National Cooperative Refinery Association - Executive Summary |
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NATIONAL COOPERATIVE REFINERY ASSOCIATION CONWAY UNDERGROUND STORAGE McPHERSON COUNTY, KANSAS RISK MANAGEMENT NATIONAL COOPERATIVE REFINERY ASSOCIATION RISK MANAGEMENT PLAN EXECUTIVE SUMMARY CONWAY UNDERGROUND STORAGE The purpose of this plan is to describe practices in place to mitigate hazards associated with the operation of the National Cooperative Refinery Association Conway Underground Storage located in McPherson County, Kansas. Information in this plan is available to the Local Emergency Planning Committee, outside emergency response groups, and other interested parties. TABLE OF CONTENTS 1. SUMMARY 2. ACCIDENTAL RELEASE PREVENTION AND EM ERGENCY RESPONSE POLICIES 3. DESCRIPTION OF THE STATIONARY SOURCES AND REGULATED SUBSTANCES 4. HAZARD ASSESSMENT RESULTS * Toxic Substance Scenarios * Flammable Substance Scenarios 5. PREVENTION PROGRAM * Employee Participation * Process Safety Information * Process Hazard Analysis * Operating Procedures * Training * Contractors * Pre-startup Safety Reviews (PSSRs) * Mechanical Integrity * Safe Work Practices * Management of Change * Incident Investigation * Compliance Audits 6. CHEMICAL RISK MANAGEMENT STEPS 7. FIVE YEAR ACCIDENT HISTORY 8. EMERGENCY RESPONSE PROGRAM 9. PLANNED CHANGES TO IMPROVE SAFETY APPROVED: Ken I. Roane DATE: June 18, 1999 Vice President, Refining Division 1.0 SUMMARY This document outlines the Risk Management Pla n in place at the National Cooperative Refinery Association, Conway Underground Storage located at 775 Landmark Lane, McPherson County, Kansas. This Risk Management Plan is intended to comply with the requirements of EPA's Risk Management Program (40 CFR part 68). 2.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The National Cooperative Refinery Association, McPherson, Kansas, Conway Underground Storage has a long standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as the training of personnel and considering safety in the design, installation, operation, and maintenance of our facility. 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. 3.0 DESCRIPTION OF THE STATIONARY SOURCES AND REGULATED SUBSTANCES The Conway Undergr ound Storage facility provides storage for approximately 4,000,000 barrels of petroleum products including propane, natural gas, butane, gasoline, and intermediate refinery feed stocks. The underground salt layer caverns average about 50,000 barrels capacity each. Pipelines are used to transfer products to and from the refinery and to various product terminals. The Conway Underground Storage has four EPA listed flammable substances held above the threshold quantity. These are propane, Alky olefin feed, butane and isobutane. 4.0 HAZARD ASSESSMENT RESULTS TOXIC SUBSTANCE SCENARIOS The Conway Underground Storage does not store or use EPA listed toxic chemicals. FLAMMABLE SUBSTANCE SCENARIOS The worst case scenario (WCS) for a flammable substance release from this facility involves a 10 minute release of 86,200 pounds of butane from the # 15 underground storage cavern and subsequent vapor cloud explosion (VCE). EQE International, Inc., 16850 Diana Lane, Houston Texas and EPA's Of fsite Consequence Analysis Guidance/RMP Comp. were used to calculate release distances. Butane storage was selected because the butane is transferred to Conway for underground storage and then transferred back to the refinery for further processing. Butane is transferred more often than the olefin feed. The alternative release scenario for flammable substances at this facility is a vapor cloud explosion resulting from the overfilling of # 15 butane cavern causing a release of butane to the brine ponds. This scenario assumes the release would last thirty five minutes until valves were closed and then a subsequent vapor cloud explosion occurred. EPA's Offsite Consequence Analysis Guidance/RMP Comp was used to calculate release distances. 5.0 PREVENTION PROGRAM The following is a summary of the accident prevention program in place at Conway Underground Storage. Because the process at the Conway Underground Storage is regulated by the EPA Risk Management Program regulation and the O SHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation (National Cooperative Refinery Association; PSM, Doc. 8502) Conway Underground Storage encourages employees to participate in all facets of process safety management and accident prevention. Conway Underground Storage has one employee representative in the position of Special Project Operator. This employee is responsible for writing and updating operating procedures, verifying P&ID drawings with engineers and interfacing between Conway operators and management. Other examples of employee participation include updating and compiling technical documents and chemical information, participating in the Union/Management Health and Safety Committee and participating as a member of a process hazard analysis (Process Hazard Analysis) team. Employees have access to all information cre ated as part of the accident prevention program. The employee participation policy is maintained at the National Cooperative Refinery Association Environment, Health & Safety Department, 1391 Iron Horse Road, McPherson, Kansas. It addresses each accident prevention program element. Process Safety Information (National Cooperative Refinery Association Refinery; PSM, Doc. 8503) National Cooperative Refinery Association keeps a variety of technical documents that are used to help maintain safe operation of Conway Underground Storage. These documents address inventory maximums and safe limits for pressures and flows of transfer pumps. Up to date information is maintained by the Conway Operators. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). National Cooperative Refinery Association also maintains numerous mechanical documents that provide information about the desig n and construction of Conway Underground Storage 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 facility changes to ensure that safety features in the process are not compromised. This information is available through the National Cooperative Refinery Association engineering department. Process Hazard Analysis (PHA) (National Cooperative Refinery Association; PSM, Doc. 8504) Conway Underground Storage has a comprehensive program to help ensure that hazards associated with the underground storage are identified and controlled. Within this program, areas are systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. National Cooperative Refinery Association p rimarily uses the "What If" analysis technique to perform these evaluations. The "What If" technique asks a series of questions to review potential hazard scenarios and possible consequences. This analysis is 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 underground storage 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 Process Hazard Analysis team findings are forwarded to the Process Hazard Coordinator for resolution. Implementation of mitigation options in response to Process Hazard Analysis 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 res ponse to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained. To help ensure that controls and/or hazards do not eventually deviate significantly from the original design safety features, National Cooperative Refinery Association 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. The results and findings from these updates are documented and retained. Operating Procedures (National Cooperative Refinery Association; PSM, Doc. 8505) Conway Underground Storage maintains written procedures that address operations needed for the storage and transfer of refinery products. 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. Training (National Cooperative Refinery Association; PSM, Doc. 8506) To complement the written procedures for underground storage operations, National Cooperative Refinery Association has implemented a comprehensive training program for all employees operating underground storage equipment. New employees receive basic training in underground storage operations. After successfully completing this training, a new operator is paired with a senior operator to learn 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 on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresh er 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 (National Cooperative Refinery Association; PSM, Doc. 8507) National Cooperative Refinery Association uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near underground storage equipment, procedures are 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 Conway personnel of any hazards that they find during their work. This is accomplished by providing contractors with information about safety and health hazards, emergency response plan requirements, and safe work practices prior to their beginning work. In addition, National Cooperative Refinery Association evaluates contractor safety programs and performance during the selection of a contractor. Conway personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) (National Cooperative Refinery Association; PSM, Doc. 8508) National Cooperative Refinery Association 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 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 (National Cooperative Refinery Association; PSM, Doc. 8509) Conway Underground Storage 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: identification and categorization of process equipment, performing inspections and tests of equipment, correcting identified deficiencies, applying quality assurance measures and documentation of these steps. In combination, these activities form a system that maintains the mechanical integrity of the operating equipment. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within accepta ble limits and meets the applicable regulatory codes and standards. If a deficiency is identified, corrections will be made 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. Training requirements for maintaining and inspecting process equipment including an overview of the process, its hazards and procedures applicable to employee is given to assure work is performed in a safe manner. Another integral part of the mechanical integrity program is quality assurance. National Cooperative Refinery Association incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices (National Cooperative Refinery Association; PSM, Doc 8510 and other Safety Procedures) Nation al Cooperative Refinery Association has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include control of the entry/presence/exit of support personnel, a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, a permit and procedure to control spark-producing activities (i.e., hot work), and a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. 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 (National Cooperative Refinery Association; PSM, Doc 8511) Conway Underground Storage has a comprehensive system to manage changes to equipment. This system requires that changes to items such as pumping equipment, chemicals, technology (including operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and verify that existing controls have not been compromised by the change. Affected chemical hazard information, 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 (National Cooperative Refinery Association; PSM, Doc 8512) National Cooperative Refinery Association 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 r ecommendations to prevent a recurrence, and assigns responsibility 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. These reports are reviewed during each Process Hazard Analysis and Process Hazard Analysis revalidation. Compliance Audits (National Cooperative Refinery Association; PSM, Doc 8514 To help ensure that the accident prevention program is functioning properly, National Cooperative Refinery Association 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 3 years. The audit team develops finding s 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. 6.0 CHEMICAL RISK MANAGEMENT STEPS The Conway Underground Storage has hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied at the Conway Underground Storage facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and/or human errors. In addition to the accident prevention program activities, Conway Underground Storage has safety features 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: Release Detection 1. Instrumentation with alarms 2. Twenty four hour/day monitoring of processes by operators. Release Containment/Control 1. Valves to permit isolation of the storage caverns and pumps Release and Fire Mitigation 1. Emergency Notification and Response Plan 2. Response by local fire department (1/2 mile away) 3. Refinery emergency response teams will respond (7 miles away) (24 hour pager on call) Fire Brigade Rescue Team Hazardous Materials Team Emergency Medical Team 4. Emergency Response Equipment Two fire fighting pumper trucks Hazardous materials response trailer Pick-up truck carrying rescue and medical equipment Other Items to Prevent or Mitigate a Release / Fire 1. Mutual aid agreements with McPherson Fire Department 2. Weekly training for company Emergency Response Teams Classroom training Field training 3. Employees are trained on eme rgency response duties through Classroom training Field training Computer based training 4. Preventative maintenance program for Conway equipment 5. Full time Environment, Health and Safety staff 7.0 FIVE YEAR ACCIDENT HISTORY Conway Underground Storage has an excellent record of accident prevention over the past 5 years. There have been no accidents that resulted in effects as defined in the Risk Management Program. National Cooperative Refinery Association investigates every incident very carefully to determine ways to prevent similar incidents from occurring. Listed below is a summary of the number of accidents that have occurred during the past 5 years. Conway Underground Storage Five Year Accident History Year RMP events-onsite effects RMP events-offsite effects 1994 0 0 1995 0 0 1996 0 0 1997 0 0 1998 0 0 1999 0 0 8.0 EMERGENCY RESPONSE PROGRAM INFORMATION Conway Underground Storage maintains a written emergency response plan to ensure a coordinated and timely response to chemical releases, fires, explosions, natural disasters as well as other emergencies. This type of response is necessary to protect public and worker safety as well as the environment. Items covered in the plan include emergency notification and response of employees, notification of local emergency response agencies and the public, first-aid and emergency medical care, evacuation plans and routes, the accounting of personnel after an evacuation, emergency equipment list, the inspection, testing and maintenance of emergency equipment, and employee emergency plan training requirements. The emergency response program is reviewed annually and updated as needed. The overall emergency response program for Conway Underground Storage is coordinated with the McPherson County Local Emergency Planning Committee (LEPC). This committee is comprised of local emergency response officials, industry representatives and other concerned citizens. National Cooperative Refinery Association has a representative on this committee. National Cooperative Refinery Association has the capability to communicate wit h McPherson County Emergency Management officials and emergency response organizations by telephone and hand held radios. 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 LEPC meetings, National Cooperative Refinery Association conducts periodic emergency drills that involve the LEPC and emergency response organizations. The refinery provides refresher training to local emergency responders regarding the hazards of regulated substances in the refinery. 9.0 PLANNED CHANGES TO IMPROVE SAFETY Conway Underground Storage is constantly looking for ways to improve safety and decrease possible exposure to chemicals. The following types of changes have taken place or are currently planned to improve the safe operation of the facility: * Plans to install monitoring systems on LPG brine systems which will detect the overfilling of storage caverns. * Plans to install hyd rocarbon detection system by transfer pumps and manifolds. |