Frontier Refining Inc. - Executive Summary |
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Executive Summary Frontier Refining Inc. Risk Management Program Introduction Frontier Refining Inc's (Frontier) Cheyenne Refinery conducts crude oil refining for the production of gasoline, diesel fuel, asphalt and other petroleum products. The Cheyenne Refinery processes approximately 40,000 barrels of crude oil per day. The crude oil is supplied from oil producers in Wyoming and adjacent states. Frontier Refining Inc. is proud of its Cheyenne Refinery and the two hundred and sixty well trained employees who operate and maintain the facility. The refinery has been part of the Cheyenne community for over sixty-five years and is a major contributor to Wyoming's and Cheyenne's economy. Frontier's safety performance has been recognized by the National Petroleum Refining Association with three Gold Awards and two Meritorious Performance Awards in the last five years. Frontier is committed to the safety of its employees and the community. Frontier's Accidental Release Prevention and Emergency Response Policies Frontier's concern with the safety of the facility is evidenced by the extensive commitment to policy and procedure development and the commitment of personnel and resources to safety related training. Frontier's commitment to prevention and response is further evidenced by Frontier's participation with local emergency planning committees. Frontier provides each employee an average of 30 hours per year of training on safe work practices and emergency procedures. Frontier requires that all employees attend a formal safety meeting once per month. Frontier has developed and implemented over 600 written, detailed operating procedures available 24 hours per day to the facility personnel. These procedures address release prevention and release emergency response activities. These procedures have become policy at the Frontier facility Frontier's release prevention program is based on three primary components. Those components are comprised of the util ization of equipment and processes designed for safety; providing extensive personnel training and defined operational procedures that cause the facility to be operated safely; and having extensive programs and procedures in-place that minimize the potential for accidental releases by properly maintaining the facility. The implementation of all three of these components has reduced the incident of accidental releases of RMP regulated substances such that no offsite release of any RMP regulated substance has ever occurred at the Frontier facility. Frontier has developed and implemented emergency response policies that are considered among the best in the industry. Frontier is a member of and the facility's Fire Chief is the Vice Chair Person of the Laramie County Emergency Planning Committee. Frontier's Fire Brigade participates in joint training sessions with the Cheyenne Fire Department twice per month and all Fire Brigade members have been trained in petroleum fire fighting at the University of Nevada-Reno Fire Science Academy. Frontier maintains a $200,000 live fire fighting facility onsite. Frontier is a founding member of the Laramie County Industrial Mutual Aid Organization. Page 2 RMP Executive Summary 40 CFR, Part 68 Regulated Substances Handled at the Facility Three RMP applicable chemical are present at the Frontier facility in amounts above the 40 CFR, Part 68 specified threshold quantities. The substances are butane, propane, chlorine and anhydrous hydrogen fluoride(HF). These chemicals are used in processes common to the petroleum refining industry. Frontier has onsite a maximum inventory, at any one time, of 26,000 pounds of chlorine, 146,000 pounds of HF, 380,000 pounds of propane and over 1,000,000 pounds of butane. Toxics and Flammables Worst Case Release Scenarios for the Facility Toxics Worst Case Release Scenario: The worst case toxic release scenario is the failure of a mixer/settler tank in the HF Alk ylation Unit at the refinery. The mixer/settler tank contains a maximum of 109,000 pounds of HF in a 60% light end petroleum solution. The scenario selected assumes an instantaneous release of the entire volume contained in the mixer/settler tank. The release would occur over a ten minute period. Active mitigation of the release would occur by the facilities HF Water Deluge System within four minutes of the release occurring. The deluge system places a water flow of up to 6,000 gallons per minute onto the release site. Such a release scenario hypothetically would cause an offsite impact. Frontier utilized the EPA's RMP*Comp worst case release model to evaluate this scenario. The RMP*Comp model indicated that the toxic endpoint for HF would be reached 14 miles from the facility. This calculation is very conservative. It assumes the HF plume is neutrally buoyant, released during in a low wind speed and a stable atmospheric condition. Flammables Worst Case Release Scenario: The worst case flammables release scenario is the rupture, vaporization and ignition of the total volume of butane, 1,040,000 pounds, in the facilities Horton Sphere. RMP*Comp for this scenario yielded a distance to the overpressure endpoint of 0.8 miles from the sphere. This would result in an offsite impact. The rupture of the Horton Sphere containing liquidized gas under pressure, in reality, would result in only a faction of the sphere contents being volatilized through flash vaporization. The fraction would rapidly cool to the boiling point of the liquid either remain in the sphere or spill to the ground. This remaining liquid may catch on fire, but would likely not be involved in the generation of the overpressure wave. Toxics and Flammables Alternative Case Release Scenarios for the Facility Toxics Alternative Case Release Scenario: Chlorine Frontier uses chlorine to treat cooling process water. One ton cylinders of chlorine are stored at five process locations and one tank storage area onsite. Each process location has 2 cylinders and the storage area has 3 cylinders. The chlorine alternative scenario used RMP*Comp to model the endpoint determination of a 1,044 pounds of chlorine being discharged through a 5/16th diameter tank nipple. The release is assumed to have occurred over a 60 minute time period. An endpoint of 0.1 miles was determined for this scenario. This release would move offsite, but not cause impact to any offsite receptors. Page 3 RMP Executive Summary Toxics and Flammables Alternative Case Release Scenarios for the Facility(cont.) Toxics Alternative Case Release Scenario: HF The HF alternative case scenario involves a break in a nipple on the 12-inch pipe at the bottom of the mixer/settler tank. In this scenario, the Water Deluge System (up to 6000 gallons per minute of water) would be activated within 4 minutes of the release. The scenario assumes a release of 15,976 pounds of HF f or 60 minutes. The initial release rate is 8,100 pounds per minute of HF, decreasing due to tank pressure drops, to an average of 69 pounds per minute for the 60 minutes of the release. RMP*Comp predicts a toxic endpoint is reached 0.4 miles from the release site. This would result in offsite impacts. Flammables Alternative Case Release Scenario: Butane The alternative flammable release modeled the impact of a rupture and vapor cloud explosion of the full contents of a tank containing 64,000 pounds of butane liquified under pressure. RMP*Comp application to this scenario predicted an estimated distance to a 1 pound per square inch overpressure endpoint of 0.14 miles. This scenario would result in offsite impacts. Frontier's Accidental Release & Chemical Specific Prevention Program & Steps Under RMP, petroleum refineries are classified as Program 3 facilities. Program 3 facilities are subject to the Section 7 requirements of the RMP submittal program. The data necessary for Section 7 are a taken, on a one to one match, from the OSHA Process Safety Management (PSM) requirements. Frontier is compliant with the PSM requirements of the State of Wyoming's OSHA regulations. Frontier insures that accidental releases from the facility, as well as releases of specific chemicals, are adequately addressed through the implementation of the PSM program at the facility. Frontier's PSM program directs the inspection of tens of thousands of discrete points in the refinery to insure that the materials used to handle the chemicals at the refinery have maintained their integrity and are acceptable for continued use. If inspection reveals a weak point in the material or process, Frontier corrects the problem consistent with PSM and implements, if necessary a change in the process operations and procedures to address the weakness. In the event that equipment fails, Frontier has installed process and chemical specific detection and monitoring equipment. These d etectors alert facility personnel if a release has occurred. Frontier operational personnel participate in comprehensive and frequent process training to insure that releases are responded to expeditiously and in a manner that minimizes the potential for injuries or exposure to facility or adjacent population. Frontier has installed a video camera system that allows operational personnel to monitor the HF Alkylation unit, a RMP subject process, 24 hour a day, 7 day a week. This system enhances Frontier's ability to detect and respond to operational emergencies. Page 4 RMP Executive Summary Frontier's Five Year Accident History Frontier's strong commitment to safety is evidenced by the very low incident of chemical related injuries at the refinery. Frontier has had only accidental release of the RMP applicable chemicals from the facility in the last 5 years. The release of 6 pounds of HF took place in April, 1998. One on-site person was injure d by this spill. This release was contained onsite and did not cause any offsite impacts. Frontier's Emergency Response Program All of the refinery's employees are trained as first responders to environmental emergencies. Frontier maintains a thirty two person fire brigade onsite, comprised of facility personnel, that act as first responders to refinery emergency situations involving hazardous materials, including those subject to RMP. Twenty one of Frontier's employees are trained to respond to medical injuries to the Basic Emergency Care (BEC) level. Frontier and its staff are active members and participants in the Laramie County Emergency Planning Committee. Frontier's staff act as instructors at the University of Nevada-Reno's Fire Science Academy. Frontier invests over 1300 hours per year to maintain the process training of its operating staff. Frontier conducts emergency response drills on a regular basis and participates twice monthly with the Cheyenne Fire Departm ent in joint emergency training exercises. Frontier has an extensive alarm and notification program for emergency situations at the refinery. Operational personnel, refinery visitors and contractors are required to pass a safety training program prior to proceeding onto the operational area of the refinery. This training includes how to recognize emergency alarms and what to do in the event an alarm is sounded. Frontier participates in an emergency notification and response program developed and implemented by the LEPC, the Wyoming Department of Environmental Quality and the Laramie County Emergency Manager. Additionally, Frontier participates in the areas Shelter In Place program for nearby residents and other population. The Shelter In Place program is a county wide effort that provides information and procedures for potential offsite receptors what they should do regarding emergency situations in the vicinity of their residence or place of work. This Shelter In Place pr ogram is communicated directly to the local residents and other potentially impacted populace by a variety of people and organizations, including senior refinery management. Frontier's Planned Changes to Improve Safety at the Facility Frontier has an active and aggressive program that constantly strives to improve the safety of the refinery. Frontier is currently evaluating safety, monitoring and detection equipment enhancements; changes in operational programs to enhance process safety management concerns; evaluating different chemicals as potential replacements for those currently used in the refinery operations and subject to RMP; installing new incident mitigation equipment related to RMP subject process units; updating and enhancing the refineries training program; and evaluating new equipment and processes for process unit operations on RMP subject processes. |