Koch Petroleum Group L.P. - CC West Refinery - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Koch Petroleum Group (KPG) L.P. is owner and operator of two petroleum refineries in Corpus Christi, Texas and has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as personnel training 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. At the time of this filing, the KPG refineries in Corpus Christi continue to enjoy a safety record paramount in the refining industry of greater than six million man-hours without a lost-time work injury. This RMP is for KPG West Refinery in Corpus Christi, Texas. The KPG East Refinery is addressed in a separate EPA RMP submittal. The KPG facility at Corpus Christi performs a number of processing functions that would traditionally be classified as Petro chemical Refining and Specialty Chemical Processing. For the remainder of this submittal, the KPG West refinery in Corpus Christi will be referred to as 'KPG' and the primary processing function at the facility will be generically referred to as 'Refining'. KPG has enjoyed a nearly perfect safety record, and our emergency response capabilities are among the best in the refining industry. The cornerstones of our emergency response capabilities include a 24-hour, 365 day/year, fully paid, in-plant industrial emergency response group (Refinery Terminal Fire Company - RTFC). Today, only three other refineries in the United States employ this capability. In addition, due to the Corpus Christi Port Industrial consortium, over one hundred trained emergency responders could be deployed with state-of-the-art emergency response equipment within an hour if necessary. Another aspect of our emergency response capabilities is immediate notification of our adjacent neighbors through the Communi ty Alert Network (CAN) and Radio Broadcast AM 620. CAN is a computerized calling network that is capable of making multiple phone calls simultaneously to pre-determined calling zones. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES KPG operates a variety of processes to produce petroleum products (e.g., natural gas, propane, butane, condensate) from raw crude oil. The refinery has several regulated flammables, such as propane, butane, etc. In addition, the refinery uses and/or processes hydrogen fluoride (HF), hydrogen chloride (HCl) and methyl chloride (CHCl3), which are also regulated toxic EPA RMP substances. HAZARD ASSESSMENT RESULTS AND FIVE YEAR ACCIDENT HISTORY (KPG WEST REFINERY) Program Level 3 Toxic Scenarios The worst-case scenario (WCS) associated with toxic substances in the refinery is a catastrophic failure at the HF Alkylation Unit of the HF turnaround storage tank, resulting in a significant release of HF gas over a 10-minute period. Although we have numerous controls to prevent such releases and to manage the consequences, no credit for engineered or administrative controls or passive mitigation measures was taken into account in evaluating this scenario. The maximum distance to the toxic endpoint of 0.016 mg per liter could be as far as 25 miles for the WCS. The HF Alkylation Unit alternative release scenario (ARS) is a tandem pump seal failure of the second stage HF acid circulation pump. The duration of the potential accident scenario is the assumed time necessary to isolate and mitigate the release event e.g., 15-minutes. Early detection and mitigation of the HF release would be facilitated by the presence of HF detectors, shutdown/isolation valves and remotely controlled water spray monitor network capable of delivering 9,000 gallons per minute of water when needed. The 15-minute response time is a conservative estimate and it is likely the response and mitigation time would be much less given the refinery's HF det ection and mitigation systems. Of the toxic ARSs analyzed (e.g., HF, HCl and CH3Cl), the HF release event represents the largest impact distance of 0.4 miles to an endpoint concentration of 0.016 mg per liter. Other ARS analyzed for this filing include potential release scenarios at the Poly Methyl Biphenol (PMB) Unit that handles HCl and CH3Cl. The PMB is also an EPA RMP Program Level 3 process unit; for more details on these scenarios, see the RMP Submit documentation. Program Level 3 Flammable WCS and ARS The Program Level 3 flammable WCS at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest FCCU Storage Tank (08FB223) containing mixed light end hydrocarbons (C3-C5). Although we have numerous controls to prevent such releases and to manage the consequences, no credit for engineered or administrative controls or passive mitigation measures was taken into account in evaluating this scenario; therefore, the full tank inventory is assumed to be released, completely vaporize, and resulting VCE occurs. The maximum impact distance to the 1-psi endpoint could be as far as 1.8 miles for the WCS. For all of the ARS reviewed, none have offsite impacts to residential public receptors; however, one commercial receptor could be impacted. The ARS scenario postulates a propane release from a storage tank (FB-210) over a 15-minute period and an ensuing VCE occurs. The 15-minute release duration is the maximum time necessary to isolate and mitigate the release scenario. The maximum potential distance to the 1-psi endpoint could be as far as 0.18 miles. Program Level 1 Flammable WCS Of the units reviewed for RMP qualification, seven refinery-processing units were determined to be Program 1. This category of units includes the following process areas: (1) Treaters, (2) Mid Crude, (3) Cumene, (4) Coker, (5) West Crude, (6) PX ISOM, and (7) UDEX Complex. Potential offsite consequences for these units range from 0.1 miles to 0.3 miles impact distances assuming a 1 psi endpoint threshold. For each scenario it was assumed that mixed light end hydrocarbons (C3-C5) were released and an ensuing VCE occurs. No passive mitigation measures were taken into account in evaluating these WCSs. Five Year Accident History KPG has an excellent accident prevention record; there have been no RMP defined accidents that have occurred over the past five years involving EPA RMP chemicals for the qualifying units. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at KPG. Because processes at the refinery that are regulated by the EPA RMP rule 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. For all process units containing threshold quantities (TQs) of highly hazardous chemicals (HHCs) per OSHA PSM, the prog rams summarized below are applied equally to EPA RMP covered and EPA RMP non-covered process units. Employee Participation KPG 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 all 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 forming teams to promote both process and personal safety. The teams typically have members from various area s of the refinery, including operations, maintenance, engineering, and refinery management. Process Safety Information KPG keeps a number 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. The Records Department within the refinery is responsible for maintaining up-to-date process safety information. The majority of the information that is maintained by the records department is available on the KPG Intranet. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS) that are maintained on the KPG Intranet. This information specifically addresses 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 certain process parameters (e.g., temperature, level, composition) in the unit operating procedures, which can be found on the KPG Intranet. The refinery maintains these parameters within defined 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. Process Hazard Analysis Within the PHA program, each process is systematicall y examined to identify hazards and confirm that adequate controls are in place to manage potential hazards. KPG primarily uses the hazard and operability (HAZOP) analysis technique to perform the majority of the PHA evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted with a team of people who have operating and maintenance experience as well as engineering expertise. The PHA team is led by a leader with experience and qualification in the HAZOP analysis technique. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are typically addressed by assigning action items to PHA team members responsible for managing unresolved issues during the PHA. Implementation of action items in respons e 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 PHA action items are tracked and maintained in KPG Intranet software, Koch Incident Tracking System (KITS). Within this software, each employee assigned an action is responsible for execution of the action item by an assigned target date. If the employee neglects or forgets to execute their action item, they are automatically reminded via email of their assigned action and upcoming due date. For delinquent action items supervisors are emailed notification of employee's outstanding action items and the supervisor is responsible for taking appropriate action. The completion of action items at KPG is considered a minimum expectation of all employees and if not completed will decrease an employee's performance pay. To help ensure that the process controls and/or process hazards do not eve ntually deviate significantly from the original design safety features, KPG 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 for the lifetime of the process unit. The results and findings from base and revalidation PHAs are documented and retained. Once again, the team findings are tracked via action items and the final resolution of the findings are documented and retained in KITS. Operating Procedures KPG 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. T he procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process or KPG's "Operating Procedure Review/Approval Process (5/99; Rev 0)" procedure. In addition, KPG maintains upper and lower safe operating limits for all process equipment in the Unit Operating Procedures and provides 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 available on the KPG Intranet and at each control room area. Training To complement the written procedures for process operations, KPG 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 the basic training, an operator in training is paired with a senior operator to le arn process-specific duties and tasks. 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 to confirm that their skills and knowledge are maintained 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. Contractors KPG uses contractors to supplement its workforce as part of routine practices or during periods of increased maintenance or construction activities. Before a contract employer is accepted at KPG, the contract employer is asked to complete a pre-qualification form (PQF) indicating the contract employers' safety record in industry. The PQF is KPG's initial screening process for accepting a contract employer to work at the refinery and also used as an ongoing screening tool to renew and approve continued support from contract employers. Because some contractors work on or near process equipment, the refinery has procedures in place designed to oversee that contractors: 7 perform work in a safe manner, 7 have the appropriate knowledge and skills, 7 are aware of the hazards in their workplace, 7 understand what they should do in the event of an emergency, 7 understand and follow site safety rules, and 7 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) emergency response plan requirements, and (4) safe work practices prior to beginning work. In addition, KPG evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contr actors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) KPG 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 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. Mechanical Integrity KPG has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compr essors, 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. The purpose of these activities is to form a system that maintains the mechanical integrity of the process equipment. The governing documents that address KPG's mechanical integrity program include the following Equipment Synopsis documents for: 7 Fixed Equipment 7 Electrical Equipment 7 Instrumented Systems 7 Machinery 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 toolbox and vendor 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. KPG 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. Safe Work Practices KPG has a long-standing record of safe work practices in place to ensure worker safety within the facility. Examples of these include the following: 7 Security control and badge reader systems that regulate the entrance, presence and exit of all personnel and contractors at KPG, 7 Work Permit Procedure, all work to be performed in a process area is to be performed under the direction of a work permit, 7 Lockout/Tagout Procedure to ensure isolation of energy sources on equipment undergoing maintenance, 7 Line Breaking Procedure for the safe removal of hazardous materials before process piping or equipment is opened, and 7 Confined Space Procedure that ensures 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. Management of Change KPG 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. Incident Investigation KPG promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss (as defined by EPA RMP), 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 forw ards these results to refinery management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked and maintained in KITS. 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 PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, KPG periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three-years or on an as needed basis to track compliance with PSM requirements. At minimum, an audit team composed of personnel knowledgeable in PSM requirements, auditing technique s and process unit technology conducts the comprehensive audit that is executed once every 3-years. The audit team develops findings in the form of action items that are documented in an audit report and the action items from the audit are placed in the KITS system. Corrective actions taken in response to the audit team's findings are tracked in KITS. The final resolution of each finding is documented in KITS, and the two most recent audit reports are retained in the Record Department PSM Files. CHEMICAL SPECIFIC PREVENTION STEPS Many processes at KPG have potential 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 KPG. 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, KPG has safety f eatures on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safety features are used in various processes: Release Detection 1. Hydrocarbon detectors with alarms Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases 2. Valves to permit isolation of the process (manual or automated) 3. Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 4. Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank) 5. Curbs or dikes to contain liquid releases 6. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 7. Atmospheric relief devices 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 EMERGENCY RESPONSE PROGRAM INFORMATION KPG maintains a written emergency response program (KPG-Emergency Response Program; September 1998), which is in place to protect workers, the public and 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 all aspects of emergency response, including 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, KPG has procedures that address maintenan ce, 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. When necessary, the emergency response program changes are administered through the Safety Department, which includes informing and/or training affected personnel in the changes. The overall emergency response program for KPG is coordinated with KPG Emergency Response Team, RTFC, Local Emergency Response Agencies and the Local Emergency Planning Committee (LEPC). KPG has around-the-clock communications capability with these organizations. At least once a year, KPG's Emergency Response Team and these organizations are involved in an onsite test drill that is evaluated for effectiveness if an emergenc y should ever occur. This drill provides a means to ensure the emergency public notification system is in working order, as well as facilitating practice and orderly response to potential emergency events. PLANNED CHANGES TO IMPROVE SAFETY Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at KPG. Some of the key components of the safety improvements we expect to achieve are as follows: 7 The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures. 7 The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards. 7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program. 7 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection. 7 An ongoing dialogue with the KPG, RTFC and the local LEPC will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In this way, we shall bolster our strong commitment to the safety of our workers and the community. PROCESS UNIT PROGRAM LEVEL CERTIFICATION The KPG West Refinery Programs 1 and 3 certification statement and signatory as required by 40 CFR 68.12(b)(4) and 40 CFR 68.185(b) has been provided in the KPG West Refinery hard copy RMP submittal, submitted June 21, 1999. |