CENEX HARVEST STATES LAUREL REFINERY - Executive Summary
CENEX HARVEST STATES REFINERY |
RISK MANAGEMENT PLAN EXECUTIVE SUMMARY
The purpose of this plan is to describe practices in place to mitigate hazards associated with the operation of the CENEX HARVEST STATES refinery located in Laurel, Montana. Information in this plan is made available to the local community, outside emergency response groups, and other interested parties.
TABLE OF CONTENTS
2. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE PRACTICIES
3. DESCRIPTION OF THE STATIONARY SOURCES AND REGULATED SUBSTANCES
4. HAZARD ASSESSMENT RESULTS
7 Toxic Substances
7 Flammable Substances
5. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
7 Employee Participation
7 Process Safety Information
7 Process Hazard Analysis
7 Operating Procedures
7 Pre-startup Safety Reviews (PSSRs)
7 Mechanical Integrity
7 Safe Work Practices
7 Management of Change
7 Incident Investigation
6. CHEMICAL SPECIFIC PREVENTION STEPS
7. FIVE YEAR ACCIDENT HISTORY
RGENCY RESPONSE PROGRAM
9. PLANNED CHANGES TO IMPROVE SAFETY
1. SUMMARY (40 CFR 68)
This document outlines the Risk Management Plan in place at the CENEX HARVEST STATES Laurel, Montana Refinery. This Risk Management Plan is intended to comply with the requirements of EPAs Risk Management Program (40 CFR part 68).
2. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE PRACTICES 40 CFR 68.155(a)
The CENEX HARVEST STATES Laurel, Montana 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 facility. Our practice 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. DESCRIPTION OF THE STATIONARY SOURCES AND REGULATED SUBS
TANCES 40 CFR 68.155(b)
The CENEX HARVEST STATES refinery, located at 802 Highway 212 South, Laurel, Montana, operates a variety of processes to produce petroleum products from raw crude oil. The refinery processes approximately 45,000 barrels of feed stocks per day through the operation of typical refining processes. The CENEX HARVEST STATES refinery receives and transports petroleum products via rail, trucks, and pipelines and has a storage capacity of petroleum and refined products exceeding three million barrels through a network consisting of nearly 80 above ground tanks.
The refinery has a number of streams regulated as flammable mixtures above the threshold quantity. In addition, the refinery uses hydrogen fluoride, which is also a regulated substance, in a quantity above the threshold quantity.
4. HAZARD ASSESSMENT RESULTS 40 CFR 68.155(c)
The worst case scenario (WCS) for a toxic substance release from this facility is a ten minute release of HF
from the HF Alkylation unit. This scenario has the potential for the maximum off site impact, based on EPAs Offsite Consequence Analysis Guidance. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures were considered in evaluating this scenario.
The potential for this quantity of HF to be present in one drum only occurs at a frequency of about 4 weeks every three years. Under actual storage conditions, the HF which is stored as a liquid would not instantly vaporize. Ambient conditions would determine the rate at which a vapor cloud would be generated. However, under EPA RMP modeling requirements, all of the release is assumed to discharged into the air and no pool is formed. Therefore, the distance reported for this release may be overstated.
The alternative release scenario (ARS) for HF at this facility is a ten minute release of 1,000 pounds from a failed HF circulation pump seal. This scena
rio results in the potential for off site impacts, based on EPAs Offsite Consequence Analysis Guidance. The ten minute release duration is based on the time it would take to identify the release and isolate it from the remaining inventory. No other passive or active mitigation measures were taken into account in evaluating this scenario. Mitigation measures that would help to prevent, identify and minimize the effects of this release include: dual pump seals, HF detection devices, motor operated valves, and remote operated water mitigation.
The worst case scenario (WCS) for a flammable substance release from this facility involves the release and subsequent vapor cloud explosion (VCE) of the full inventory of a butane storage tank. The capacity of the tank is 5,180,000 pounds of butane. This scenario results in the potential for off site impacts, based on EPAs Offsite Consequence Analysis Guidance. Although we have numerous controls to prevent such relea
ses and to manage their consequences, no credit for passive mitigation measures were considered in evaluating this scenario.
EPA recommends that the VCE be modeled using a "TNT equivalent model". A TNT equivalent model assumes that the release is in an area where the equipment is highly congested (within a few feet of each other). For this WCS, the release is in an open tank farm area which is not congested. This would substantially reduce the over pressure of the blast which the TNT equivalent model does not account for. Therefore, the distance reported for this release may be overstated.
The alternative release scenario (ARS) for flammable substances at this facility is a VCE of a process vessel (88,000 pounds). This scenario results in the potential for off site impacts, based on EPAs Offsite Consequence Analysis Guidance. Although a VCE scenario is unlikely, it was the only flammable ARS which resulted in the potential for off site impacts. The water deluge system surrou
nding the process vessel would help to prevent a VCE.
5. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS 40 CFR 68.155(d)
The following is a summary of the general accident prevention program in place at the refinery. Because the processes at the refinery are regulated by the EPA RMP regulation and 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.
It is part of Cenex Harvest States culture to ensure systems, procedures and people work together to prevent chemical releases from occurring. In addition to many support functions, e.g., engineering, inspection and maintenance, Cenex uses a "layers of protection" approach for preventing chemical and flammable releases so that an unlikely failure in one layer will not defeat the safeguards provided by another layer. These layers are diverse and independent of each other and include the following:
(1) Equipment i
s designed and constructed using sound engineering practices.
(2) Control systems monitor equipment operation to keep it within normal limits.
(3) Alarms indicate when operations are outside normal limits and trained operator technicians make the proper response to correct the deviation.
(4) Instrument and mechanical protection devices prevent excessive equipment temperature or pressure automatically.
(5) Emergency response plans, equipment and trained personnel are in place to respond to an accidental release.
(6) Cenexs and the communitys emergency response plans are integrated to protect the workers, community and the environment through avenues such as the community warning siren system.
Employee Participation (CENEX HARVEST STATES policy: PSM_I_2)
CENEX HARVEST STATES 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 in
formation 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 policy 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.
Process Safety Information (CENEX HARVEST STATES policy: PSM_II_1 - 8)
CENEX HARVEST STATES 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 and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the refinery are assigned responsibility for maintaining up-t
o-date process safety information.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). 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 safety-related limits for specific process parameters (e.g., temperature, level, composition). The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).
The refinery also maintains numerous mechanical 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 to ensure that safety features in the process are not compromised.
Process Hazard Analysis (CENEX HARVEST STATES policy: PSM_III_1)
CENEX HARVEST STATES 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.
CENEX HARVEST STATES primarily uses the hazard and operability (HAZOP) analysis as well as the "what if" analysis techniques to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. Both analyses are 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 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 forwarded to management for resolution. Implementation of mitigation options in response 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 approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, CENEX HARVEST STATES 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 until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained.
Operating Procedures (CENEX HARVEST STATES policy: PSM_V_1)
CENEX HARVEST STATES 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. The procedures are maintained current and accurate by revising them a
s necessary to reflect changes made through the management of change process.
In addition, CENEX HARVEST STATES maintains as part of the operating procedures, documentation that 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 readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.
Training (CENEX HARVEST STATES policy: PSM_V_1)
To complement the written procedures for process operations, CENEX HARVEST STATES has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having ade
quate 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 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 (CENEX HARVEST STATES policy: PSM_VI_1)
CENEX HARVEST STATES uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the refinery has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) under
stand and follow site safety rules, and (6) 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 their beginning work. In addition, CENEX HARVEST STATES 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.
Pre-startup Safety Reviews (PSSRs) (CENEX HARVEST STATES policy: PSM_VII_1)
CENEX HARVEST STATES 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 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 (CENEX HARVEST STATES policy: PSM_VIII_1)
CENEX HARVEST STATES 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: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities for
m a system that maintains the mechanical integrity of the process equipment.
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 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. CENEX HARVEST STATES 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 (CENEX HARVEST STATES policy: PSM_IX_1-6)
CENEX HARVEST STATES has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personn
el, form a system to help ensure that operations and maintenance activities are performed safely.
Management of Change (CENEX HARVEST STATES policy: PSM_VIII_1)
CENEX HARVEST STATES 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 (CENEX HARVEST STATES policy: PSM_X_1)
CENEX HARVEST STATES prompt
ly 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 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 revalidations.
To help ensure that the accid
ent prevention program is functioning properly, CENEX HARVEST STATES 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 3 years. The audit team develops findings 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 SPECIFIC PREVENTION STEPS 40 CFR 68.155(d)
The processes at CENEX HARVEST STATES 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 CENEX HARVEST STATES. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equip
ment failures and/or human errors.
In addition to the accident prevention program activities, CENEX HARVEST STATES has safety features on many units 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 or will be used in various processes:
1. Hydrocarbon detectors with alarms
2. HF / H2S detectors with alarms
3. Instrumentation (pressure, level, etc.) with alarms
4. Video camera surveillance
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases
2. Scrubber to neutralize chemical releases
3. Valves to permit isolation of the process (manual and automated)
4. Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
5. Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank)
bing and diking to contain liquid releases
7. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump).
8. Atmospheric relief devices
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
7. FIVE YEAR ACCIDENT HISTORY 40 CFR 68.155(e)
CENEX HARVEST STATES has an excellent record of accident prevention over the past 5 years. The frequency of accidental releases has decreased. None of the incidents that have occurred have resulted in off site effects. CENEX HARVEST STATES investigates every incident very carefully to determine ways to prevent similar incidents from occurring. CENEX HARVEST STATES has experienced one reportable accident in 1
994, two accidents in 1995, zero accidents in 1996, zero accidents in 1997, two accidents in 1998 and no accidents in 1999.
8. EMERGENCY RESPONSE PROGRAM INFORMATION 40 CFR 68.155(f)
CENEX HARVEST STATES maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program is modeled after the Integrated Contingency Plan and 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, CENEX HARVEST STATES has procedures that address maintenance,
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.
The overall emergency response program for the CENEX HARVEST STATES is coordinated with the Yellowstone County Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. CENEX HARVEST STATES has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire departments, other industrial response teams). This provides a means of notifying the public of an incident, if necessary, as well as fac
ilitating quick response to an incident. In addition to periodic LEPC meetings, CENEX HARVEST STATES conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.
9. PLANNED CHANGES TO IMPROVE SAFETY 40 CFR 68.155(g)
CENEX HARVEST STATES resolves findings from PHAs, some of which result in modifications to the process. The following types of changes have taken place in the last few years or are currently planned to improve the safe operation of the facility:
7 Replace all chlorine gas injection systems with a less hazardous chemical.
7 Limit the maximum inventory of ammonia stored onsite.
7 Install additional HF mitigation devices - including fixed spray nozzles and remote operated water cannons.
7 Increase the fire water supply capacity.
7 Install additional video camera equipment for early release dete
7 Installation of double and tandem seals on rotating equipment.
7 Implementation of a personal monitor program.