to be isolated by the operators (active mitigation) within 30 minutes, maximum.  The calculated distance to the 1-psi endpoint for this event is 0.16 mile. The effects of the alternative release scenario would  extend beyond the plant boundaries and could involve one residence with two occupants. 
 
 
 
 
 
 
 
4. FIVE-YEAR ACCIDENT HISTORY 
 
The HUNT REFINING COMPANY, TUSCALOOSA REFINERY has an excellent record of accident prevention over the past 5 years.  There have been no accidents with  
any offsite consequences in the last five years. 
 
5. ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS 
 
The following is a summary of the general accident prevention program in place at the HUNT REFINING COMPANY, TUSCALOOSA REFINERY.   Because processes at  
the refinery that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and 
describes the management system in place to implement the accident prevention program. 
 
 
 
 
 
a) Employee Participation 
 
The HUNT REFINING COMPANY, TUSCALOOSA 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 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 and addresses each accident prevention program element.  In addition, the refinery has a number of initiatives under way that address process safety and employee safety issues.  These initiatives include the safety and health committee that promotes both process and personal saf 
ety.  This committee typically has members from various areas of the plant, including operations, maintenance, engineering, and plant management. 
 
b)    Process Safety Information 
 
The HUNT REFINING COMPANY, TUSCALOOSA 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 inventories, and equipment design basis/configuration information.  Specific departments within the refinery are assigned responsibility for maintaining up-to-date process safety information. Information summarizing the reference documents and their location is readily available as part of the written employee participation plan to help employees 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).  This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals.  For specific process areas, the refinery has documented safety-related limits for specific process parameters (e.g., temperature, level, composition). 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 systems).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 and temperature ratings, electrical rating of equipment, etc.  This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as  
for evaluating proposed process and facility changes to ensure that safety  
features in the process are not compromised. 
 
c)  Process Hazard Analysis 
 
The HUNT REFINING COMPANY, TUSCALOOSA 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 adequate controls are in place to manage these hazards. 
 
 
 
 
The HUNT REFINING COMPANY, TUSCALOOSA 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.  The analyses are conducted using a team of people who have operating and maintenance 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 suggestio 
ns for additional prevention and/or mitigation measures when the team believes such measures are necessary. 
 
The PHA team findings are forwarded to local and corporate management for  
resolution.  Implementation of mitigation options in response to PHA findings is  
based on a relative risk ranking assigned by the PHA team.  This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention.  All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete.  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 HUNT REFINING COMPANY, TUSCALOOSA 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 until the p 
rocess is no longer operating.  The results and findings from these updates are documented and retained.  Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained. 
 
d)  Operating Procedures 
 
The HUNT REFINING COMPANY, TUSCALOOSA 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.  These procedures can be used as a reference by experienced operators 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 maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. 
 
In addition, the HUNT REFINING COMPANY, TUSCALOOSA REFINERY  
 
maintains documents that provide 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. 
 
e)  Training 
 
To complement the written procedures for process operations, the HUNT REFINING  
COMPANY, TUSCALOOSA REFINERY has implemented a comprehensive training program for all employees involved in operating a process.  New employees receive basic training in refinery operations if they are not already familiar with such  
operations.  After operators demonstrate (e.g., through tests, skills demonstration)having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently.  In addition, all operators periodically receive refresher training on the operating procedures required to maintain their skills and 
knowledge 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. 
 
f)  Contractors 
 
The HUNT REFINING COMPANY, TUSCALOOSA REFINERY uses contractors  
to supplement its workforce during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the refinery has procedures in place to help 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 hazards that they find during their work.  This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) em 
ergency response plan requirements, and (4) safe work practices prior to their beginning work.  In addition, the HUNT REFINING COMPANY, TUSCALOOSA REFINERY evaluates contractor safety programs and performance during the selection of a contractor.  Refinery personnel periodically monitor contractor performance for the purpose of evaluating contractor safety obligations. 
 
g)  Pre-startup Safety Reviews (PSSRs) 
 
The HUNT REFINING COMPANY, TUSCALOOSA 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 supporting systems are operationally ready.  The PSSR review team uses checklists to verify all aspects o 
f readiness.  A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented 
 
h)  Mechanical Integrity 
 
The HUNT REFINING COMPANY, TUSCALOOSA 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, (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 an MOC team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. 
 
Another integral part of the mechanical integrity program is quality assurance.  The HUNT REFINING COMPANY, TUSCALOOSA 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 material  
and spare parts are used when repairs are made. 
 
i)  Safe Work Practices 
 
The HUNT REFINING COMPANY, TUSCALOOSA 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 entry into a confined space.  These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 
 
j)  Management of Change 
 
The HUNT REFINING COMPANY, TUSCALOOSA REFINERY has a comprehensive system to manage changes to 
processes.  This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented.  Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change.  Affected chemical  
hazard information, process 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. 
 
k)  Incident Investigation 
 
The HUNT REFINING COMPANY, TUSCALOOSA REFINERY promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or  
personal injury.  The goal of each investigation is to determine 
the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident.  The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results 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 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. 
 
 
 
 
6.    COMPLIANCE AUDITS 
 
To help ensure that the accident prevention program is functioning properly, the HUNT REFINING COMPANY, TUSCALOOSA REFINERY periodically conducts an audit to  
determine whether the procedures and practices required by the accident revention program are being  
implemented.  Compliance audits are conducted at least every 3 years.  Both hourly and management personnel participate as audit team members.  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. 
 
7.  CHEMICAL RELEASE CONTAINMENT AND CONTROL 
 
The processes at the HUNT REFINING COMPANY, TUSCALOOSA REFINERY have hazards that must be managed to ensure continued safe operation.  The accident prevention program summarized previously is applied to all Program 2 and 3 EPA  
RMP-covered processes at the HUNT REFINING COMPANY, TUSCALOOSA REFINERY.  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 progra 
m activities, the HUNT REFINING COMPANY, TUSCALOOSA 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 (mitigate) a release.  The following types of safety features are used in various processes: 
 
a)  Release Detection 
1. Hydrocarbon detectors with alarms 
2. Hazardous material detectors with alarms. 
3. Pressure, flow, and level detector with alarms 
 
b)  Release Containment/Control 
1.  Process relief valves that discharge to a flare to capture and incinerate                episodic releases. 
2.  Scrubbers to neutralize chemical releases. 
3.  Valves to permit isolation of the process (manual or automated). 
4.  Automated shutdown systems for specific process parameters (e.g., high     level, and high temperature). 
5.  Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank). 
6.  Curbing or diking to contain liquid releases. 
7.  Redundant equipment  
and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump). 
8.  Atmospheric relief devices. 
 
c)  Release Mitigation 
 
1.  Fire suppression and extinguishing systems. 
2.  Deluge system for specific equipment. 
3.  Trained emergency response personnel. 
4.  Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus). 
5.  Blast-resistant buildings to help protect control systems and personnel. 
 
 
 
8.    EMERGENCY RESPONSE PROGRAM INFORMATION / COMMUNITY AWARENESS 
 
The HUNT REFINING COMPANY, TUSCALOOSA 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 aspects of emergency response, including proper first-aid and medic 
al treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements.  In addition, the HUNT REFINING COMPANY, TUSCALOOSA 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.  The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes. 
 
The overall emergency response program for the HUNT REFINING COMPANY,  
TUSCALOOSA REFINERY is coordinated with 
the Tuscaloosa, Alabama, Local  
Emergency Planning Committee (LEPC).  This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives.  The HUNT REFINING COMPANY, TUSCALOOSA REFINERY has around-the-clock communications capability with  
appropriate LEPC officials and emergency 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 LEPC meetings, the HUNT REFINING COMPANY, TUSCALOOSA REFINERY conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.Consequence analysis information from this plan is on file with the LEPC.  This information is available to t 
he public.  Periodic LEPC informational meetings have, and will continue to address this analysis information. 
 
9.    CHANGES TO IMPROVE SAFETY 
 
The HUNT REFINING COMPANY, TUSCALOOSA REFINERY resolves all findings  
from PHAs, some of which result in modifications to the process.  The following types of changes will be reviewed: 
 
1. LPG tank area curbing. 
2. % LEL monitor at the LPG tank area. 
3. High level alarms on the LPG tanks. 
 
10. REVIEW AND UPDATE 
 
The offsite consequence analysis requirements of this plan shall be reviewed every 5 years, or within six months of significant changes in the processes, quantities stored or handled.
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