National Cooperative Refinery Association - Executive Summary |
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NATIONAL COOPERATIVE REFINERY ASSOCIATION REFINERY McPHERSON REFINERY McPHERSON, KANSAS RISK MANAGEMENT PLAN EXECUTIVE SUMMARY The purpose of this plan is to describe practices in place to mitigate hazards associated with the operation of the National Cooperative Refinery Association refinery located in McPherson, Kansas. Information in this plan is available to the Local Emergency Planning Committee, outside emergency response groups, and other interested parties. TABLE OF CONTENTS 1. SUMMARY 2. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 3. DESCRIPTION OF THE STATIONARY SOURCES AND REGULATED SUBSTANCES 4. HAZARD ASSESSMENT RESULTS Toxic Substance Scenarios Flammable Substance Scenarios 5. PREVENTION PROGRAM STEPS Employee Participation Process Safe ty Information Process Hazard Analysis Operating Procedures Training Contractors Pre-startup Safety Reviews (PSSRs) Mechanical Integrity Safe Work Practices Management of Change Incident Investigation Compliance Audits 6. CHEMICAL RISK MANAGEMENT STEPS 7. FIVE YEAR ACCIDENT HISTORY 8. EMERGENCY RESPONSE PROGRAM INFORMATION 9. PLANNED CHANGES TO IMPROVE SAFETY APPROVED: Ken I Roane DATE: June 18, 1999 Vice President, Refining Division 1.0 SUMMARY This document outlines the Risk Management Plan in place at the McPherson Refinery located at 1391 Iron Horse Road, McPherson, Kansas. This Risk Management Plan is intended to comply with the requirements of EPA's Risk Management Program (40 CFR part 68). 2.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The McPherson Refinery has a long standing commitment to worker and publi c safety. This commitment is demonstrated by the resources invested in accident prevention, the training of personnel and considering safety in the design, installation, operation, and maintenance of our facility. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our personnel are trained to respond to control and contain the release. 3.0 DESCRIPTION OF THE STATIONARY SOURCES AND REGULATED SUBSTANCES The McPherson Refinery operates a variety of processes to produce petroleum products from raw crude oil. The refinery is capable of processing over 80,000 barrels of crude oil and over 100,000 barrels of total feed stocks per day through its operation. The McPherson Refinery receives and transports petroleum products via trucks and pipelines and has a storage capacity of petroleum and refined products exceeding two million barrels in above ground tanks. The refinery has four regulated flam mable substances - propane, butane, isobutane and propylene above the threshold quantity. There are also processes that hold threshold amounts of regulated flammable mixtures. In addition, the refinery uses hydrogen fluoride, which is also a regulated substance, in a quantity above the threshold quantity. 4.0 HAZARD ASSESSMENT RESULTS TOXIC SUBSTANCE SCENARIOS The worst case scenario (WCS) for a toxic substance release from this facility is a ten minute release of 88,000 lbs of hydrogen fluoride (HF) from the HF Alkylation Unit reactors and the acid settler. Based on the EPA Offsite Consequence Analysis Guidance/RMP Comp, a release of this size would result in an offsite impact. The alternative release scenario (ARS) for hydrogen fluoride at this facility is a five minute release of 464 pounds from a failed gauge glass on the #1 Acid Settler. Based on the EPA Offsite Consequence Analysis Guidance/RMP Comp, a release of this size would result in offsite impacts. The five minu te release duration is based on the time it would take to identify the release and isolate it from the remaining inventory. Rapid intervention by process operators to close block valves to stop the release was the only active mitigation measure that was taken into account in evaluating this scenario. Other mitigation measures that would help to prevent, identify and minimize the effects of this release include: Procedures that call for Gauge glasses to be normally kept closed, Unit Operators in personal protective equipment are present when gauge glasses are opened, hydrogen fluoride detection devices in area, Control room closed circuit television cameras monitor operators opening gauge glasses and Remote operated water deluge mitigation system. FLAMMABLE SUBSTANCE SCENARIOS The worst case scenario (WCS) for a flammable substance release from this facility involves the release and subsequent vapor cloud explosion of the inventory of tank 32 or tank 33 (identical tanks in same are a). The capacity of either tank is 820,000 pounds of n-butane. Based on the EPA Offsite Consequence Analysis Guidance/RMP Comp, a release of this size would result in an offsite impact. The alternative release scenario for flammable substances at this facility is a vapor cloud fire resulting from a release of a mixed flammable mixture from a gas compressor in the FCC Unit. This scenario considers the breaking off of a one inch chemical injection line on the high stage discharge line of a compressor. Based on the EPA Offsite Consequence Analysis Guidance/RMP Comp, a release of this size would result in an offsite impact. 5.0 PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the refinery. Because the processes at the refinery are regulated by the EPA Risk Management Program (RMP) regulation and OSHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the managemen t system in place to implement the accident prevention program. Employee Participation (McPherson Refinery policy: PSM, Doc. 8502) The McPherson Refinery encourages employees to participate in all facets of process safety management and accident prevention. Each process unit has one employee representative in the position of Special Project Operator. This employee is responsible for writing and updating operating procedure, verifying P&ID drawings with engineers and interfacing between unit operators and management. Other examples of employee participation include updating and compiling technical documents and chemical information, participating in the Union/Management Health and Safety Committee and 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 through an electronic computer system called Mockingbird. This system allows employees access to numerous drawings, proce dures, and safety information. Process Safety Information (McPherson Refinery policy: PSM, Doc. 8503) The McPherson Refinery keeps a variety of technical documents 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/configuration 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 is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the refinery has documented safety-related limits for specific process parameters (e .g., temperature, level, composition). The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The McPherson Refinery also maintains numerous mechanical 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. Much of this information is available through the Mockingbird system that can be accessed from computers in the refinery, the maintenance shop and administrative offices. Empl oyees can obtain additional information not found on Mockingbird through their supervisor and the engineering department. Process Hazard Analysis (PHA) (McPherson Refinery policy: PSM, Doc. 8504) The McPherson Refinery 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 McPherson Refinery primarily uses the hazard and operability (HAZOP) analysis technique to perform 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 and safety 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 findings are forwarded to the Process Hazard Coordinator for resolution. 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 immediate attention. 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 McPherson 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. Th e results and findings from these updates are documented and retained. Operating Procedures (McPherson Refinery policy: PSM, Doc. 8505) The McPherson Refinery maintains written procedures that address various modes of process operations, such as unit startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and 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. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. In addition, the McPherson Refinery maintains as part of the operating procedures, documentation that provides guidance on how to respond to exceeding upper or lower limits for specific process or equipment parameters. This information, along with wri tten operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training (McPherson Refinery policy: PSM, Doc. 8506) To complement the written procedures for process operations, the McPherson Refinery 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 (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 a t 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. Contractors (McPherson Refinery policy: PSM, Doc. 8507) The McPherson Refinery uses contractors to supplement its work force 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 perform their work in a safe manner, have the appropriate knowledge and skills, are aware of the hazards in their workplace, understand what they should do in the event of an emergency, understand and follow site safety rules and, inform refinery personnel of any hazards that they find during their work. This is accomplished by providing contractors with a process overview, information about safety and health hazards, emergency response plan requirements, and safe work practices prior to their beginning work. In addition , McPherson 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. Pre-startup Safety Reviews (PSSRs) (McPherson Refinery policy: PSM, Doc. 8508) The McPherson Refinery 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 requir ing verification that accident prevention program requirements are properly implemented. Mechanical Integrity (McPherson Refinery policy: PSM, Doc. 8509) The McPherson Refinery 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. The basic aspects of this program include: identification and categorization of process equipment, performing inspections and tests of process equipment, correcting identified deficiencies, applying quality assurance measures and documentation of these steps. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. 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) and meets the applicable regulatory c odes and standards. If a deficiency is identified, corrections will be made before placing the equipment back into service (if possible), or an Management of Change (MOC) team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Training requirements for maintaining and inspecting process equipment including an overview of the process, its hazards and procedures applicable to employee is given to assure work is performed in a safe manner. Another integral part of the mechanical integrity program is quality assurance. The McPherson 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 materials and spare parts are used when repairs are made. Safe Work Practices (McPherson Refinery policy: PSM, Doc 8510 and other Safety Procedures) The McPherson Refinery has long-standing safe work practices in p lace 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. Management of Change (McPherson Refinery policy: PSM, Doc 8511) The McPherson Refinery 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), procedur es, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and 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. Incident Investigation (McPherson Refinery policy: PSM, Doc 8512) The McPherson Refinery promptly investigates 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 determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, dev elops 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 PHA's and PHA revalidation's. Compliance Audits (McPherson Refinery policy: PSM, Doc 8514) To help ensure that the accident prevention program is functioning properly, the McPherson Refinery 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 develops findings that are forwarded to refiner y 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. 6.0 CHEMICAL RISK MANAGEMENT STEPS The processes at the McPherson Refinery have hazards that are managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA RMP-covered processes at the McPherson Refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and/or human errors. In addition to the accident prevention program activities, the McPherson 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 in various processes: Release D etection 1. Hydrocarbon (crude oil products) detectors with alarms 2. Hydrogen Fluoride and Hydrogen Sulfide detectors with alarms 3. Process instrumentation with alarms 4. Twenty four hour/day monitoring of processes by process unit operators. Release Containment/Control 1. Process relief valves that discharge to a flare where releases are incinerated 2. Valves to permit isolation of the process (manual and/or automated) 3. Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 4. Vessels to permit partial removal of the process inventory in the event of a release 5. Curbing or diking to contain liquid releases 6. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump). 7. Atmospheric relief devices Release and Fire Mitigation 1. Refinery fire water system Two diesel driven pumps One steam driven pump Fire hydrants with permanently mounted water monitors through out refinery Permanent fire fighting foam stations 2. Fixed deluge systems for specific process equipment 3. Trained emergency response teams (24 hour pager on call) Fire Brigade Rescue Team Hazardous Materials Team Emergency Medical Team 4. Emergency Response Equipment Two fire fighting pumper trucks Hazardous materials response trailer Specialized fire fighting foam equipment Pick-up carrying rescue and medical equipment 5. Personal protective equipment for refinery personnel HF Alkylation Unit Active Mitigation Equipment 1. Closed circuit unit television system monitored 24 hours/day by operators 2. Remote operated valves for containment of hydrogen fluoride in event of leak 3. Elevated deluge m onitors around hydrogen fluoride area 4. Deluge system on hydrogen fluoride pumps and gauge glasses 5. Fire hydrant mounted monitors around hydrogen fluoride storage. 6. Administrative control to minimize amount of hydrogen fluoride in storage. Other Items to Prevent or Mitigate a Release / Fire 1. Mutual aid agreements with local emergency agencies 2. Weekly training for Emergency Response Teams Classroom training Field training 3. Employees are trained on emergency response duties through Classroom training Field training Computer based training 4. Refinery emergency notification systems Refinery emergency outdoor warning system Pager system for process units and emergency personnel Multi-channel employee hand held radio system Refinery emergency telephone number answered by 24 hour dispatch 5. Preventative maintenanc e program for refinery process equipment 6. Scheduled maintenance and testing of emergency equipment and systems 7. Onsite refinery engineering staff to ensure equipment and processes comply to latest specifications 8. Scheduled refinery shutdown for maintenance (3 year schedule) 9. Full time Environment, Health and Safety staff 7.0 FIVE YEAR ACCIDENT HISTORY McPherson Refinery has an excellent record of accident prevention over the past 5 years. None of the incidents that have occurred have resulted in off site effects. McPherson Refinery investigates every incident very carefully to determine ways to prevent similar incidents from occurring. Listed below is a summary of the number of accidents that have occurred during the past 5 years. McPherson Refinery Five Year Accident History Year RMP events-onsite effects RMP events-offsite effects 1994 0 0 1995 0 0 1996 0 0 1997 1 0 1998 0 0 1999 0 0 The McPherson Refinery experienced an accidental release of mixed flammables in 1997. It resulted in onsite property damage from a fire with no injuries. It did not result in an offsite impact. 8.0 EMERGENCY RESPONSE PROGRAM INFORMATION McPherson Refinery maintains a written emergency response plan to ensure a coordinated and timely response to chemical releases, fires, explosions, natural disasters as well as other emergencies. This type of response is necessary to protect public and worker safety as well as the environment. Items covered in the plan include emergency notification and response of employees, notification of local emergency response agencies and the public, first-aid and emergency medical care, evacuation plans and routes, the accounting of personnel after an evacuation, emergency equipment list, the inspection, testing and maintenance of emergency equipment, and employee emergency plan training requirements. The emergency response program is reviewed annually and updated as needed. The overall emergency response program for the McPherson Refinery is coordinated with the McPherson County Local Emergency Planning Committee (LEPC). This committee is comprised of local emergency response officials, industry representatives and other concerned citizens. McPherson Refinery has a representative on this committee. McPherson Refinery has the capability to communicate with McPherson County Emergency Management officials and emergency response organizations by telephone and hand held radios. 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 LEPC meetings, McPherson Refinery conducts periodic emergency drills that involve the LEPC and emergency response organizations. The refinery provides refresher training to local emergency responders regarding the hazards of regulated substances in the refinery. 9.0 PLANNED CHANGES TO IMPROVE SAFETY McPherson Refinery is constantly looking for ways to improve safety and decrease possible exposure to chemicals. The following types of changes have taken place o r are currently planned to improve the safe operation of the facility: Replace cooling water chlorine gas injection systems with a less hazardous solution. Reduce the maximum inventory of chlorine stored onsite to a minimal quantity. Conduct an audit of the Alkylation Unit and compare results to American Petroleum Institute recommended practice bulletin 751 to verify Hydrogen Fluoride safe work practices. Additional sprinkler and deluge systems. |