Alon USA Big Spring Refinery - Executive Summary

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Executive Summary of Risk Management Plan 
Alon USA LP Inc. Big Spring Refinery 
The Alon USA Big Spring Refinery (BSR) is a 61,000B/D crude oil refinery located in Big Spring TX.  The primary business is the production and sale of motor gasoline, diesel, jet fuel, and asphalt plus limited amounts of LPG's, benzene and propylene.  We handle or store the following Risk Management Plan (RMP) regulated substances in quantities above the defined threshold level.  
? Flammables purchased or produced to be used internally within the process or to be blended and sold as a product include: 
 ? Hydrogen 
 ? Methane 
 ? Ethane  
 ? Ethylene  
 ? Propane 
 ? Propylene 
 ? Butane 
 ? 1-Butene 
 ? 2-Butene 
 ? 1-Butene-Cis 
 ? 1-Butene-Trans  
 ? Isobutane 
 ? Pentane 
 ? 1-Pentene 
 ? 2-Pentene (E) 
 ? 2-Pentene (Z) 
 ? 2-Methyl-1-Butene 
 ? Isopentane  
? Toxics  
 ? Hydrogen Flouride/Hydroflouric Acid (commonly called HF Acid) is used as a catalyst in the production of gasoline blend stock.  
an effort to reduce the risk of accidental releases from this facility it is the policy of the Alon USA Big Spring Refinery to comply with the requirements of both 29 CFR 1910.119, Process Safety Management of Highly Hazardous Materials (PSM), and 40 CFR Part 68, Risk Management Program (RMP), regulatory requirements. We have verified compliance with these important regulations. 
Under the requirements of 40 CFR Part 68 the worst case and alternate case release scenario results are summarized below.  These results include administrative controls and mitigation measures to limit the distances for each reported alternate case scenario as noted below. 
 ? The worst case scenario (WCS) flammable release and resulting vapor cloud explosion impact, as defined in the RMP requirements,  is based upon releases from two sources as follows: 
   1. 2,200,000 lbs of pentane stored in a pressurized sphere resulting in a 1 psi impact area of 1.0 miles in radius, and  
   2. 1,500,000 lbs of isobuta 
ne stored in a pressurized sphere resulting in a 1 psi impact area of 0.92 miles in radius. 
The two sources are required due to potential off-site exposure to different receptors.  
The WCS scenarios by rule are not limited by passive mitigation and both vessels are assumed to be full when the release occurs. 
 ? The Alternate Release Scenario (ARS) case for a flammable substance is the release of 10,750 pounds of a propane/butane mixture from a pump seal failure.  The estimated impact area to 1 psi overpressure is a circle 629 feet (0.12 miles) in radius which does extend off-site but, does not impact any offsite receptors.  This conservative scenario assumes a steady 1,075 lb/minute leak for 10 minutes before isolation with available remotely operated valves and assumes the existing deluge system is not activated.  The explosion is evaluated using the same equation as for a WCS flammable except a more realistic efficiency factor of 0.03 is used.    
 ? The toxic material WCS releas 
e assumes the release of 90,000 lbs of HF Acid over a 10 minute period.  The defined endpoint beyond which it should no longer pose a hazard to the public is <25 miles based upon the EPA look up tables.  This maximum inventory is assumed to be stored in the acid storage drum due to a unit shut down situation.  During a full shut down the entire HF contents of the unit are de-inventoried to the drum.  This drum normally has less than 30,000 lbs of material even immediately after just loading a delivery of acid.  This scenario does not take into account mitigation effects from water spray that is available to limit the impact of the release. 
 ? The ARS for a toxic material assumes a seal failure on the acid circulation pump resulting in a 108 lb/minute release of HF Acid for 30 minutes before isolation and before application of water sprays to limit the impact distance.  The estimated impact distance is 4,300 feet (0.81 miles) before the material disperses enough to no longer pose a ha 
zard to the public.  Depending upon wind direction the release could include exposure to offsite receptors including private homes, businesses or a recreational area.  This very conservative estimate assumes we do not utilize the available remote operated valves to limit the release time nor apply available water sprays to knock the vapors down for a full 30 minutes.  The weather conditions assumed normal stability and humidity but only one half the normal wind speed which is one more conservative assumption in this analysis. 
A review of incident records for the last five years indicate there has been one release covered under the RMP regulation.  In 1996 a small yet unknown quantity of HF Acid was carried over into the flare system during a series of process upsets and was released in solution with water as a "misting rain".  This resulted in exposure and medical treatment to a truck driver loading propylene immediately downwind of the flare.   There was no off-site exposure due to t 
his incident. 
The best thing to do is prevent a release from occurring.  The BSR accidental release prevention program includes all of the elements of both PSM and RMP regulations.  Key to these prevention efforts is the knowledge of the chemicals and equipment used in the process units, the careful evaluation of and reduction of operating risks, and the proper operation, monitoring, upkeep and maintenance of equipment and systems.  These ongoing efforts severely reduce the likelihood of either WCS event occurring at the BSR. The mitigation systems currently in place and the prompt response by experienced and qualified personnel would further limit the worst case or alternate scenarios to much less than the estimated impacted areas if they did occur.  The following is more detailed information regarding our risk management and incident prevention program currently in place. 
Chemical and release specific prevention program information is as follows: 
 ? WCS - HF Acid release - This d 
rum and associated piping are routinely inspected to insure adequacy for continued service.  This includes on-stream thickness monitoring for corrosion rate and remaining life calculations.  This vessel is rated at 175 psig and is protected by a dedicated relief valve set at 150 psig.  This will vent any excess pressure that could lead to the worst case release scenario.  The liquid level is routinely monitored by computer, while the pressure is checked locally by qualified operators to insure both are kept within defined safe operating limits.   The drum has protection from fire monitors that will condense much of the HF Acid vapor and prevent it from going offsite.  During normal operating conditions this vessel is less than 1/3 full and would contain less than 30,000 lbs of HF acid. 
 ? ARS  - Toxic HF release  - Our qualified personnel use various maintenance efforts to insure the integrity of rotating equipment including monthly vibrations monitoring, laser alignment, and balanc 
ing.  This equipment is also covered by fire monitors to knock down a vapor release.  The pumps are protected by Remotely Operated Valves to isolate and reduce the volume of any released material.   
 ? WCS Flammable -  
    Tk075 is inspected externally on-line and internally during scheduled outages with the information kept and analyzed as part of our Plant Condition Monitoring System (PCMS).  The tank is protected by two independent relief valves to prevent overpressure and possible rupture.  The tank has remote operated valves to reduce the amount of material that might leak during a piping or pump failure.  The tank is protected by fire monitors to provide fire control and for cooling from any nearby fire. 
    Tk073 is inspected externally on-line and internally during scheduled outages with the information kept and analyzed as part of our Plant Condition Monitoring System (PCMS).  The tank is protected by a relief valve sized for anticipated worst case release rate to prevent  
overpressure and possible rupture.  The tank has remote operated valves to reduce the amount of material that might leak during a piping or pump failure. The tank is protected by fire monitors to provide fire control and for cooling from any nearby fire. 
 ? ARS Flammable - This pump is monitored monthly to detect increases in vibration which would give early indication of conditions that could lead to a seal failure.  The pump has remote operated valves so isolation can occur and thereby reduce the volume of material released.  The pump also has a deluge system whereby a water spray can be applied remotely to help knock down or disperse any leaking material.  The unit operators check this pump every two hours as part of the routine unit rounds.  
The Alon USA BSR Risk Management Program prevention program includes the following elements: 
EMPLOYEE PARTICIPATION - All Alon USA Big Spring employees are involved in risk management efforts.  This involvement includes assistance in ident 
ifying and correcting hazards, assistance in conceptual design of improvements and new installations, reviewing and revising operating procedures, pre-startup safety reviews, training, operation and maintenance of equipment, development of maintenance procedures, and the safe operation of the plant. Selected employees, including represented ones, are members of special teams for Incident Investigations, PHA evaluations and the Health & Safety Committee, while others are directly involved in the writing and reviews of the operating and maintenance procedures. 
PROCESS SAFETY INFORMATION (PSI) - PSI is the written process safety information on the hazards of the chemicals used in a covered process as well as information of the process technology and specified equipment.  This information is available before conducting the hazard analysis and is available for review by hard copy or electronically to all employees. PSI includes the following types of information  
 ? Chemical Information  
- Material Safety Data Sheets (MSDS) contain most of the required hazard information for each PSM covered highly hazardous chemical used or generated at the Big Spring Refinery.  Expanded information regarding inadvertent mixing, corrosion and potential effects of exposures is included in specific reports or references. 
 ? Flow Diagrams - Block flow diagrams are used primarily in training and process overview documents.  Process flow diagrams (PFD's) are available in the design/drafting area of the technical files and are often part of operating procedures and training manuals.  
 ? Process Chemistry - A general description of the process chemistry is included in the process overviews and operating procedures and in the PHA documentation.  A more detailed process chemistry description including chemical reactions and side reactions is available in the technical files. 
 ? Maximum Inventory - A maximum intended inventory (MII) of hazardous materials is identified for each covered proce 
 ? Safe Upper and Lower Limits  - Safe operating limits for temperatures, flows, pressures, etc. are identified and available. 
 ? Consequences of Deviations - The consequences of deviations, including those affecting the safety and health of employees, have been compiled and analyzed. Significant items are included with appropriate warning and caution statements as part of our Operating and Maintenance Procedures. 
 ? Materials of Construction - These are documented in equipment files located in the technical files and include manufacturer information including specifications, data sheets, drawings, etc.  
 ? P&ID's - Piping and Instrumentation Diagrams are maintained and provide equipment, piping and instrumentation information consistent with industry standards and good engineering practice.  
 ? Electrical Classifications - Electrical area classification are based on American Petroleum Institute, Recommended Practice 500 (API RP500) and the National Electric Code (NEC).  They 
are shown on the plot plans and provide guidelines to specify types of equipment authorized to be used in specific areas.  
 ? Relief systems - The relief valve and relief system design basis has been evaluated and is maintained in the Technical Files area.  
 ? Ventilation systems - Where appropriate and needed for the process, ventilation system designs are maintained in the technical files. 
 ? Design Codes and Standards - The technical files contain supporting documentation that equipment complies with recognized and generally accepted good engineering practices.  In cases where equipment was designed and constructed in accordance with codes, standards or practices that are no longer in general use, documentation is provided to show the equipment is designed, maintained, inspected, tested, and operating in a safe manner.   
 ? New Construction Standards - New equipment is purchased, fabricated and installed per the Fina Engineering Standards (FES) including references to those ind 
ustry standards listed in FES 10.02 unless approved by the project engineer.  
 ? Energy (Heat) and Material Balances - This information is provided by the Process Engineering group utilizing good engineering practices and is included on the Process Flow Diagrams for units built after May 26, 1992. 
 ? Safety Systems - This information is documented in Technical Files, on unit P&ID's, the Distributed Control System (DCS), and the DOC3000 software system.  Area Volatile Organic Compounds (VOC) detection systems, firewater system, deluge system, and foam systems are documented in the technical files.  
PROCESS HAZARD ANALYSIS (PHA) - Assigned teams, as specified by the PSM standard, have performed a hazard analysis to identify, evaluate and control hazards involved in each covered process. The analysis was appropriate to the complexity of the process and scheduled based upon various prioritized factors including age of the process, extent of hazards, number of potentially affected employ 
ees, and operating history.  The method of choice used at the Big Spring refinery for initial PHA's was the Hazard and Operability Studies (HAZOP).  This was supplemented with Check Lists and What If? analysis as needed. Other techniques are approved and are used as needed and determined by the PHA team.  The Scope of a process hazard analysis includes: 
 Hazards of the process 
 Identification of appropriate previous incidents 
 Engineering and administrative controls 
 Consequences of failure of these engineering and administrative controls 
 Facility siting 
 Human factors 
 Qualitative evaluation of possible safety and health effects of failure of controls 
Team Requirements - The team leader must have training and experience in the process hazard analysis methodology used.  The team will include at least one employee with experience and knowledge specific to the process being evaluated.  For any significant project, at least one represented employee from the operating area shall b 
e included on the team. 
Documentation of PHA Findings - The PHA team findings and final accepted PSM covered recommendations will be documented and resolved in a timely manner based upon a priority that is based primarily upon current risk and overall risk reduction afforded by the recommendation.  A formal tracking system (FRATS) has been established to monitor progress in completing the recommendations and documenting resolutions to the recommendations.   
Communication of Findings - PHA findings and action steps are available to employees and contractors who have potential exposure to the hazards over the electronic system. 
Process Hazard Analyses Timing - Each unit PHA is updated and revalidated within five years of the initial or last major PHA study. 
Retention of PHA's - All PHA and corrective action documentation are retained in the technical files for the life of the process involved.  
OPERATING PROCEDURES  - Written operating procedures provide clear instructions for safe 
ly conducting activities, including operations maintenance, involved in each covered process, consistent with the process safety information.  The procedures address the following required elements or phases of operation:  
 Initial Startup, 
 Normal Operations, 
 Temporary Operations, 
 Emergency Shutdown, (Including the conditions under which emergency shutdown is required and the assignment of incident related shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner), 
 Emergency Operations, 
 Normal Shutdown, 
 Startup following a turnaround or after an emergency shutdown. 
Operations Maintenance issues as required under Mechanical Integrity (MI). 
Operating Limits including: 
 Consequences of deviation, and  
 Steps required to correct or avoid deviation. 
Safety and health considerations including: 
 Properties of and hazards presented by the chemicals in the process, 
 Precautions necessary to prevent exposure includi 
   Engineering controls, 
   Administrative controls, 
   Personal protective equipment,and 
Control measures to be taken if physical contact or airborne exposure occurs, 
Quality control for raw materials, 
Control of hazardous chemical inventory levels, 
Special or unique hazards. 
Safety systems and their functions. 
Periodic Review - Operating procedures are reviewed as often as necessary to assure that they reflect current operating practices including changes documented through the MOC system and re-certified at least annually to insure that they are current and accurate.   
Safe Work Practices - Safe work practices/procedures are used to control hazards during operation and maintenance activities.  These procedures, documented in the Big Spring Safety Policies and Procedures Book (the "Red Book"), apply to all employees and contractors.  These practices will include, as a minimum, Lock Out/Tag Out (LOTO), Hot Work, confined space entry, first break for opening process equipment  
or piping, and control over entrance of all personnel including contractors into the facility and the covered process areas.  
TRAINING - Initial training, including a process overview, unit operating and relevant maintenance procedures, is required for all newly assigned employees or current workers involved in operating the process.  This training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, operations maintenance work, and safe work practices applicable to the employee's job tasks.  Refresher training is required at least every three years, plus a clear understanding and documentation that the training was received and understood. 
Alon USA Responsibilities - Alon USA requests and obtains information regarding the contractor's safety performance and programs.  The information is used as part of the contractor evaluation process.  The information is required prior to a new contractor being placed on the appr 
oved contractor listing issued by the Purchasing Department.  Fina informs all contractors of the known potential site hazards of fire, explosion or toxic releases related to the contract work and explains to contract employers the applicable provisions of the Emergency Response Plan. Sufficient controls are in place by Alon USA to control the entrance and exit of contractors from the facility plus their presence in the covered process units.  Alon USA periodically audits the performance of the contractors in fulfilling their obligations. Alon USA maintains a contractor injury and illness log related to the contractor's work in the units. 
Contractor Responsibility - each contractor is directly responsible for the health and safety of their employees as well as the requirements listed below: 
 All employees are properly trained in the work practices necessary to safely perform his/her job. 
 All employees are instructed in the contents of the Alon USA Site Orientation Manual which incl 
udes information concerning known potential fire, explosion or toxic release hazards related to his/her job in the process as well as information concerning the Emergency Response Plan. 
 Training documentation is maintained that verifies the employee has received and understands the required information. 
 Insure that all employees follow the safety rules including the safe work practices of the Big Spring Refinery.  This includes the requirement to promptly report and investigate incidents, including damage to equipment, or injuries per Safety Policy & Procedure #17. 
 Inform Alon USA of any unique hazards presented by the contract employer's work and to report to Alon USA any hazards found as part of the work.  
PRE-STARTUP SAFETY REVIEW (PSSR) - A pre-startup safety review is conducted for new facilities as well as existing facilities that have been modified to the extent that the process safety information has been changed.  That review is designed to insure the following importan 
t considerations have been addressed before any hazardous chemical is introduced into the process:  
 ? Equipment was fabricated, constructed and installed according to design specifications. 
 ? Safety, operating, maintenance, and emergency procedures are in place and are adequate. 
 ? That a Process Hazard Analysis has been performed for new or significantly modified facilities and recommendations are resolved or implemented before start up. 
 ? Modified facilities meet the requirements of our Management of Change Procedures and Practices. 
 ? Training of each employee or contractor involved in operating the affected part of the process has been completed. 
MECHANICAL INTEGRITY - Mechanical Integrity efforts assure the initial and on-going integrity of process equipment by determining and documenting the equipment is designed, installed and maintained properly for the intended service.  Key issues covered under MI include the requirements to: 
? Develop, document and maintain the ne 
cessary procedures and records to accomplish MI responsibilities. 
? Insure proper and unique numbering for equipment, drawings, lines and files per established plant procedures. 
? Provide and evaluate the equipment specifications for new and/or repaired/rebuilt equipment. 
? Provide and document the construction oversight, inspection, and testing during construction and installation of capital or major unit revamp work. 
? Specify and assure the specified materials, spare parts, and equipment are suitable for the process application intended. 
? Provision of the knowledge, equipment, materials, and manpower necessary to maintain covered process equipment to the approved PSI in a timely manner.  
? Design, implement and document the predictive, preventive and repair maintenance programs necessary to assure the continued integrity of process equipment, including maintaining records of periodic testing and routine maintenance. 
? Train each employee involved in maintaining the integrity of the 
covered equipment.  
? Provide input into budgeting and planning of both routine and turnaround work to insure the long term mechanical integrity of the process systems. 
? Provide the appropriate technical expertise to evaluate existing equipment problems and recommend solutions to maintain to original PSI. 
? Provide and document the necessary work for MOC items including updating of PSI including files, drawings and other technical information. 
? Establish, publish, provide, and distribute all documentation, to include all records, files, and drawings (PSI, MI, PHA, PSSR, MOC, etc.).  
HOT WORK PERMITS - Alon USA controls all hot work operations conducted in or near a covered process. This is accomplished through a permitting system for hot work review and approval. 
MANAGEMENT OF CHANGE (MOC) - Alon USA developed, implemented, and utilizes written procedures to manage changes to facilities, process chemicals, technologies, or equipment, other than "replacement in kind".  This insur 
es provision of relevant information to keep Mechanical Integrity information and related files current.  MOC assures the following considerations are addressed prior to any covered change: 
The technical basis for the proposed change, 
The impact of the change on safety and health, 
Modifications to operating procedures, 
Necessary time period for the change, and 
Authorization requirements for the proposed change. 
Affected employees and contractors involved in the operation or maintenance of a process are informed of and trained in the change prior to start-up of the process or affected part of the process.  If the change results in a change in the PSI or MI Files, such PSI and MI information is updated accordingly.  If the change results in a change to the operating procedures or practices, such procedures or practices are updated accordingly.  
INCIDENT INVESTIGATION - Alon USA investigates, as a minimum, every incident that results in, or reasonably could have resulted in, a catastro 
phic release of highly hazardous chemicals in the workplace. The incident investigation team is lead by an employee trained in incident investigation techniques. Team members include at least one member familiar with the covered process, a represented worker appropriate for the investigation, a contract employee if the incident involved the work of a contractor and others with appropriate technical knowledge and experience as needed to thoroughly investigate and analyze the incident.  The investigation team issues a report, per the approved procedures, to the Big Spring Refinery Health, Safety, & Environmental (HSE) Committee.  The HSE Committee reviews and approves the final version of all Incident Investigation Reports including all accepted recommendations.  
EMERGENCY PLANNING AND RESPONSE - The Alon USA Big Spring Refinery Emergency Response (ER) Plan describes the organization, responsibilities, and plans for responding to emergencies.  The ER Plan is available at the workplace  
for employee review.  The plan is reviewed and updated at least annually prior to the required drill regarding salt well storage facilities.  Affected personnel assigned new responsibilities or designated actions receive training upon assignment of those new duties.  General refresher training is completed after the yearly update and prior to the annual drill.  Newly assigned personnel review the portions of the ER Plan they must know to protect themselves in the event of an emergency.  This plan is communicated to and coordinated with local groups including the Local Emergency Planning Committee (LEPC) and responders such as the Big Spring Fire Department, the Howard County Sheriff's Department, the Big Spring Police Department, the Texas Department of Public Safety and the Howard County Volunteer Fire Department.  These groups are used to supplement the efforts of the Alon USA Emergency Response and HAZMAT teams that take direct control to handle the emergency on-site.  Communication 
on-site includes a warning siren system and individual portable radios.  Communication to the public is coordinated through the LEPC and 911 systems which, in turn, include notifications through the local radio and cable TV stations.  Routine, joint training exercises are conducted to insure a coordinated, timely and appropriate response will occur in the unlikely event of a release actually occurring.  The Big Spring Refinery has developed a written plan that complies with the approach in the National Response Team's Integrated Contingency Plan Guidance ("One Plan"). 
COMPLIANCE AUDITS - Alon USA certifies an evaluation (audit) of compliance with all of the PSM/RMP  provisions at least every three years.  The audit verifies relevant procedures and practices are adequate and are being followed.  The audit is conducted by at least one person knowledgeable in the process and includes at least one hourly person.  The audit team issues a report of the findings to local management.  Alon  
USA management promptly determines and documents an appropriate response to the findings and documents that deficiencies have been corrected.  The two most recent audits' results and recommendations are documented and kept on file.   
As part of our efforts to continually improve and reduce the risk of our processes we periodically evaluate the hazards of our operations.  Some of the safety improvement items we currently plan to implement came from these hazard reviews.  Two of these items for the Alkylation unit include: 
? Installation of additional water spray capabilities to provide an increased capability to reduce the impact of either a release or a fire in this area of the plant. 
? Installation of additional detection systems to enhance our ability to provide early warning of a release.
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