Conoco Refinery, Ponca City, Okla - Executive Summary |
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Risk Management Plan Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Conoco Ponca City Refinery has a long-standing commitment to protecting the environment and the health and safety of our employees and the public. 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 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 OF OUR FACILITY AND REGULATED SUBSTANCES HANDLED The Conoco Ponca City Refinery, located in Ponca City, Kay County, Oklahoma, operates a variety of processes to produce petroleum products (e.g., propane, butane, gasoline, and diesel) from raw crude oil. The refinery has several regulated flammables, such as propane, butane, etc. In add ition, the refinery uses and/or processes ammonia, hydrogen fluoride and hydrogen sulfide which are also regulated substances. Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors. HAZARD ASSESSMENT RESULTS The Conoco, Ponca City Refinery summarized a Risk Management Plan based on direction from the EPA Risk Management Program regulation 40 CFR part 68, under the Clean Air Act, Section 112r(7). From the Offsite Consequence Analysis Guidance document (dated April 15, 1996) provided by the EPA and using the relevant endpoint from the look-up tables together with details of the release rate and duration, a calculation of the hazard distance was made for the Worst Case scenarios for flammables & toxics. The EPA uses the term "endpoint" to define the concentration level at which there would be no adverse impact to the public or environment from a release or catastrophic event from a stationary site. "Covered" pro cesses (processes containing flammables or toxics in excess of the threshold quantities of a covered substance in greater than 1% concentration) were categorized into Program level 1 or 3 (see below for description) with no program level 2 processes being identified. This approach resulted in 24 processes listed as "covered" of which 1 was identified as Program Level 1 and 23 Program Level 3 processes. Program Level 3: As defined in 40 CFR part 68.10, a Program Level 3 "covered" process contains flammable or toxic substances in excess of the Threshold Quantities listed in tables (in section 68.130), is covered by the OSHA PSM standards, and the worst case release scenario (flammable or toxic) in that process potentially has an offsite consequence to the public or environment. The worst-case scenario (WCS) associated with toxic substances in Program 3 processes at the refinery is a catastrophic failure in the Alkylation Process, resulting in a release of 92,000 LB of hydrogen fluor ide (HF) gas over a 10-minute period from the acid settler. Although we have numerous controls to prevent such releases and to manage resulting consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating this scenario. The maximum distance to the toxic endpoint of 20-PPM (0.016 milligrams per liter) for this WCS is 12 miles. The alternative case scenario (ARS) for HF is a seal leak from the rerun column feed pump. This leak results in 1500-lb of HF released over a 15-minute period. The 15-minute release duration is the time necessary for operations personnel to isolate and shut down the feed pump. No other mitigation measures were taken into account in evaluating this scenario. The maximum distance to the toxic endpoint of 20 PPM (0.016 milligrams per liter) for this ARS is 0.67 miles using Det Norske Veritas PHAST 5.2 Professional program software. There are three WCS associated with a release of flammable substances in Program 3 processes at the refinery. These WCS are vapor cloud explosions (VCE) involving the full inventory of three separate vessels. Each of these affects different public receptors. All other process scenarios are within the bounds of these three or are completely onsite. Following are the three WCS: Scenario No 1: T-41E, Light straight run storage in the West Plant Tank Farm was based on 5,000,000 pounds of butane. The calculated distance to the 1-PSI endpoint is 1.38 miles radius affecting the Circle Drive Park, the residential area east and north of refinery, & onsite industrial renters, Scenario No 2: T-957, Isobutane Sphere in the South Plant Tank Farm contains 1,100,000 pounds of a flammable mixture. The calculated distance to the 1- PSI endpoint is 0.82 miles affecting Jupiter Chemicals, Circle Drive Park, & the residential area east of refinery, Scenario No 3: T-917 Butane Sphere in the South Plant Tank Farm contains 1,100,000 pounds of Butane. The calculat ed distance to the 1- PSI endpoint is 0.82 miles affecting Jupiter Chemicals, Circle Drive Park, & the residential area east of refinery. None of the administrative controls in place to limit the storage inventory in T-41E, T-957 or T-917 were credited in these calculations. The inventories were assumed to release, completely vaporize, and ignite, resulting in a VCE. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures were taken into account in evaluating these WCS. Flammable alternate release scenarios were calculated with the multi-energy method as described in American Institute of Chemical Engineers' Guidelines for Evaluating the Characteristics of Vapor Cloud Explosions, Flash Fires, and BLEVES. Offsite impact from the alternate release scenario selected extends into the southerly portion of the Circle Drive Park. The source of this scenario for flammables was in the #5 Fluidized Catalytic Cra cking unit. This alternate release scenario uses the same type of analyses made for analyzing onsite buildings. Program Level 1: The process is eligible for Program Level 1 if the process contains flammable or toxic substances in excess of the Threshold Quantities listed in tables (in section 68.130), if there are no public receptors within the distance to an endpoint for the worst-case scenario analyzed for the process, and there has not been any catastrophic effects to the public or environment due to releases within the last 5 years. One Process was identified at this refinery as Program Level 1 containing a regulated flammable substance above the threshold quantity; however, there were no Program Level 1 processes containing regulated toxic substances at or above the threshold quantity. The WCS identified this Program Level 1 was for a flammable substance release in the Isomerization Unit. The distance to the 1 PSI specified endpoint for the worst-case accidental release scenario of 47,400 pounds of a flammable mixture is 0.29 miles which is less than the distance to the nearest public receptor of .0327 miles. Within the past five years, this process has not had any accidental release that caused offsite impacts as defined in the risk management program rule (40 CFR 68.10(b)(1)) and no additional measures were necessary to prevent an offsite impact from accidental releases. In the event of fire, explosion, or a release of a regulated substance from this process, entry within the distance to the specified endpoint may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in this RMP. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the accident prevention program in place at the Conoco Ponca City Refinery. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject t o 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. Employee Participation The Ponca City Refinery employees 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 are involved 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 areas of the plant, including operations, maintenance, engineering, and plant management. Process Safety Information The Ponca City Refinery keeps a variety of technical documents that are important to the safe operation and maintenance 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 primary delivery tool for information is the electronic document management system. Personnel have access to many stations from which to retrieve this information. This information is readily available as part of the written employee participation plan to help employees locate any necessary 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 supplement ed 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) in the Process Technology Package Safe Operating Limits (Section 1.4). 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 technical documents that provide information about the design and construction of process equipment. This information includes materials used in 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 a ctivities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis The Ponca City 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. Primarily the "what-if" checklist analysis technique is used to perform evaluations coupled with elements of the Hazard and Operability (HAZOP) methodology. This analysis provides a systematic and thorough hazard evaluation technique that brings different points of view to identify potential hazards. The analyses are conducted using a team of people incorporating operating and maintenance experience as well as engineering expertise. The 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 local and corporate 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 implemented in response to PHA team findings are tracked until they are complete then documented. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Ponca City Refinery 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 a nd findings from these updates are documented with priorities assigned to any action item associated with the review. Operating Procedures The Ponca City Refinery 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 as necessary to reflect changes made through the management of change process. The Refinery documents Safe Operating Limits 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 procedur es, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, the Ponca City Refinery provides 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. After operators demonstrate (e.g., through tests & skills demonstration) adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators receive refresher training at least every 3 years on operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. Refresher training emphasizes process overview informat ion, operating issues, safe work practices, and operating procedures that are rarely used such as emergency shutdown, emergency operation and startup following an emergency shutdown. A Training Needs Analysis (TNA) document lists the needed training to be performed for a specific job within the operating unit and also verifies the training has taken place by the trainee and trainer signing and dating the document. Contractors The Ponca City Refinery 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) understand and follow site safety rules, and (6) inform refinery personnel of any hazards that they find during their work. This is accomplished by contractor employees attending safety orientation sessions covering: (1) a process overview, (2) information about safety and health hazards, (3) the emergency response plan requirements and (4) review & discussion of safe work practices prior to their beginning work. In addition, the Ponca City refinery evaluates contractor safety programs (safety organization, employee education & training & accident prevention programs) and their prior performance (using OSHA injury rates, property loss experience, regulatory compliance history & workers comp experience) 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) The Ponca City Refinery 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 en sure 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 support systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. Our checklist contains a list of safety questions covering process considerations that must be addressed prior to startup and provides the names of the reviewer responsible for confirmation of each pre-startup safety question. 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 and training has been completed & documented. Mechanical Integrity The Ponca City Refinery has well-established practices and procedures to maintain pressure vessels, piping systems, relief an d vent systems, controls, pumps and compressors, motors, emergency shutdown, and electrical 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 into equipment purchases and repairs to ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. 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, a Management Of Change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment until appropriate repairs or replacement can be made, or employees will correct th e deficiency before placing the equipment back into service (if possible). In combination, these activities form 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. Safe Work Practices The Ponca City Refinery has numerous 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 op ened, (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. Hot Work permit forms are 1)distributed to employees and periodically reviewed at safety meetings & 2)periodically audited by Area Safety Personnel to ensure the information is accurate and well documented. 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 Ponca City Refinery has a thorough 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)confirm that the technical basis for the change is ap propriate, (2) ensure the safety and health impacts of the change are understood, (3) verify that adequate controls are in place to manage any new hazards (4) insure that existing controls have not been compromised by the change, (5) establish the permissible time period for temporary changes, and (6) document that the change is authorized by the appropriate personnel. Affected chemical hazard information, process operating limits, and equipment information, and procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary notification and training needed due to the change. Incident Investigation The Ponca City Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, property damage, environmental effects, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence o f the incident or a similar incident. The investigation team (trained in investigation techniques including root cause failure analysis) 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 to completion. 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, the Ponca City Refinery 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. Both hourly and mana gement personnel participate as audit team members. 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. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the Conoco Ponca City Refinery contain hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program level 1 and 3 EPA RMP-covered processes at the Refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures or human errors. In addition to the accident prevention program activities, the Refinery has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (or mitigate) a release. The following types of safety features are used in various processes: Release Detection 7 Hydrocarbon detectors with alarms 7 Cameras with 24 hour monitoring 7 HF detectors with alarms Release Containment/Control 7 Process relief valves that discharge to one of 4 different flare systems to capture and incinerate episodic releases 7 Scrubber to neutralize chemical releases 7 Valves to permit isolation of the process (manual or automated) 7 Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 7 Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank) 7 Curbing or diking to contain liquid releases 7 Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump & dual electrical feed) 7 Atmospheric relief devices Release Mitigation 7 Fire suppression and extinguishing systems 7 Deluge system for specific equipment 7 Trained emergency response personnel 7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 7 Blast-resistant buildings to help protect control systems and personnel 7 Instrument Safety Systems & Independent alarms manned on a 24-hour basis FIVE-YEAR ACCIDENT HISTORY The Conoco, Ponca City Refinery has an excellent record of accident prevention over the past 5 years. There are two incidents that met the criteria for inclusion in this Risk Management Plan. These two incidents both occured in our #5 Hydrotreater process in 1996. Neither of these incidents had any offsite impact. We investigate each incident very carefully to determine ways to prevent similar incidents from occurring. EMERGENCY RESPONSE PROGRAM INFORMATION The Conoco Ponca City Refinery has implemented an effective emergency response (ER) program to protect the refinery worker, the public safety and the environment. The program consists of knowledgeable emergency responders, appropriate response equipment, and procedures for responding to a release of a r egulated substance, including the possibility of a fire or explosion. The Emergency Response program utilizes the Incident Command System (ICS) to manage all aspects of response. The three divisions of the Emergency Response Team include the Hazardous Materials (Hazmat) Team, Fire Brigade, and Rescue Team. The ER procedures address all aspects of emergency response, including proper first-aid and medical treatment, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public, and post incident cleanup and decontamination requirements. In addition, the Ponca City Refinery has procedures that address maintenance, inspection, testing and functional certification of emergency response equipment, as well as instructions that address the use of emergency response equipment. Emergency response employees receive training in these procedures to perform their specific duties. The emergency response program is reviewed annua lly and 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 and/or training affected personnel in the changes. The overall emergency response program for the Ponca City Refinery is coordinated with the Kay County, Local Emergency Planning Committee (LEPC) as well as local fire departments and law enforcement agencies. This coordination includes periodic meetings with local emergency response officials, local government officials, and industry representatives. The Refinery has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., 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 periodic LEPC meetings, the Ponca City Refinery conducts periodic emergency dr ills with the LEPC, local emergency response organizations, and local medical providers. PLANNED CHANGES TO IMPROVE SAFETY All findings from PHA's are resolved, some of which result in modifications to the process. The following changes are planned in the Conoco, Ponca City Refinery as a result of recent studies: 7 Improved leak detection for mitigation of HF leaks in the alkylation process 7 Improved isolation of unit inventories by remotely operated isolation valves interlocked to the detection devices. 7 Removing toxic chemicals, such as chlorine and sulfur dioxides from water-treatment systems. 7 Providing written work instructions for calibrating and testing instrument safety systems. 7 Installing emergency shutdown valves in the liquefied petroleum gas storage area, limiting the amount of hazardous material that could be released. 7 Revisions to personnel training programs 7 Revised written operating procedures |