Ciniza Refinery - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Ciniza Refinery are strongly committed to employee, public, and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program which covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activity is petroleum refining. We have 15 regulated substances present at our facility in regulated quantities. These substances include 1-Butene, 2-Butene-cis, 2-Butene-trans [2-Butene, (E)], 2-Methyl-1-butene, Butane, Ethane, Ethylene [Ethene], Hydrogen, Hydrogen fluoride/Hydrofluoric acid [HF acid], Isobutane [P ropane, 2-methyl], Isopentane [Butane, 2-methyl-], Methane, Pentane, Propane, and Propylene [1-Propene]. The various hydrocarbons in this list , with the exception of methane and ethane, are components of the liquid fuels produced at this facility (gasoline, LPG, etc.). Methane and ethane are gaseous byproducts of the refining process (essentially natural gas) which are consumed onsite as fuel for the processing of crude oil. Hydrogen is also a byproduct of the refining process which is utilized onsite both as a fuel and in the sulfur removal process for the production of clean, low-sulfur motor fuels. HF acid is utilized as a catalyst in the conversion (alkylation) of light, gaseous hydrocarbons into extremely clean, high quality gasoline. 3. The Worst Case Release Scenarios and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables and Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic vessel failure in the Alkylation Unit. In this scenario, 65,000 lbs of HF acid is released from the HF storage vessel. The liquid release is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over a 10 minute period. The scenario assumes a 100% release of the maximum capacity of the storage vessel. Under conditions of Class F atmospheric stability and a 1.5 m/s wind speed (extremely stable and calm), the maximum distance of 9.9 miles is obtained corresponding to a toxic endpoint for HF of 0.016 mg/L. One alternative HF release scenario considered assumes a damaged / broken HF supply line in the Alkylation Unit. This scenario involves the release of 750 lb. of liquid HF acid. The liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate within 10 minutes. Under neutral weather conditions, the maximum distance to the HF toxic endpoint of 0.016 mg/L is 0.43 miles. A second alternative release scenario for Hydrofluoric acid assumes a liquid release due to an HF transfer hose failure during HF delivery to the facility. The scenario involves the total release of the transfer system's 70 lb. inventory of HF acid. The liquid acid is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate within 1 minute. Under neutral weather conditions, the maximum distance to the 0.016 mg/L toxic endpoint is 0.43 miles. A third alternative release scenario for HF acid involves a gaseous HF release from processing equipment in the Alkylation Unit. This scenario assumes a release of 275 lb. of HF in a vapor form. The HF-con taining vapor is presumed to be released over a 10 minute period. Under neutral weather conditions, the maximum distance to the 0.016 mg/L HF toxic endpoint is 0.31 miles. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves the catastrophic failure of a Natural Gasoline storage tank in the facility's Tank Farm. In this scenario, 4,920,000 lb. of a flammable mixture containing approximately 50% moderately volatile materials such as Pentane, Isopentane, and Butane and approximately 50% heavier, gasoline-range components is released. In accordance with the Risk Management Program's Worst Case Scenario requirements, it is presumed that the entire contents of a full storage tank are released as a vapor (a physical impossibility) which then finds an ignition source resulting in 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions (extremely stable and calm), a calculated dista nce of 1.37 miles is obtained corresponding to an endpoint of 1 psi overpressure. One alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from an LPG storage vessel in the facility's Tank Farm. The release is assumed to result in a BLEVE. The scenario involves the release of 127,000 lb. of LPG, a highly volatile, flammable mixture consisting primarily of Propane and Isobutane. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 is 0.44 miles. A second alternative release scenario submitted for Program 2 and 3 flammable substances involves a hydrocarbon vapor release from the process equipment in the Alkylation Unit. The modeled vapor release is assumed to result in a Vapor Cloud Fire. The scenario involves the release of 8800 lb. of flammable gas (primarily Propane) over a period of 10 minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of the lower flamm ability limit is <0.06 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps The Ciniza Refinery has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68. This facility was designed and constructed in accordance with API and ASME Standards. The following sections briefly describe the elements of the release prevention program that are in place at our facility. Process Safety Information Ciniza Refinery maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodologies used to carry out these analyses are What If, What If/Checklist (combined) and HAZOP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at an interval of 3 years. Any findings related to the hazard analyses are addressed in a timely manner. The most recent PHA update was performed on 1/9/1998. Operating Procedures For the purposes of safely conducting activities within our covered processes, Ciniza Refinery maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Ciniza Refinery has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequen tly as needed. Mechanical Integrity Ciniza Refinery carries out highly documented inspections and maintenance checks on process equipment to ensure proper operations. Process equipment examined during these checks includes, among other things, pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Inspection and maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by these checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at the Ciniza Refinery to manage changes in process chemicals, technology, equipment, and procedures. The most recent review/revision of maintenance procedures was performed on 06/07/1999. Process operators, maintenance personnel, or any other employee whose job tasks are aff ected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at the Ciniza Refinery. The most recent review was performed on 06/05/1999. These reviews are conducted to confirm, prior to placing equipment into operation, that construction and equipment as well as operating and maintenance procedures are suitable for a safe startup. Compliance Audits Ciniza Refinery will conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits will be carried out at least every 3 years, and any corrective actions required as a result of the audits will be undertaken in a safe and prompt manner. Incident Investigation Ciniza Refinery promptly investigates any incident that has resulted in or could reasonably ha ve resulted in a catastrophic release of a regulated substance. These investigations are undertaken to identify the cicumstances leading to the incident as well as any corrective actions needed to prevent the incident from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Ciniza Refinery truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, an evaluation of the past safety performance of the contractor is carried out. Ciniza Refinery has a stric t policy of informing the contractors of known potential hazards related to the contractor's work and the processes around which the contractor will be working. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Ciniza Refinery has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, the number and size of accidental releases have been reduced to a minimum. These release events and the estimated release quantities associated with them are summarized below. There have been 17 accidental releases of regulated substances from our facility within the last 5 years. The first release took place on 07/16/1994 and involved approximately 500 lbs of Propane and 50 lbs of Hydrofluoric acid. No deaths or injuries occurred offsite as a result of this accident. Onsite, here was one minor injury and so me property damage. There were no onsite deaths. Another release, of 50 lbs of Butane, occurred on 10/18/1994. No deaths or injuries occurred offsite as a result of this event. Onsite, there were no deaths or injuries. There was some onsite property damage. A release of 4 lbs of Hydrofluoric acid and 200 lbs of Isobutane occurred on 06/23/1995. No deaths or injuries occurred either onsite or offsite as a consequence of this mechanical failure incident. An equipment leak resulting in the release of approximately 100 lbs of Isobutane and 2 lbs of HF acid occurred on 06/24/1995. No onsite or offsite deaths or injuries occurred as a result of this event. A small release consisting of an estimated 50 lbs of Isobutane and 1 lb. of HF occurred on 07/07/1995. No deaths or injuries occurred offsite as a result of this incident. Onsite, there were no deaths or injuries. A release of an estimated 50 lbs of Butane occurred on 12/27/1995. No deaths or injuries occurred offsite as a re sult of this release. Onsite, there were no associated deaths or injuries. There was some minor onsite property damage. A release of crude oil containing approximately 215 lbs of Isopentane, 200 lb. of Butane, 50 lbs of Isobutane, 215 lbs of Propane and 310 lbs of Pentane occurred on 04/05/1996. No deaths or injuries occurred either onsite or offsite as a result of this occurrence. There was some onsite property damage. A spill of liquid hydrocarbons containing an estimated 50 lbs of Butane occurred on 06/10/1996. No deaths or injuries occurred offsite as a result of this incident. There were no onsite deaths or injuries. A small release of a liquid hydrocarbon mixture containing approximately 1 lb. Hydrofluoric acid and 5 lbs of Propane occurred on 08/19/1996. No deaths or injuries occurred offsite as a result of this incident. There were also no onsite deaths or injuries. A minor spill of a hydrocarbon liquid containing approximately 50 lbs of Butane occurred on 06/10/199 7. No deaths or injuries occurred onsite or offsite as a result of this accident. There was some minor onsite property damage. A release of 50 lbs of Butane occurred on 12/25/1997. No deaths or injuries occurred offsite as a result of this event. Additionally, there were no onsite deaths or injuries. A release of approximately 200 lbs of Propane occurred on 01/16/1999. No onsite or offsite deaths or injuries occurred as a result of this release. A small release of 2 lbs of HF acid occurred on 01/30/1999. No deaths or injuries occurred offsite as a result of this leak. Onsite, there were also no deaths or injuries. A release of 5 lbs of HF and 250 lbs of Propane occurred on 02/21/1999. No onsite or offsite deaths or injuries resulted as a consequence of this equipment leak. Another small leak consisting of an estimated 0.05 lb. of Hydrofluoric acid and 2 lbs of Propane occurred on 02/26/1999. No deaths or injuries occurred as a result of this release either onsite or offsi te. A release of LPG containing an estimated 125 lbs of Isobutane, 5 lbs of Butane, and 5000 lbs of Propane took place on 05/02/1999. No deaths or injuries occurred offsite as a result of this accident. Onsite, there was one injury and no deaths. An accidental release of light hydrocarbons containing an estimated 40 lbs of Methane, 275 lbs of Ethane, 900 lbs of Propane, 650 lbs of Isobutane, 1000 lbs of Butane, 100 lbs of Isopentane, 3 lbs of Pentane, and 2 lbs of Hydrogen occurred on 05/31/1999 due to a mechanical failure. No deaths or injuries occurred offsite as a result of this incident. Additionally, there were no onsite deaths or injuries. There was some minor onsite property damage. 6. Emergency Response Plan Ciniza Refinery maintains a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. The McKinley County LEPC is the Local Emergency Planning Committee (LEPC) for this area. The Ciniza Refinery is a member of a mutual aid group consisting of emergency response groups from surrounding communities. In addition, onsite mutual aid training/orientation sessions are conducted periodically with various local emergency response groups. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program and related programs. Major improvements to the facility's process control system, fired heater controls, and eme rgency shutdown systems have been undertaken over the past year. Additional equipment improvements / upgrades in these areas are planned for installation during the balance of 1999. Improvements to the facility's storage tank dike system are planned over the next several years with dike improvement beginning during mid-1999. Process area paving and drainage improvements to enhance emergency response capabilities began several years ago with major portions of this work being completed in 1998. Major upgrades to the facility's stormwater containment infrastructure were completed in 1998. Additional major improvements to the facility's wastewater handling system are scheduled for late 1999 and early 2000. |