Cooperative Refining, LLC - Executive Summary |
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COOPERATIVE REFINING, LLC COFFEYVILLE, KANSAS RISK MANAGEMENT PLAN For HYDROGEN FLUORIDE HDROGEN SULFIDE BUTANE & PROPANE TABLE OF CONTENTS 1. Summary 2. Accidental release prevention and response policies 3. Description of the stationary source and regulated substances 4. Hazard assessment results 5. General accident prevention program steps 5.1 Employee Participation 5.2 Process Safety Information 5.3 Process Hazard Analysis 5.4 Standard Operating Procedures 5.5 Training 5.6 Contractors 5.7 Pre-Startup Safety Review 5.8 Mechanical Integrity 5.9 Safe Work Practices 5.10 Management of Change 5.11 Incident Investigations 5.12 Compliance Audit 6. Five-year accident history 7. Emergency response program 8. Conclusion 1. SUMMARY This document outlines the Cooperative Refining, LLC (CRLLC); Coffeyville Refinery Risk Management Program (RMP) prepared in accordance with 40 CFR Part 68. This RMP addresses the worst case and the more realistic scenarios for the toxic endpoint for a release of Hydrogen Fluoride (HF) and Hydrogen Sulfide, and for over pressure situations resulting from vapor cloud explosions of Propane and Butane. This program description has been prepared utilizing the Model Risk Management Plan Guidance for Petroleum Refineries, API Publication 760. 2. ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES CRLLC has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. 3. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The CRLLC refinery, located at North and Linden streets near Coffeyville, K S, operates a variety of processes to produce petroleum products (e.g., gasoline, diesels, propane, and butane) from raw crude oil. Hydrogen sulfide and other sulfur compounds are present in crude oil, that produce sulfur dioxide when combusted. Even though these compounds are present in the refinery and are not stored above thresholds to be included in this plan, hydrogen sulfide has been included as a general duty to inform the public. This plan has also been prepared for hydrogen fluoride, propane and butane that are either used or produced during the refining process. The refining process consists of: 1. Separation: Liquid hydrocarbons are distilled by heat separation into gases, gasoline, diesel fuel, fuel oils and heavier residual material. 2. Conversion: There are three common conversion processes: a. Cracking: This process breaks or cracks large hydrocarbon molecules into smaller ones. This is done by thermal or catalytic cracking. b. Reforming: High temperatures and cat alysts are used to rearrange the chemical structure of a particular oil stream to improve its quality. c. Combining: Chemically combines two or more hydrocarbons such as liquid petroleum gas (LPG) materials to produce high-grade gasoline. 3. Purification: Converts compounds to an easily removable or an acceptable form. 4. Blending: Mixes combinations of hydrocarbon liquids to produce a final product(s). 4. HAZARD ASSESSMENT RESULTS For the purposes of this hazard assessment CRLLC considers the entire facility a single process and has selected RMP compounds on a facility wide basis. Utility operations that support the refinery, which do not contain RMP covered compounds, still require portions of process safety information and operating procedures to be completed. This report focuses on the compounds that pose the greatest off site impact. Toxic and flammable substances were evaluated to assess quantity and locations of each that would produce the respective worst case scenario (WCS). Alternate, more realistic incidents utilizing the same compounds are also presented in this report. The WCS associated with a toxic substance for this facility is a 10 minute release of hydrogen fluoride (HF) from a alkylation unit acid mixer settler vessel, hypothetical failure. No mitigation measures (emergency safety equipment) were taken into account in evaluating this scenario as required by the EPA. The WCS assumes that a catastrophic vessel or pipe fails releasing the entire contents of the vessel. Several factors need to be recognized to put things in perspective. There has never been a HF release from this facility or any other facility of the magnitude of what is being reported in this WCS. Safety systems and process equipment are designed to assure this will not occur. Under actual storage conditions the HF would not instantly vaporize, but instead would be contained by process unit curbing and drained to a collection basin for neutralization. The refinery has nume rous safety systems (HF sensors, water curtains, water deluge, dikes, and neutralization) to prevent off site migration of a HF vapor release. The weather conditions assumed for a WCS release does not exist in most areas and an actual release would disperse more quickly. For the reasons stated above, the distance to toxic endpoint reported for this WCS release is grossly overstated. The alternate case or more realistic release scenario (ARS) for HF at this facility is a ten-minute release. Beneficial effects of our diking, water deluge, and water curtain measures were all taken into account in evaluating this scenario. The WCS and alternate scenario distance to endpoint for this report were estimated using Trinity Consultants BREEZE HAZ DEGADIS+ based on the U. S. Environmental Protection Agency's DEGADIS model that predicts dispersion from releases of dense gases. The WCS associated with hydrogen sulfide at this facility is a ten-minutes release. As before, no mitigation measur es were taken into account. The ARS associated with hydrogen sulfide at this facility is a 90-minute release. Both the WCS and ARS for hydrogen sulfide were generated using the EPA OCA Guidance Reference Tables The WCS associated with a release of butane; a flammable substance stored at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing butane. A full tank inventory is 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, mitigation measures were not taken into account in evaluating this WCS. The ARS for butane is a VCE resulting from the release of butane from a transfer line. The release is expected to be isolated by the operators within 15 minutes (active mitigation). This event was selected as being a practical scenario for use in emergency planning and response due to the continuous movement of butane to and from these tanks. The WCS for propane, a flammable substance is a VCE involving the full inventory of the largest tank containing propane. The assumption for this WCS is based on a full tank inventory released, completely vaporized, and ignited, resulting in a VCE. No mitigation measures were taken into account in evaluating this WCS. The ARS for propane at the refinery is a VCE resulting from the release from a transfer line. The release is expected to be isolated by the operators within 15 minutes (active mitigation). 5. GENERAL ACCIDENT PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the CRLLC refinery. Processes at the refinery are regulated by both EPA RMP regulation and OSHA PSM standard. 5.1 Employee Participation CRLLC employees participate in many 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. Additional ways that employees can be involved in the accident prevention program is documented in an employee participation plan that is maintained as part of the refinery Process Safety Management Plan. 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 are typically comprised of members from various areas of the plant, including operations, maintenance, engineering, and plant management. 5.2 Process Safety Information CRLLC keeps a variety of technical documents and standard operating procedures that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configu ration information. Specific departments within the refinery are assigned responsibility for maintaining up-to-date process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information addresses any known hazards associated with the use and handling of chemicals. The refinery ensures that processes are maintained within operating limits using process controls and monitoring instruments, protective instrument systems (e.g., automated shutdown systems) and highly trained personnel. The refinery also maintains numerous 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 operational procedures and trained personnel, provid es a basis for inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in each process is not compromised. 5.3 Process Hazard Analysis CRLLC 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. The refinery primarily uses the What if/What if Checklist technique to perform Process Hazard Analysis (PHA). 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. The PHA team fi ndings are forwarded to local management for review. 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 attention first. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the CRLLC 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 and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for considerati on and the final resolution of the findings is documented and retained. 5.4 Operating Procedures CRLLC 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. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. These procedures are periodically reviewed and certified as current and accurate. 5.5 Training To complement the written procedures for process operations, CRLLC has implemented 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) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. 5.6 Contractors CRLLC uses contractors to supplement its workforce 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 ma nner, (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 addition, the CRLLC refinery 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. 5.7 Pre-startup Safety Reviews (PSSRs) CRLLC 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 featur es, 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. 5.8 Mechanical Integrity CRLLC has well-established practices and procedures in place to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified defici encies, and (5) applying quality assurance measures. In combination, these activities form a program that maintains the mechanical integrity of the process equipment. Another integral part of the mechanical integrity program is quality assurance. The CRLLC refinery incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper material 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, employees will correct the deficiency before placing the equipment back into service (if possible), or an MOC team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. 5.9 Safe Work Practices CRLLC has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 5.10 Management of Change CRLLC has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process-operating conditions), procedures, and other facility changes be properly reviewed and authorized before implementation. 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. 5.11 Incident Investigation CRLLC promptly investigates all incidents that resulted in, or reasonably could have resulted in a fire/explosion or toxic gas release that could lead to major property damage, severe 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 pr event 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. 5.12 Compliance Audits To help ensure that the accident prevention program is functioning properly, the CRLLC 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, under the supervision and the direction of the CRLLC Legal Department. Both hourly and management personnel parti cipate 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. The final resolution of each finding is documented, and the two most recent audit reports are retained. 6. FIVE-YEAR ACCIDENT HISTORY The CRLLC refinery has an excellent record of accident prevention over the past 5 years with only one RMP reportable release. Hydrofluoric acid was released from the facility's alkylation unit. However, the release was immediately recognized by the refinery's automated release detection system and instantly controlled with a water deluge system that limited the off site release amount to less than 500 pounds. Three workers were taken to the hospital for first aid. One was kept overnight for observation then released. There were no off site injuries and no adverse off site environmental impact. 7. EMERGENCY RESPONSE PROGRAM INFORMATION The CRLLC refinery maintains a written Emergency Preparedness and Response Plan, 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, the CRLLC refinery 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 du ties. The emergency response program is updated when necessary based on modifications made to refinery processes or other refinery facilities. The overall emergency response program for CRLLC interfaces with plans developed by other local emergency response organizations. This coordination includes periodic meetings that include local emergency response officials, local government officials, industry representatives and the local media. The CRLLC refinery has around-the-clock communications capability with emergency response organizations (e.g., fire department, police, and media). 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 participating in Montgomery County Local Emergency Planning Committee (LEPC) meetings, CRLLC conducts periodic emergency drills that involve the LEPC and emergency response organizations. The refinery provides periodic refresher training to local emergency resp onders regarding the hazards of regulated substances that are present in the refinery. 8. CONCLUSION CRLLC has implemented a number of steps to improve the safety of the processes. All of the programs covered in this submittal are designed to facilitate change of unsafe situations and to ensure that when changes are performed to the processes in the facility, that they do not compromise Safety, Environment, Equipment, or Product Quality. These steps (i.e. those outlined in the General Accident Prevention Program) have been incorporated into everyday business functions that translate into an ongoing effort that improves safety at this facility. |