Countrymark Cooperative, Inc. - Executive Summary
COUNTRYMARK COOPERATIVE INC. |
1200 REFINERY ROAD
MT. VERNON, INDIANA
RISK MANAGMENT PLAN
Countrymark Cooperative Inc. supports the concept and requirements of EPA's Risk Management Planning Regulations as outlined in 40 CFR Part 68 Section 112 (r ). It is the policy of Countrymark to conduct our business and operate our facilities in a manner that will protect the health and safety of our employees, the public and the environment.
We believe it is important for interested parties to have access to information that can help them better understand our business, our facility and possible impacts. If you have any questions about this document, our company or our plans, please contact our Community Relations Representative (Jimmye Wiginton) at 812-838-8130 or the EH & S Manager,(Don Horning) at 812-838-8133.
Countrymark Cooperative, Inc. owns and operates a small 24,000 barrel per day petroleum refinery that produces quality m
otor and heating fuels for farm, commercial and residential use. The refinery started production in Mt. Vernon in the early 1940's and is proud of the role it continues to play in Indiana agriculture. Countrymark employs approximately 250 people, many of whom live in Mt. Vernon.
The refinery feedstock is sweet (naturally low sulfur levels) crude oil typically from producers in southern Illinois, Indiana and western Kentucky. Crude oil is gathered via a system of underground gathering pipelines and over-the-road transports. Finished fuel products are transported from Mt. Vernon to terminals in Switz City, Jolietville and Peru, Indiana via a 238 mile long underground pipeline. Countrymark's customer base is predominantly agriculture, but commercial accounts serve all business sectors.
PETROLUEM REFINING AND EMERGENCY RESPONSE
Petroleum refining uses heat, pressure and catalysts to process the raw crude oil into finished products. The crude oil, many of the processing chemica
ls and the finished product are designated as hazardous materials by the US Environmental Protection Agency. There are three primary chemicals managed at the refinery that are regulated under EPA's Risk Management Planning regulation: (1) Hydrofluoric Acid (Also known as Hydrogen Fluoride) is a regulated toxic hazardous material and is used as a catalyst when making gasoline and, 2) Iso-butane is a regulated flammable hazardous material used as a unit feedstock. (3) Propane is a finished product that is similar to iso-butane for purposes of the worst case scenario. They are stored in close proximity to each other. Isobutane was used in the Worst / Alternate case scenarios due to having the larger tank and therefore more significant consequences. There are other chemicals on site such as ammonia and chlorine, that are present in smaller amounts but are not above the RMP regulatory thresholds.
Countrymark is committed to operating in a safe and environmentally sound manner while
complying with governing laws, regulations and engineering standards. This commitment is demonstrated through resources invested in safe design, operation and maintenance of our facilities. Our operating practices and procedures ensure that numerous controls are implemented to prevent a release of toxic or flammable materials.
If a major release would occur, we have several layers of response that would be activated. Unit Operators are trained in initial responses to all types of potential incidents. If warranted, the on-site Fire Response Brigade is called to provide the firefighting or emergency manpower requirements in the initial stages of a release. Next, a general community and industrial mutual aid fire response could be requested. Commercial emergency responders could be also be obtained in addition to activation of all available emergency responders within a large radius of the refinery.
HAZARD ASSESSMENT RESULTS
EPA's Risk Management Planning regulation requires
that two types of potential releases undergo Worst Case Scenario (WCS) analyses: toxic WCS's and, flammable WCS's. As defined by EPA, a WCS assumes that the numerous engineering and administrative safety controls currently in place all fail at once. Specifically, a WCS assumes a catastrophic failure of an entire vessel and release of contents over a 10-minute period. Countrymark used both the EPA's RMP Comp program and the ALOHA software when evaluating WCS endpoints. The RMP Comp calculation was reported in the RMP submittal.
EPA also requires preparation of an Alternate Release Scenario (ARS) for each category as applicable. The ARS uses more realistic or plausible assumptions, such as a pipe or valve failure.
For the flammable WCS, Countrymark used Iso-butane which is generally similar to propane which is also stored on-site. The largest Iso-butane tank has a capacity of 312, 946 gal @ 85% capacity (368,172 max.) or 1,470,846 lbs. when full. The WCS flammability end point
is approximately 1 mile. The ARS (most likely) is approximately one-half mile.
For the toxic WCS, Countrymark used Hydrofluoric Acid. The working tank volume for HF Acid in process (acid settler) is 4,560 gallons or 36,936 lbs. The WCS toxic end point is approximately 6 miles. The ARS (most likely) is 3 miles.
ACCIDENTAL RELEASE PREVENTION
Countrymark previously implemented a comprehensive program to prevent accidental releases of highly hazardous chemicals under the U.S. Occupational Safety and Health Agency (OSHA) Process Safety Management (PSM) Program. Countrymark's PSM program ensures that proper safety information is in place; operating procedures are followed; chemical hazards are identified; employees and contractors are trained; and critical equipment is inspected and maintained. The OSHA PSM program satisfies the EPA's RMP requirements.
Some of the many, specific procedures in place to prevent a chemical accident include:
7 Safety procedures that reduce the po
tential for human error leading to a tank overfill;
7 Routine pipe and vessel inspection and testing;
7 Safety information about the processes available to employees;
7 Written operating procedures that include emergency response actions;
7 Employee and contractor awareness training programs to promote consistently safe work practices;
7 Maintenance programs to ensure ongoing equipment reliability;
7 Compliance auditing to ensure standards are being followed;
7 Incorporation of PSM "Management of Change" review procedures;
7 Safety reviews prior to start-up of our processes;
7 Full implementation of OSHA permit required programs.
FIVE YEAR ACCIDENT HISTORY
EPA's RMP regulation requires that any incidents involving regulated chemicals that resulted in any off-site impact or significant on-site impacts be reported in this document. The Countrymark refinery has an excellent history of accident prevention as indicated by the absence of any recordable releases of hydrofluoric acid, Iso-b
utane or propane in the last 5 years.
EMERGENCY RESPONSE PROGRAM
Countrymark refinery maintains a comprehensive emergency response program designed to protect employees, the public and the environment in the event of a hazardous material incident. All refinery employees receive emergency response training. Operations employees receive additional response training for particular units on their rotation. The written Emergency Response Plan describes actions and resources necessary in the event of an emergency.
We maintain a trained Fire Response Brigade with response equipment matched to the unique hazards of a petroleum refinery. We are active members of the Mt. Vernon Industrial Mutual Aid and River Spill Response Mutual Aid groups. We have employees who are active volunteer firefighters, are on the local ALERT Committee, and the RMP related CLEAR (Chemical Leadership and Education Awareness Resource) Committee. The CLEAR Committee is a Mt. Vernon area industry task force
formed to specifically address RMP requirements and to improve emergency preparedness.
PLANNED CHANGES TO IMPROVE SAFETY
Countrymark has an ongoing Risk / Safety Oversight Committee that is meant to support the Environmental, Safety and Health Policies. This Risk/ Safety Oversight Committee monitors and tracks training, incident investigations, performance audits and other related activities designed to reduce overall risks. It is our intention to continue this program and further develop behavioral safety initiatives. We also work closely with our insurers and risk underwriters to evaluate and plan on physical changes that may further reduce inherent facility hazards and risks. Written emergency pre-plans have been prepared on RMP worst case equipment and more are planned that specifically covers other refinery areas.
Physical improvements designed to increase our margin of safety are planned and include upgrades to the fire protection system, detection system and soil grading
to enhance fire fighting in particular areas on site.