Jupiter Sulphur, LLC. - Billings - Executive Summary |
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1.0 Billings Facility Risk Management Plan: Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Billings Facility (Facility) 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 the facility's processes. The Jupiter Sulphur, Inc. (Jupiter) policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to, control, and contain the release. Jupiter owns and operates the Billings Facility located in Billings, Montana. The facility receives H2S gas from the adjacent Conoco Refinery and processes it into various products. The plant produces Ammonium Bisulfite (ABS), Ammonium Thiosulfate (ATS), and Ammonium Sulfide (AS). All of these products contain ammonia and as such ammonia is a raw material that is stored on site. The H2S gas is transferred to the plant by pipeline from the refinery. The gas is sent to a liquid knockout pot to remove any entrained liquid from the gas. The gas is then routed to one or more of three areas to be processed depending on product needs. ABS Production The ABS facility consists of a burner, a heat recovery boiler, and an absorber/reactor. The SO2 from the burner is cooled in the boiler and then is sent to the absorber/reactor where it is contacted with ammonia and water to make ABS. The ABS is stored and either shipped as product or used as a feed material to the ATS plant. ATS Production The ATS facility consists of an absorber/reactor where ABS is contacted with H2S, ammonia, AS and water to produce ATS. The ATS is then sent to storage and shipped as product. AS Production The AS facility consists of an absorber/reactor where H2S is contacted with ammonia and water to produce AS. The AS is then sent to storage and either shipped as product or used as a feed material to the ATS plant. Ammonia Unloading and Storage Ammonia is used as a raw material in the facility. Ammonia can be received in railcars or trucks. The ammonia is offloaded through a rigid pipe system into one of four ammonia storage vessels. The ammonia is pumped into the ABS, ATS and ASC processes where it is reacted into the various products. The Facility was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, Facility personnel identified no listed flammable substances and only one toxic regulated substance kept on site. The chemical, quantity on site, and associated threshold quantity is presented in Table 1. TABLE 1 Largest Quantity of Regulated Substance Regulated Substance or Mixtures Containing Regulated Substance Largest Quantity On Site(lbs) Threshold Quantity (lbs) Ammonia (anhydrous) 219,725 10,000 Worst-Case Scenarios The listed substance which is stored above threshold quantities at the Billings Facility is anhydrous ammonia. Based on worst-case analysis, the distance to the endpoint exceeds the distance to public receptors. In addition, the Facility is subject to OSHA PSM. Therefore, the Billings Facility is classified as a Program 3 process under the Accidental Release Prevention (ARP) program. Flammable Substances The Facility does not have any flammable substances above the threshold quantity; therefore, analysis of worst-case release scenarios for flammable substances is not required. Toxic Substances The endpoint for a worst-case release of a toxic substance is based on the Emergency Response Planning Guideline level 2 (ERPG-2) developed for each substance by the American Industrial Hygiene Association. The ARP Program requirement for toxics, in a worst-case scenario, assumes the total qua ntity is released in ten minutes. The distance to the endpoint for the worst-case release of the above threshold quantity toxic substance using the EPA equations is presented in Table 2. A release of 219,725 lbs of ammonia (anhydrous) is the worst-case toxic release with a 5.03 miles distance to the endpoint. TABLE 2 Distance to Endpoint for Worst-Case Scenario Chemical Name Weight (lbs) Toxic Endpoint ERPG-2 (mg/L) Distance to ERPG-2 (miles) Ammonia (anhydrous) 219,725 0.14 5.03 Alternative Release Scenarios Alternative release scenarios are those that are more likely to occur than the worst-case release scenario. Alternative release scenarios for toxic substances should be those that lead to concentrations above the endpoints beyond the facility's fenceline. Alternative release scenarios for flammable substances should have the potential to cause substantial damage, including on-site damage. The following conditions are considered for alternative release scenarios: 7 Release rate dependent upon scenario; 7 Use of typical meteorological conditions at the stationary source; 7 Actual release height; and 7 Consideration of active and passive mitigation systems. Flammable Substances The Billings Facility does not have any flammable substances held above the threshold quantity. Therefore, analysis of regulated flammable substances are not required. Toxic Substances One alternative release scenario for each toxic substance is required under the ARP program. A hypothetical, but likely to occur, release scenario has been identified for the toxic substance above threshold quantity. This scenario involves a 10 minute leak of ammonia (anhydrous) at a swivel joint or flange located at the railcar unloading area. The distance to the toxic endpoint for the alternative-case release is presented in Table 3. The alternative-case release resulted in a 0.025 mile d istance to the 0.14 mg/L ERPG-2 endpoint for anhydrous ammonia. Table 3 Distance to Endpoint for Alternative-Case Scenario Chemical Name Total Estimated Release (lbs) Toxic Endpoint ERPG-2 (mg/L) Distance to (miles) Ammonia (anhydrous) 45.4 0.14 0.025 GENERAL ACCIDENT RELEASE PROGRAM The following is a summary of the accident prevention program in place at the Billings Facility. The processes at the plant that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard. Therefore, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. The facility is in the process of reviewing the accident prevention program and is in various stages of implementing charges to improve work place safety. Employee Participation Active employee participation and involvement in the development and implementation of the Facility's PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Employee involvement will help to ensure that all perspectives regarding PSM are considered, and that the best ideas are implemented. Open communications are encouraged between supervisors and employees regarding all safety and health issues. The Facility strongly promotes employee involvement in safety issues through existing programs. These programs include regularly scheduled safety meetings, "near-miss" reporting, and special training programs (emergency response training, first aid, etc.). The Billings Facility actively seeks employee involvement in the development and conduct of all accident preventi on activities through the appropriate existing safety programs. Accident prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments, or suggestions. Process Safety Information Complete and accurate written process safety information (PSI) concerning process chemicals, process technology, and process equipment is essential to effective PSM and RMP programs and to completing and maintaining a process hazard analysis (PHA). The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans. Process Safety Information is to be readily available to all employees. A variety of technical documents are to be kept that are used to help maintain safe operation of t he process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDSs). Numerous technical documents are to be maintained that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. 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 (PHA) There is a comprehensive program to help ensur e 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 Facility primarily uses the hazard and operability (HAZOP), checklist and What-if/Checklist method analysis techniques to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. PHA team members include a process/project engineer assigned for the process/project; plant manager or knowledgeable plant person; person knowledgeable in methods of hazard analysis; and others with particular expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. Th e 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 matrix assigned by the PHA team. The matrix is based on severity (criticality) and probability (frequency). This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. 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 PHA team 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 recommended order of analysis will be based upon the f ollowing criteria: 1) age of process; 2) extent of process hazards; 3) number of affected employees; and 4) operating history of the process. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures Written procedures are to be maintained that address various modes of process operations, such as; (1) initial startup, (2) normal operations; (3) temporary operations; (4) emergency shutdown; (5) emergency operations; (6) normal shutdown; (7) startup following a turnaround; and (8) start up after emergency shutdown. These procedures provide guidance for experienced operators and also provide the basis for training new operators. Operating procedures are to be periodically reviewed and annually certified as current and accurate. The review is to assure that the procedures reflect current operating prac tice, include changes from process technology changes, chemical changes, equipment changes, and changes to facilities. The review and certification process involves both operators and technical staff. The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities. To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees. Operating procedures are specific instructions or details on what steps are taken or followed in caring out the stated procedures. The specific instructions include the applicable safety precautions and appropriate information on safety implications. Training In addition to training on operating procedures, there is to be a comprehensive training program for all employees involved in operating the process. New employees are to receive bas ic training in process operations and procedures. In addition, all operators are periodically to receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is to be conducted at least every three years. The appropriate frequency of training is to be based on management in consultation with the employees involved in operating the particular process. All of this training is to be documented for each operator including the means used to verify that the operator understood the training. Contractors The Billings Facility uses contractors during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, there are procedures in place to ensure that contractors (1) perform their work in a safe manner; (2) have appropriate knowledge and skills; (3) are aware of the hazards of their workplace; (4) understand what they should do i n the event of an emergency; (5) understand and follow site specific safety rules; and (6) inform plant personnel of any hazards that they find during their work. This is to be accomplished by providing contractors with an orientation session that covers (1) a process overview; (2) information about safety and health hazards including known or potential fire, explosion, or toxic release hazards; (3) emergency response plan requirements; and (4) safe work practices must be developed and implemental regarding control of entrance, presence and exit of contract personnel prior to beginning their work. In addition, contractor safety programs and performance during the selection of a contractor are to be evaluated. Contract employee injury and illness log should be maintained. Plant personnel are to periodically monitor contract performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Review (PSSR) A PSSR should be conducted on any new facili ty or facility modification that requires a change in process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment and highly hazardous chemicals into service. This review provides one additional check to make sure construction is in accordance with design specification and that all-supporting systems are operationally ready. The PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. The PSSR also ensures that procedures (safety, operating, maintenance, and emergency) are in place and adequate. A PHA is determined to have been conducted, recommendations resolved, and training of employees involved in the process is verified as part of the PSSR. Mechanical Integrity Well established practices and procedures for main taining process equipment should be kept. The basic aspects of this program are to include (1) training; (2) developing written procedures; (3) performing inspections and tests consistent with good engineering practices; (4) correcting equipment deficiencies outside acceptable PSI limits; and, (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. 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 jobs in a safe manner. Another integral part of mechanical integrity program is quality assurance. Quality assurance measures are to be incorporated 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 During construction of new processes or equipment, checks and inspections are to be performed to assure that installation is consistent with design specifications and manufacturer's instructions suitable for the particular application. The Facility has 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 and toxic substances before process piping and 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 o perations and maintenance activities are performed safely. Management of Change There is a comprehensive system of written procedures to manage changes to all covered processes. This system requires that changes to items such as process chemicals, process equipment, technology (including process operating conditions), procedures, impact to safety and health and other facility changes be properly reviewed and authorized before being implemented. Prior to changes being made, they 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, including contractors employees, are provided any necessary training on the change. Incident Investigation The Facility will promptly inv estigate (within 48 hours) all incidents that resulted in or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to gather the facts, determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident. The reports are maintained for five years. An investigation team is established to investigate each process incident. The team will consist of members involved in the incident including at least one person knowledgeable in the process involved; a contract employee (if the incident involved the work of a contractor); and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. The investigation team documents its findings in a report. The report includes dates of incident and of investigation, description of incident, factors contributing to the incident, and a re commendation to prevent a recurrence. These results are forwarded to the business management team for resolution. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Billings Facility 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 staff personnel participate as audit team members with at least one person knowledgeable in the audit techniques. The audit team develops findings in a report that is forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked and documented until they are complete. The final resolution of each finding is documented, and the appropriate enhancements to the prevention program are implemented. The two most recent compliance audit reports are retained. Chemical Specific Prev ention Steps The processes at the Billings Facility have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program summarized previously is applied to the RMP-covered process at the Billings Facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The Facility 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 in the RMP covered process: Release Detection 1. Ammonia sensors with audible alarms are located on the loading rack. Release Containment/Control 1. Pressure relief v alves on railcars designed to relieve at 280 psi. 2. Key manual valves are chained and padlocked in their critical (open/closed) position. 3. Automated shutdown systems activated by sensors that close. 4. Excess flow check valves designed to plug the outlet if outflow reaches a certain flow rate. 5. Safety relief valve designed with audible alarms to indicate a release. 6. Derailers and chock blocks to prevent rail car movement. Release Mitigation 1. Standard operating procedures that control, isolate, and terminate leaks. 2. Water fog streams employed at origin of the leak. 3. Personnel trained in emergency procedures. 4. Personal protective equipment (e.g., escape respirator, self-contained breathing apparatus, and supplied air breathing apparatus) Five Year Accident History The Billings Facility has an excellent record of accident prevention over the past five years. There has been no incident involving a release of anhydrous ammonia which caused any off-site effects. Emergenc y Procedure Information The Facility maintains a written emergency procedure, which is in place to protect worker and public safety as well as the environment. The procedures account for the possibility of a toxic substance being accidentally released, as well as for the possibility of a fire or explosion. The procedures address notification of local emergency response agencies if a release occurs, and post incident cleanup and decontamination requirements. Employees receive training in emergency procedures. The emergency procedure is updated when necessary based on modifications made to the Facility. The emergency procedure changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes. The overall emergency procedure program for the Facility is coordinated with the Yellowstone County Emergency Disaster Center. The Facility has around-the-clock communications capability with appropriate officia ls 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, the Facility conducts periodic emergency drills that involve emergency response organizations, and the Facility provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the plant. |