Conoco Billings Refinery - Executive Summary

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Accidental Release Prevention and Response Policy  
The Conoco Billings 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. 
Description - Stationary Source and Regulated Substances 
The Conoco Billings Refinery, located at 401 South 23rd Street, Billings, Montana is majority owned by E. I. duPont De Nemours & Co. and is operated by Conoco Inc. The refinery operates a variety of processes to produce petroleum products (for example, propane, butane, gasoline products, jet fuels, and coke) from raw crude oil. The refinery has several regulate 
d flammables, such as propane and butane. In addition, the refinery processes hydrocarbons using Hydrofluoric Acid (HF), a regulated substance. 
Description - Worst-Case Scenario (WCS) and Alternative Release Scenarios (ARSs) 
Toxic WCS 
The worst-case scenario (WCS) associated with a toxic substances at our refinery is a catastrophic failure in the HF Alkylation process, resulting in a release of 130,000 lbs. of HF acid, released as a gas over a 10-minute period. Although we have numerous controls to prevent such releases and to manage their consequences, no credits for administrative controls or passive mitigation measures were taken into account in evaluating this scenario. The maximum distance to the toxic endpoint of 20 parts per million (ppm) (0.018 milligrams per liter) for this WCS is 14 miles. 
Toxic ARS 
The alternative release scenario (ARS) for HF is a 1-inch seal leak from an acid circulation pump. In this scenario, a release takes place, releasing 960 lbs. of HF acid as  
a gas over a 10-minute period. The 10-minute release duration is the approximate time necessary to depressurize the process into our emergency dump drum and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. The maximum distance to the toxic endpoint of 20-ppm (0.018 milligrams per liter) for this ARS is 0.4 miles. 
Flammable WCS 
The WCS associated with flammable substances is a vapor cloud explosion (VCE) involving the full inventory of 7,600,000 lbs.of butane from our largest storage tank. Administrative controls in place to limit the storage inventory in the tank are not considered; therefore, the full tank inventory is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is 1.6 miles. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account for this rel 
ease scenario. 
Flammable ARS 
The ARS for flammable substances at the refinery is a VCE resulting from the release of propane from a propane storage tank (105,000 lbs). The release is expected to be isolated by the operators within 10 minutes (active mitigation). The maximum distance to the 1-psi endpoint for this event is 0.3 miles. This event was selected as being a practical scenario for use in emergency planning and response.  
Five-Year Accident History  
The Conoco Billings Refinery has an excellent record of accident prevention over the past 5 years. The frequency of all-accidental releases and injuries to our employees has decreased during this period. We investigate every incident thoroughly to determine ways to prevent similar incidents from occurring and keep records of all incidents that occur at our facility. No incidents have occurred that have resulted in off-site impact during this time. The following is a brief summary of the one on-site accident involving the release 
of a regulated substance. 
On March 30, 1999, an employee preparing a piece of equipment for maintenance received a minor acid burn due to exposure to a trace amount of hydrofluoric acid. This exposure resulted in a reportable on-site injury. 
General Accidental Release Prevention Program Steps 
The following is a summary of the general accidental release prevention program in place at the Conoco Billings Refinery. All processes at the refinery regulated by the EPA RMP rule are also subject to the OSHA PSM standard. This summary addresses each of the applicable OSHA PSM elements and describes the management system in place to implement the accident prevention program. The PSM administrative procedures used for process safety management have been revised to incorporate all RMP required items and these procedures are now considered our PSM/RMP Compliance Plan. 
Employee Participation 
The Conoco Billings Refinery encourages employees to participate in all facets of process safety manage 
ment, which also includes participation in the RMP accident prevention program. Examples of employee participation range from updating and compiling technical documents and chemical information, writing operating and maintenance procedures, and participating as a member of a process hazard analysis (PHA) teams. Employees have access to all information created as part of the refinery PSM/RMP programs. 
Specific ways that employees are involved in the refinery programs are documented in our employee participation plan. It addresses each accidental release prevention program element. In addition, the refinery regularly undertakes initiatives that address continuous improvement of our process safety management system and employee safety. These initiatives include having active teams that promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. Additional information abou 
t management and site PSM Team responsibilities can be found in our PSM/RMP Compliance Plan document Employee Participation, (PSM-ADM-02). 
Process Safety Information (Process Technology Package) 
The Conoco Billings 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 such as safe operating limits (SOLs), specific chemical inventories, and equipment design basis/configuration information. Specific positions and groups within the refinery are assigned responsibility for maintaining up-to-date process safety information. Management responsibilities are outlined in our PSM administrative procedure, Process Safety Information, PSM-ADM-03, that describes our Process Technology Package (PTP) information. 
Chemical-specific information, including exposure hazards, emergency response and exposure treatment considerations, are provided 
through material safety data sheets (MSDS). 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 safe operating limits (SOL s) for specific process parameters (for example, temperature, level, and composition) in our PTPs. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument safety systems (for example, automated shutdown systems). Information covering these issues can be found in our refinery PTPs and is available for all employees to access. 
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, and other data. This information, in conjunction with written mechanical department activity procedures and trained personnel, provides the basis for established inspection and maintenance activities, as well as for evaluating proposed process changes. This helps to ensure that safety features in the process are not compromised. Additional information about our Mechanical Integrity (MI) program can be found in our site Mechanical Integrity Systems Manual and specific MI procedures. 
Process Hazard Analysis 
The Billings 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 refinery recognized techniques to perform these evaluations. All our PHA s are conducted using a team of people who have operating and maintenance experience as well as eng 
ineering expertise. This team identifies and evaluates hazards of the process and makes recommendations for additional prevention and safety measures or design changes when the team believes such actions are necessary. 
Local management reviews the PHA Team recommendations, and employees are assigned accountability to resolve all recommendation that have been made by the PHA team and accepted by local management. Implementation of recommendations in response to PHA findings is prioritized by the PHA Team. All approved recommendations being implemented in response to PHA Team findings are tracked until they are complete. The final resolution of each finding is documented and retained. Upon completion of all recommendations for a specific PHA, a final report is issued that all affected employees can access.  
To help ensure that the process controls and process hazards do not eventually deviate significantly from the original design safety features, the Conoco Billings Refinery periodica 
lly updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency for the life of the process. Again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained. Additional details, including management responsibilities, can be found in the refinery Process Hazard Analysis, (PSM-ADM-04) procedure. 
Operating Procedures 
The Conoco Billings Refinery maintains written operating procedures that address various modes of process operations, such as Startup Procedures (operations performed during the startup phase for a process including procedures for initial startup, normal startup, and startup after a turnaround or emergency shutdown); Normal; Shutdown, and Emergency Procedures. Emergency shutdown procedures include the conditions requiring shutdown and assign responsibility for determining when to initiate an emergency shutdow 
n to appropriate personnel. 
These procedures are used by all operators and provide the basis for consistent training of new operators. All procedures are periodically reviewed with a mandatory minimum review period of 24 months. The refinery Manager annually certifies that all operating procedures are current and accurate. We use our management of change procedure to track changes to procedures due to changes in chemicals or technology. Procedures are readily available to operators in the process and for other personnel to use as necessary to safely perform their job tasks. Additional information, including management responsibilities, can be found in our PSM administrative procedure that outlines this element, PSM Procedures Program, (PSM-ADM-05). 
To complement the written procedures for process operations, the Conoco Billings 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 successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. When new operators can demonstrate through tests or skills demonstration that they have the knowledge necessary to perform the duties and tasks in a safe manner, they may be qualified for a job position and allowed to work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at a high level. All training is documented for each operator, including the means used to verify that the operator understood the training. Additional information, including management responsibilities for the refinery training program, can be found in our PSM administrative procedure, PSM Training Program, (PSM-ADM-06) and site training procedures that outline specific training. 
The Conoco Billings Refinery uses contractors to supplement its workforce during periods of increased maintenance or construction activities and for specialty work. The refinery has procedures in place to ensure that contractors: 
 - perform their work in a safe manner, 
 - have the appropriate knowledge and skills, 
 - are aware of the hazards in their workplace, 
 - understand what they should do in the event of an emergency, 
 - understand and follow site safety rules, and 
 - inform refinery personnel of any hazards that they find during their work. 
This is accomplished by providing contractors with:  
 - a process overview, 
 - information about safety and health hazards, 
 - emergency response plan requirements, and  
 - safe work practices prior to their beginning work.  
In addition, the refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contractors  
are fulfilling their safety obligations. Additional information, including management responsibilities, is in our procedure Contractors, (PSM-ADM-07). 
Pre-Startup Safety Reviews (PSSR) 
The Conoco Billings Refinery conducts a PSSR for any new process or process 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 a final 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 of 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. Additional information, including management respo 
nsibilities, can be found in our document Pre-startup Safety Review, (PSM-ADM-08). 
Mechanical Integrity 
The Conoco Billings 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:  
 - conducting training,  
 - developing written mechanical activity procedures, 
 - performing inspections and tests according to our mechanical integrity plan, 
 - correcting identified deficiencies, and 
 - 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: 
 - an overview of the process, 
 - safety and health hazards, 
 - applicable maintenance procedures,  
 - emergency response plans, and 
 - applicable safe work practices. 
Written mechanical department a 
ctivity procedures help ensure that work is performed in a consistent manner and provide a basis for training or new maintenance employees. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (for example, adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment, until the identified deficiency can be corrected.  
Another integral part of the mechanical integrity program is quality assurance. The refinery incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and proper materials and spare parts are used when repairs are made. Additional information, i 
ncluding management responsibilities, can be found in our refinery PSM administrative procedure on Mechanical Integrity, (PSM-ADM-09) and our Mechanical Integrity Systems Manual. 
Safe Work Practices (SWP) 
The Conoco Billings Refinery has long-standing safe work practice (SWP) procedures, in place to help ensure worker and process safety. Examples of these include: 
 - Process Equipment Isolation, 
 - Work Authorization System (includes Hot Work, Lock Out &Tag Out, Gas Testing, and others), 
 - Incident Reporting, Handling and Follow-up, 
 - Refinery Contractor Safety Orientation and Access,  
 - Confined Space/Bodily Entry Procedure, and 
 - The Electronic MSDS System. 
These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 
Management of Change 
The Conoco Billings Refinery has a comprehensive system to manage changes to processes. This system requires that changes to ite 
ms 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. Additional information, including management responsibilities can be found in our refinery PSM administrative procedure, Management of Change, (PSM-ADM-11). 
Incident Investigation 
The Conoco Billings Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environment 
al 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 to refinery management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete.  
The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidation. Additional information about this system, including management responsibilities can be found in our procedure Incident Investigation, (PSM-ADM-12). 
Compliance Audits 
To help verify that 
our programs are functioning properly, the refinery periodically conducts audits to determine that procedures and practices developed are fully implemented. We plan to conduct two to four audits per year for specific PSM/RMP prevention program elements. These audits combined form our total compliance audit that is required every 3 years. Both hourly and management personnel from our site and other Conoco sites participate in the audit process. The audit team findings are forwarded to the refinery PSM Team where employee responsibilities are assigned. Corrective actions taken in response to the audit teams findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. Additional information about our audit program can be found in our procedure Compliance Audits, (PSM-ADM-14). 
Chemical Specific Prevention Steps 
The processes at the Conoco Billings Refinery have hazards that must be managed to ensure 
continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA RMP covered processes at the 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 program activities, the Conoco Billings Refinery has safety features on many processes 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: release detection - hydrocarbon detectors with alarms - HF acid detection systems - H2S detection systems release containment/control - process relief valves that discharge to a flare to capture and incinerate episodic releases - valves to permit isolation of the process (manual or automated) - automated shutdown systems for specific process parameters (for e 
xample, high level, high temperature) - vessel to permit partial removal of the process inventory in the event of a release (for example, dump drum) - curbing or diking to contain liquid releases - redundant equipment and instrumentation (for example, uninterruptible power supply for process control system, and backup fire pumps) - atmospheric relief devices - release mitigation - fire suppression and extinguishing systems - deluge system for specific equipment - trained emergency response personnel - personal protective equipment (for example, protective clothing, self-contained breathing apparatus, personal H2S monitors) - blast-resistant buildings to help protect control systems and personnel. 
Emergency Response Program Information 
The Conoco Billings Refinery maintains a written emergency response program in place to protect workers, public safety, and the environment. It has been developed as an integrated contingency plan per national Response Team Guidelines and is intended to 
meet all site requirements for emergency response planning. The emergency response program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. 
The procedures address all aspects of emergency response. It includes proper first-aid and medical 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 Conoco Billings Refinery has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as procedures that address the use of emergency response equipment. Employees receive training in the procedures 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 or training affected personnel on the change. The overall emergency response program for the Conoco Billings Refinery is coordinated with the Local Emergency Planning Committee of Yellowstone County. This coordination includes regular meetings with the committee, which includes emergency response officials, government officials, and industry representatives. The Billings Refinery has around-the-clock communications capability with appropriate LEPC officials of Yellowstone County and emergency response organizations (for example, the Billings 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 participating in Yellowstone County LEPC meetings, Billings Refinery personnel conduct periodic emergency drill 
s that involve the LEPC and other emergency response organizations. 
Planned Changes or Changes Made to Improve Safety 
The Conoco Billings Refinery resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes that have taken place in the last few years or are currently planned to improve safety of our refinery: 
 7 The Chlorine Gas Injection system at the Combination and Condensate Area cooling towers was removed and replaced with a sodium hypochlorite (liquid bleach) system. 
 7 The Ammonia Injection system in the Combination Area that used a regulated substance was removed and replaced with a non-regulated amine based neutralizer. 
 7 The SO2 Injection system in the Boiler House was removed. 
 7 All written operating, maintenance, safe work practice, and environmental procedures in the refinery were revised to increase information in the procedures, assist in regulatory compliance, and to make them more useful for employees wh 
o are required to use them. 
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