Montana Refining Company - Executive Summary |
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Montana Refining Company Risk Management Plan Executive Summary 1. Accidental Release Prevention and Emergency Response Policies Montana Refining Company recognizes that, because of the complexity of our operation and the hazardous substances we handle, there are potential hazards to the public and our employees. It is for this reason we are committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent releases of hazardous substances so that the health and safety of the surrounding community and our employees is maintained. Montana Refining has employees at the refinery that are trained in emergency response to effectively respond to incidents involving hazardous substances. Montana Re fining invites local health care providers, including hospitals and ambulance services, to attend awareness seminars on some of the hazardous chemicals present at the facility, and has provided the local hospital with information on hazardous chemicals to aid in the treatment of exposures to these chemicals. Two company employees are members of the Cascade County Local Emergency Planning Committee (LEPC), which was provided periodic updates on the Montana Refining Company Risk Management Program development. Montana Refining is supporting the LEPC in upgrading the current community emergency alerting system so that the public can be notified of an emergency situation, including an accidental release, in a more timely and effective manner. 2. The Stationary Source and the Regulated Substances Handled Montana Refining Company operates a 7,000-barrel per day refinery in Great Falls, Montana that contains various processes used to refine crude oil into various grades of motor gasoline , diesel fuels, jet fuels, and asphalt products. We have 12 substances regulated under the Risk Management Program rule present in covered processes at the facility, as follows: isobutane, butane, propane, hydrofluoric acid, isopentane, propylene, pentane, 2-Butene-trans, 1-Butene, 2-Butene-cis, 2,2-Dimethylpropane and ethane. These substances may occur in the pure form as well as in mixtures. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario Montana Refining Company is required to determine a worst case release scenario for both regulated toxic substances as a class and regulated flammable substances as a class that results in the greatest distance to a specified endpoint. The worst-case release scenarios and respective release quantities are specified by the Environmental Protection Agency (EPA) in the Risk Management Program rule, and represent incidents that are considered unlikely. Montana Refining must also determine an alternative release scenario for both classes of substances mentioned above. The alternative scenarios and respective release quantities were chosen by Montana Refining to reflect more likely release scenarios for use in community emergency planning. In all scenarios, the endpoints represent the distance from a release that the public or environment could be subject to serious impacts. EPA Offsite Consequence Analysis Guidance Reference Tables or Equations were used to perform the required offsite consequence analyses for both types of scenarios. The worst case scenario for toxic substances involves the release of the entire contents of a hydrofluoric acid storage vessel as a vapor cloud over a ten-minute period, with subsequent dispersal offsite. Although systems are in place to prevent, mitigate, and control such a release, no mitigation is assumed in this scenario. Under very stable (Class F) at mospheric conditions and a 3.4 miles per hour (1.5 meters per second) wind speed, the maximum distance to the toxic endpoint for hydrofluoric acid of 0.016 milligrams per liter (mg/l) is 7.5 miles. The alternative release scenario for hydrofluoric acid involves a release of hydrofluoric acid vapor from an acid recirculation pump due to a pump seal failure. The release is assumed to occur over a 10-minute period, as this is the estimated time it would take operators to shut down the release. No additional mitigation is assumed. Under neutral (Class D) atmospheric conditions and a 6.7 miles per hour (3.0 meters per second) wind speed, the maximum distance to the toxic endpoint for hydrofluoric acid of 0.016 mg/L is 0.19 mile. The worst case release scenario for flammable substances involves an instantaneous release of the entire contents of a full isobutane storage vessel as a vapor cloud, which finds an ignition source and detonates in a vapor cloud explosion. Although systems are in place to prevent, mitigate, and control such a release, no mitigation is assumed in this scenario. The calculated distance to the specified endpoint of one pound per square inch (1 psi) overpressure is 0.57 mile. The alternative release scenario for flammable substances involves a release of isobutane from a storage vessel due to overfilling. The isobutane is assumed to be released as a vapor cloud, which finds an ignition source and detonates in a vapor cloud explosion. The release is assumed to occur over a 10-minute period, as this is the estimated time it would take operators to shut down the release. No additional mitigation is assumed. The calculated distance to an endpoint of one pound per square inch (1 psi) overpressure is 0.15 mile. 4. The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps Montana Refining Company has taken all the necessary steps to comply with the accidental release prevention program requirements set out under t he Risk Management Program rule. The following sections briefly describe the elements of the release prevention program that is in place at the facility. These elements are identical to those set out in the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard, with which Montana Refining has been in compliance since 1992. Process Safety Information Montana Refining Company maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process safety information is readily available to all employees overseeing or maintaining processes, and is updated based upon the results of hazard analyses, as well as employee participation. Process Hazard Analysis Montana Refining Company periodically conducts a comprehensive Process Hazard Analysis (PHA) on each process covered under the RMP rule to ensure that hazards associated with the processes are ident ified and controlled appropriately and effectively. The methodology used to conduct each PHA is the Hazard and Operability (HAZOP) analysis, supplemented by Checklists. Both methodologies are approved and effective means of identifying hazards within processes. The analyses of each covered process are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at five-year intervals. All findings and recommendations related to the hazard analysis are evaluated and resolved in a timely manner. Operating Procedures For the purposes of safely operating all refinery processes, Montana Refining Company maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is reviewed regularly and is readily accessible to operators involv ed in the processes. Training Montana Refining Company has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Employees are tested to document their understanding of the training given. Refresher training is provided at least every three years, or more frequently as appropriate. Mechanical Integrity Montana Refining Company carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined includes pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are performed by qualified personnel with training in maintenance practices. Furthermore, these personnel are given specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Chan ge Written procedures are in place at Montana Refining Company to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of, and given applicable training on, the modification before implementation and/or start up. Process safety information is updated accordingly. Pre-startup Reviews Pre-start up safety reviews related to new processes and to significant modifications in existing processes are conducted as a regular practice at Montana Refining Company. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are adequate for the safe startup and operation of the new or modified process. Compliance Audits Montana Refining Company conducts audits on a regular basis to evaluate compliance with the provisions set out under the RMP rule to verify that procedures and practices developed or implemented under the rule are adequate and are being followed. These audits are conducted at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Montana Refining Company promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the root cause(s) of the incident as well as any corrective actions to prevent recurrence. All reports are retained for a minimum of five years. Employee Participation Montana Refining Company believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, employees participate in all process hazard analyses and have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, contractors are hired to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is conducted. Montana Refining Company has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of evacuation procedures in the event of an accidental release of a regulated substance. In addition to the accidental release prevention activities, Montana Refining Company has procedures and equipment in place to effectively detect, prevent, mitigate and control releases of hazardous substances. These include: * Closed-circuit television monitors on certain processes, such as the alkylation unit and storage to alert operators to releases or othe r problems * Process controls, which may include relief valves, check valves, interlock systems, manual and automatic shutdown systems, and process alarms * A flare system to collect and destroy hydrocarbon vapors from processes * A high capacity water deluge system at the alkylation unit to knock down an acid cloud to minimize its offsite dispersal * The ability to de-inventory certain storage vessels * Fire monitors and hose stations throughout the refinery * Trained emergency response personnel 5. Five-year Accident History Over the last five years, there have been no reportable releases of regulated substances. Montana Refining Company firmly believes this is a direct result of its commitment to the effective development, implementation and maintenance of the accidental release prevention program in place at the facility. 6. Emergency Response Plan Montana Refining Company maintains a written emergency response plan for response to accidental releases of regulated substances or other hazardous materials. Trained facility responders will implement the plan with the intent of mitigating the offsite, as well as onsite, consequences of a release. The plan also provides procedures for notifying local emergency response agencies and the public. The emergency response plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. To ensure proper functioning, our emergency response equipment is tested and/or inspected regularly. Malfunctioning equipment is repaired or replaced promptly. In order to provide an effective and coordinated response, the plan is coordinated with the City of Great Falls Fire Department, who may be called upon to provide assistance in emergency response. 7. Planned Changes to Improve Safety Improving process safety is an important goal of Montana Refining Company. Currently, numerous recommendations from previous process hazard analyses are being evalu ated and/or implemented. The majority of these improvements and changes slated for implementation are in the area of process controls. It is important to note that the implementation of the accidental release prevention program is an on-going process, and Montana Refining Company expects the continual identification of areas where process safety can be improved. Appropriate additions and changes to procedures, processes and equipment based on current and future studies will be made in a prompt manner. 5 |