Koch Petroleum Group, L.P. - Pine Bend Refinery - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES |
Koch Petroleum Group L.P. ("Koch") is owner and operator of a petroleum refinery in Rosemount, Minnesota (the "Refinery"). At Koch, safety is more than a priority. It is a value. While priorities may change from time to time, a value defines who you are and what you believe in. Kochs refinery has made a commitment to worker and public safety. Our vision is to be recognized as a leader for safe operations ensuring the health and safety of employees, contractors, customers, and neighbors. Our first priority is prevention. This priority is demonstrated by the resources invested in accident prevention. These include designing and constructing our equipment to meet stringent, nationally recognized standards of performance. We operate and maintain our equipment to ensure reliability, which also serves as a measure of how safe an operation is. We train our employees to recognize the importance of safety and to
incorporate safety as a value, both at work and at home.
In the event that a release does occur, our trained personnel will respond to, control, and contain the release. We have some of the best trained, best equipped emergency responders in the country. Our emergency responders train regularly, not only at the facility but at internationally known training centers. We train, not just internally, but with our mutual aid partners - local emergency responders, on a regular basis as well. Our goal is to have the best trained, best equipped emergency response capability that is never used, except to drill.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Koch refinery operates a variety of processes to produce some of the cleanest petroleum fuel products in the nation, including all grades of gasoline, diesel fuel, liquefied petroleum gas, and jet fuel, from crude oil. The refinery also produces a number of other byproducts including food grade carbon dioxide, sul
fur, asphalt and petroleum coke. The refinery has several regulated flammables, such as propane and butane.
The refinery has reduced its inventory of regulated toxic chemicals, specifically reducing our inventory of chlorine and ammonia, to make the refinery a safer place to work and a better neighbor in our community. As a result, no toxic chemicals are reportable for the RMP.
HAZARD ASSESSMENT RESULTS
The worst-case scenario (WCS) associated with a release of flammable substances in Program 3 processes at the refinery is a vapor cloud explosion (VCE) involving the full inventory of a sphere containing normal butane (n-butane). If the full tank inventory of 5.1 million pounds is assumed to release, completely vaporize, and ignite, resulting in a VCE, the maximum distance to the 1-psi endpoint for this WCS is 1.4 miles. A smaller n-butane sphere at the refinery is located closer to the fence-line than the sphere identified above . The WCS maximum distance to the 1-psi endpoint
is 1.2 miles, which stretches approximately 700 feet further in one direction than the WCS distance for the butane sphere described above. For this reason, two worst-case release scenarios have been submitted for Program 3 flammable processes at the refinery. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for mitigation measures is taken into account in evaluating the two worst-case scenarios. The maximum distances to endpoint are calculated using EPA's Offsite Consequence Analysis Guidance.
The alternative release scenario (ARS) for flammable substances at the refinery is a VCE resulting from the release of propane from a tank as a result of an overfill (24,000 lb released over a 10-minute period). The release is expected to be isolated by the operators within 10 minutes. The maximum distance to the 1-psi endpoint for this event could be as far as 0.14 miles. The maximum distance to endpoint is calculated using EPA's Offs
ite Consequence Analysis Guidance and its assumptions for VCE alternative release scenarios (flash fraction factor for propane of 0.38 and TNT yield factor of 3%). This event was selected as being a practical scenario for use in emergency planning and response.
Several processes at the refinery are determined to be Program 1. The WCS for these Program 1 processes is a VCE involving the full inventory of the largest vessel containing a mixture of regulated flammable substances. If the full tank inventory in each covered process is assumed to release, completely vaporize, and ignite, resulting in a VCE, the maximum distance to the 1-psi endpoint for each Program 1 worst-case release scenario does not reach a public receptor. No mitigation measures were taken into account in evaluating the worst-case scenarios. Please note that no Program 2 processes exist at the refinery.
FIVE-YEAR ACCIDENT HISTORY
Koch has an excellent record of accident prevention. Over the past 5 years, no a
ccidental releases have resulted in off-site impacts or on-site injuries or deaths. Only one release, that occurred in 1997, resulted in significant damage to equipment. This release involved a flash fire at a heater. Appropriate actions have been taken to prevent an incident similar to this accident. We investigate every incident very carefully to determine ways to prevent similar incidents from occurring.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the accident prevention program in place at Koch. Because Program 3 processes at the refinery that are regulated by the EPA RMP regulation are also subject to 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.
Koch encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation rang
e 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 can be involved in the accident prevention program 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 Total Safety Culture to promote both process and personal safety.
Process Safety Information
Koch has available technical documents that are needed to maintain safe operation of the refinery. 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-to-date process safety information. A table summarizing the reference documents and their location 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 supplemented by documents that specifically address known hazards associated with handling and exposure to the chemicals. The refinery has documented safety-related limits for specific process parameters (e.g., temperature, level, composition, flow, pressure) in a Key Process Parameter Document. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument system
s (e.g., automated shutdown systems).
The refinery also maintains numerous other technical 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
Koch 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 on a regular basis to identify hazards and ensure that adequate controls are in place to manage these hazards.
Koch primarily uses the hazard and operability (HAZOP) technique to p
erform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The 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.
If ways are found to make processes safer, all appropriate individuals, including corporate management, are involved in implementing the improvements. Koch tackles those changes which can have the greatest impact on safety first. All recommendations for improvement are tracked, to be sure that they are implemented in a timely manner. The final resolution of each finding is documented and retained.
Koch periodically updates and revalidates the hazard analysis results. These periodic revi
ews are conducted at least every 5 years until the process is no longer operating. Both the HAZOP, and the What-If, Checklist technique are utilized during the Hazard Analysis Revalidation process. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for implementation and the final resolution of the findings is documented and retained.
Koch maintains written procedures that address all modes of process operations, including (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 consistent training of new operators. These procedures are periodically reviewed and certified as current and accurate.
In addition, Koch maintains a Key Process Parameter Document that provides guidance on how to respond to upp
er 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 jobs.
To complement the written procedures for process operations, Koch 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 through tests, skills demonstration and other methods that they have adequate knowledge to perform the duties and tasks in a safe manner on their own, they are allowed to work independently. In addition, all operators receive refresher training on the operating procedures to ensure that their skills and knowledge are maintain
ed at the highest level. All training is documented for each operator, including the means used to verify that the operator understood the training.
Koch uses contractors to supplement its workforce as part of routine practices and 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 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 a
ddition, Koch 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)
Koch 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.
Koch 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. This program includes: (1) training, (2) written procedures, (3) regular inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that reliably 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, 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. Koch 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
Koch has safe work practices in place to help ensure worker and process safety. Examples of these include (1) Security control and badge reader systems that regulate the entrance presence and exit of support personnel, (2) a work permit procedu
re, all work performed in the process area is to be performed under the direction of a work permit, lockout/tagout procedure is an integral part of the work permit 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 personnel, form a system to help ensure that operations and maintenance activities are performed safely.
Management of Change
Koch has a comprehensive computerized system to manage changes to processes. This system requires that changes to process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes are properly reviewed and aut
horized 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.
Koch promptly investigates all incidents that result in, or could result in, a fire/explosion, toxic gas release, major property damage, environmental impact, 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 accident prevention program is functioning properly, Koch 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 typically is an independent, autonomous group, and contains at least one or more individuals knowledgeable in the process being audited. The audit team develops findings that are forwarded to refinery management fo
r 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.
CHEMICAL SPECIFIC PREVENTION STEPS
The processes at Koch have potential 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 the refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) 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 (mitigate) a release. The following types of safety features are used where appropriate throughout the refinery:
ydrocarbon or Hydrogen Sulfide detectors with alarms
1. Process relief valves that discharge to a flare system equipped with a flare gas recovery unit to capture episodic releases
2. Valves to permit isolation of the process (manual or automated)
3. Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
4. Curbing or diking to contain liquid releases
5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)
6. 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
5. Blast-resistant buildings to help protect control systems and personnel
EMERGENCY RESPONSE PROGRAM INFORMATION
Koch maintains a written emergency r
esponse program to protect worker and public safety as well as the environment. The program 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, Koch 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 emergency response program for the refinery is coordinated with the Dakota County Public Safety Department. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. Koch has around-the-clock communications capability with emergency response organizations (e.g., fire department), who provide the means of notifying the public of an incident, if necessary, as well as facilitating quick response. The refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery. Koch conducts regular emergency drills that involve the Dakota County Public Safety Department and emergency response organizations throughout the county and the southeast metropolitan area.
PLANNED CHANGES TO IMPROVE SAFETY
Diligent compliance with our Risk Management Program forms th
e framework in which we will continue to improve the level of safety at Kochs Pine Bend Refinery. Some of the key components of the safety improvements we expect to achieve are as follows:
- The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures.
- The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards.
- The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program.
- Compliance audits will ensure we maintain and increase our level of safety protection.
- An ongoing dialogue with the Dakota County Emergency Management Coordinator, or his/her designate, and local
emergency response providers will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In this way, we shall bolster our strong commitment to the safety of our workers and the community.
We encourage all interested citizens or community organizations to contact the Dakota County Emergency Management Coordinator for the latest information on emergency response for the county. We plan to continue to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis.