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Alon Refining Krotz Springs, Inc.

Parent Companies:
Alon USA Energy, Inc.
EPA Facility ID:
100000113824
Other ID:
70750HLLPTHWT10
Facility DUNS:
0
Parent Company DUNS:
876661062

Location:

Address:
P.O. Box 453
Krotz Springs, LA 70750
County:
ST. LANDRY
Lat / Long:
30.527, -91.746 (Get map)
Method:
Interpolation - Photo
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Alon USA Energy, Inc.
Phone:
(972) 367-3600
Address:
PO Box 517030
Dallas, TX 75251 -7030
Foreign Address:

Person responsible for RMP implementation:

Name:
Mark Hollier
Title:
PSM Supervisor

Emergency contact:

Name:
Charles Frederick
Title:
Superintendent Emergency Services
Phone:
(337) 566-0281
24-hour phone:
(337) 566-0100
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 566-2301
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. Landry Parish LEPC
Full-Time Equivalent Employees:
186
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2600-00003-V1
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Aug. 15, 2014
Inspecting Agency:
OSHA
Using Predictive Filing:
No

Processes:

Isomerization Unit (15)
RMP ID:
1000060598
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
110,000
No
Public OCA Chemical
0
No
Reformer Unit (20)
RMP ID:
1000060599
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
240,000
No
Public OCA Chemical
0
No
MTBE Unit (21)
RMP ID:
1000060600
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
580,000
No
Public OCA Chemical
0
No
Crude Unit (23)
RMP ID:
1000060601
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
42,000
No
Ammonia (anhydrous)
7664-41-7
12,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
ATS Unit (35)
RMP ID:
1000060602
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
150,000
No
Public OCA Chemical
0
No
POLY Unit (40)
RMP ID:
1000060603
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
140,000
No
Public OCA Chemical
0
No
FCC Unit (42)
RMP ID:
1000060604
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
430,000
No
Hydrogen sulfide
7783-06-4
20,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Offsites Unit (90)
RMP ID:
1000060605
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
26,000,000
No
Pentane
109-66-0
29,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
GDU UNIT (45)
RMP ID:
1000060606
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
100,000
No
Public OCA Chemical
0
No
LRU Unit (30)
RMP ID:
1000060751
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
10,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Rasheed Reynolds, Environmental Resources Management
Address:
775 N. University Blvd.
Suite 280
Mobile, AL 36608
Foreign Address:

Phone:
(251) 706-8600

Latest RMP Submission:

Date:
Feb. 18, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000048429

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in ATS Unit (35))
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in ATS Unit (35))
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in FCC Unit (42))
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Offsites Unit (90))
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Offsites Unit (90))
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

April 25, 2013 at 08:14
ID:
1000037337
NAICS:
Petroleum Refineries (32411)
Duration:
8 hours and 15 minutes
Chemicals involved:
  • Propane
  • Butane
Release events:
Gas release
Fire
Weather conditions at time of event
Wind speed:
12.0 miles/h NE
Temperature:
55.00 ℉
Atmospheric stability:
D
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$7000000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Improper procedure
  • Maintenance activity/inactivity
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised maintenance

7. Prevention: Program level 3

Isomerization Unit (15), Petroleum Refineries (32411)
Prevention Program ID:
1000050410
Safety Review Date
Dec. 4, 2014, since latest RMP submission
PHA Update Date
Aug. 16, 2012, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Jan. 5, 2015, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
July 14, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 29, 2014
Management of Change Review Date
Nov. 26, 2012
Pre-startup Review Date
Dec. 29, 2014
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
May 28, 2011
Incident Invest. Change Completion Date
Dec. 30, 2013
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission
Reformer Unit (20), Petroleum Refineries (32411)
Prevention Program ID:
1000050411
Safety Review Date
Jan. 6, 2015, since latest RMP submission
PHA Update Date
April 16, 2014, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Dec. 10, 2014, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
Feb. 3, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 6, 2015
Management of Change Review Date
Nov. 26, 2012
Pre-startup Review Date
Jan. 6, 2015
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
March 4, 2014
Incident Invest. Change Completion Date
Aug. 4, 2014
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission
MTBE Unit (21), Petroleum Refineries (32411)
Prevention Program ID:
1000050412
Safety Review Date
Dec. 31, 2014, since latest RMP submission
PHA Update Date
April 29, 2014, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
Changes since PHA
  • Increased Inventory
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Oct. 31, 2014, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
Feb. 18, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 31, 2014
Management of Change Review Date
Nov. 26, 2012
Pre-startup Review Date
Dec. 31, 2014
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
July 30, 2014
Incident Invest. Change Completion Date
Dec. 31, 2014
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission
Crude Unit (23), Petroleum Refineries (32411)
Prevention Program ID:
1000050413
Safety Review Date
Dec. 29, 2014, since latest RMP submission
PHA Update Date
April 1, 2014, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Jan. 6, 2015, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
Nov. 26, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 29, 2014
Management of Change Review Date
Nov. 26, 2012
Pre-startup Review Date
Dec. 29, 2014
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
April 23, 2014
Incident Invest. Change Completion Date
Sept. 24, 2014
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission
ATS Unit (35), Petroleum Refineries (32411)
Prevention Program ID:
1000050414
Safety Review Date
Sept. 11, 2014, since latest RMP submission
PHA Update Date
Sept. 13, 2012, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Jan. 22, 2015, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
Sept. 8, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 16, 2014
Management of Change Review Date
Nov. 26, 2012
Pre-startup Review Date
Sept. 16, 2014
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
Nov. 28, 2011
Incident Invest. Change Completion Date
Jan. 29, 2013
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission
POLY Unit (40), Petroleum Refineries (32411)
Prevention Program ID:
1000050415
Safety Review Date
Nov. 18, 2014, since latest RMP submission
PHA Update Date
May 7, 2013, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Nov. 5, 2014, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
June 11, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 20, 2014
Management of Change Review Date
Nov. 26, 2012
Pre-startup Review Date
Nov. 20, 2014
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
April 5, 2013
Incident Invest. Change Completion Date
Feb. 11, 2014
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission
FCC Unit (42), Petroleum Refineries (32411)
Prevention Program ID:
1000050416
Safety Review Date
Dec. 18, 2014, since latest RMP submission
PHA Update Date
Oct. 6, 2010, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Sept. 30, 2014, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
Nov. 19, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 18, 2014
Management of Change Review Date
Nov. 26, 2012
Pre-startup Review Date
Dec. 18, 2014
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
Aug. 13, 2014
Incident Invest. Change Completion Date
Feb. 1, 2015
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission
Offsites Unit (90), Petroleum Refineries (32411)
Prevention Program ID:
1000050417
Safety Review Date
Jan. 8, 2015, since latest RMP submission
PHA Update Date
June 4, 2014, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Dikes
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
Dec. 2, 2014, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
July 5, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 8, 2015
Management of Change Review Date
Nov. 23, 2012
Pre-startup Review Date
Jan. 8, 2015
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
Oct. 16, 2014
Incident Invest. Change Completion Date
Jan. 1, 2016
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission
GDU UNIT (45), Petroleum Refineries (32411)
Prevention Program ID:
1000050418
Safety Review Date
Nov. 16, 2014, since latest RMP submission
PHA Update Date
April 14, 2011, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
July 26, 2014, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
Nov. 22, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 16, 2014
Management of Change Review Date
Nov. 26, 2012
Pre-startup Review Date
Nov. 16, 2014
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
Oct. 26, 2010
Incident Invest. Change Completion Date
Nov. 4, 2010
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission
LRU Unit (30), Petroleum Refineries (32411)
Prevention Program ID:
1000050539
Safety Review Date
Nov. 12, 2014, since latest RMP submission
PHA Update Date
Feb. 18, 2011, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Dec. 12, 2014, since latest RMP submission
Training Review Date
Aug. 15, 2014, since latest RMP submission
Maintenance Review Date
Sept. 25, 2014, since latest RMP submission
Maintenance Inspection Date
Nov. 26, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 29, 2014
Management of Change Review Date
Nov. 26, 2012
Pre-startup Review Date
Dec. 4, 2014
Compliance Audit Date
July 20, 2012
Compliance Audit Change Completion Date
May 15, 2015
Incident Investigation Date
Dec. 6, 2013
Incident Invest. Change Completion Date
Aug. 7, 2014
Participation Plan Review Date
Aug. 5, 2014
Hot Work Review Date
July 14, 2014
Contractor Safety Review Date
May 5, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 10, 2014, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Jan. 5, 2015
Local Response Agency:
Local Response Agency Phone:
(337) 566-3311
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary



Executive Summary



The Krotz Springs Refining Company - is located at P.O. Box 453 Hwy. 105 South; Krotz Springs, St. Landry Parish, Louisiana 70750-0453. The facility is committed to operating in a manner that is safe for the facility's workers, the public, and the environment. As part of this commitment, Krotz Springs Refining Company has established systems to ensure safe operation of the facility. One part of this system is the Risk Management Program (RMP) that complies with the Environmental Protection Agency's (EPA's) regulation 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a Risk Management Plan (RMPlan) describing the risk management program at Krotz Springs Refining Company. This document is intended to satisfy the RMPlan requirements and to provide the public with a description of the risk management program at the facility in Krotz Springs, Louisiana.









Risk Management Program





Written Plan for Krotz Springs Refining Company









Table of Contents



INTRODUCTION

DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES

ACCIDENTAL RELEASE PREVENTION AND RESPONSE PRACTICES AND PROGRAMS

HAZARD ASSESSMENT RESULTS

FIVE YEAR ACCIDENT HISTORY

GENERAL ACCIDENT RELEASE PREVENTION PROGRAM STEPS

1.0 EMPLOYEE PARTICIPATION

2.0 PROCESS SAFETY INFORMATION

3.0 PROCESS HAZARD ANALYSES

4.0 OPERATING PROCEDURES

5.0 TRAINING

6.0 CONTRACTORS

7.0 PRE-STARTUP SAFETY REVIEW (PSSR)

8.0 MECHANICAL INTEGRITY

9.0 HOT-WORK/SAFE WORK PERMIT PRACTICES

10.0 MOCA

11.0 INCIDENT INVESTIGATION

12.0 EMERGENCY PLANNING AND RESPONSE

13.0 COMPLIANCE AUDITS

CHEMICAL SPECIFIC PREVENTION STEPS

RELEASE PREVENTION

RELEASE DETECTION

RELEASE CONTAINMENT/CONTROL

RELEASE MITIGATION

EMERGENCY RESPONSE PROGRAM

1.0 EMERGENCY RESPONSE PLAN

2.0 EMERGENCY RESPONSE EQUIPMENT INSPEC
TION, TESTING & MAINTENANCE

3.0 MUTUAL AID PARTICIPATION

4.0 TRAINING FOR ALL EMPLOYEES IN RELEVANT PROCEDURES

PLANNED CHANGES TO IMPROVE SAFETY









Introduction



1000 0011 3824 EPA Facility ID Number





Description of the Stationary Source and Regulated Substances



Krotz Springs Refining Company is located in Krotz Springs, Louisiana. The

refinery utilizes crude and related hydrocarbon products and chemicals to

manufacture refined petroleum products such as gasoline, diesel and LPG. These

products are manufactured in several process units, and are produced through the

refining of petroleum. Operation of these processes involve the use or handling

of certain listed regulated substances as defined by the Environmental Protection

Agency (EPA). The information below indicates the processes as defined by the RMP

rule and the regulated substances therein:



-Isomerization Unit 15 - Program 3: methane, ethane, propane, isobutene, butane, isopentane, pentane, and hydrogen.



-Reformer Unit (20) - Program 3: methane, ethane, propane, isobutene, butane, isopentane, pentane, and hydrogen.



-MTBE Unit (20) - Methyl Tertiary Butyl Ether - Program 3: isopentane, methane, pentane, propane, propylene, isobutene, butane, 1-butene, butene, 2- butene, 2-butene-cis, 2-butene-trans.



-Crude Unit (23) - Program 3: ethane, propane, isobutene, butane, isopentane, pentane, methane.



-ATS Unit (35) - Ammonium Thiosulfate - Program 3: ammonia (anhydrous).



-POLY Unit (40) - Catalytic Polymerization - Program 3: 1-butene, 2-butene, butene, 2-butene-cis, 2-butene-trans, ethane, hydrogen,isopentane, methane, pentane, 1-pentene, 2-pentene (E)-, 2-pentene (Z)-.



-FCC Unit (40) - Fluid Catalytic Cracking - Program 3: methane, ethane, ethylene, propane, propylene, butane, isobutene, 2-butene-cis, 2-butene-trans, 2-butene, pentane, isopentane, 1-butene, hydrogen, hydrogen sulfide.



-Offsites Unit (90) - Program 3: propane, isobutene, bute
ne, pentane, isopentane, propylene, ethane, hydrogen, methane, butane.



-GDU Unit (45) - Gasoline Desulfurization Unit - Program 3: isobutene, butane, ethane, propane, pentane, isopentane, 1-butene, 1-pentene, hydrogen.



-LRU Unit (30) - Program 3: ethane, propane, isobutene, butane, isopentane, pentane, hydrogen, methane.







Accidental Release Prevention and Response Practices and Programs



The refinery's accidental release prevention and response practices and programs are

designed to protect the employees, contractors, visitors, the general public and the

environment. Our commitment is demonstrated through the way we conduct daily

business to safely maintain and operate the facility and prevent chemical releases.

In the event that a release does occur, both passive and active safety systems are

in place to support and provide the foundation to detect, control and minimize the

impact of the event. In addition to these safety systems and protocols, highly

trained employees and contractors take active roles in key design, maintenance and

operational programs intended to prevent releases, as well as, well developed and

rehearsed emergency response systems. In the event of a chemical release, members

of the ERT (Emergency Response Team) are trained as Incident Commanders, First

Responders, Emergency Medical Technicians, Rescue Team Members, HAZMAT and oil

spill response team members.









Hazard Assessment Results



A hazard assessment was performed to analyze releases for potential impacts to the

surrounding community and environment. These assessments consist of determining

"worst case" and "alternative case" scenarios as specified by the Environmental

Protection Agency (EPA). Since our facility is a Program 3 source, and because of

the site lay out, 2 "worst case" and 3 "alternative case" scenarios have

been selected after proposing and reviewing five worst case scenarios and thirteen

alternative case scenari
os.









Five Year Accident History



At Krotz Springs Refining Company - Louisiana, the Process Safety Management and the Risk

Management Plan are designed to protect the employees, public and environment.



On April 25, 2013 there was an RMP-related accident at the Alon USA-Krotz Springs Refinery.

Liquefied petroleum gas was released from a process vessel, resulting in a fire that caused

considerable property damage. At the time of the event, wind speeds were 12 mph NE at 55 degrees

Fahrenheit. The duration of the release was 8 hours and 15 minutes, beginning at 8:14 am.

Offsite responders were notified of this incident, and responded accordingly. There were no

deaths or injuries resulting from this release. It was determined that the cause of this was

release was human error. Maintenance procedures were revised in order to reduce the probability

of this event from reoccurring.







General Accident Release Prevention Program Steps





1.0 Employee Participation



Company employees are encouraged to actively participate in accident prevention at

Krotz Springs Refining Company. Employee participation in these efforts is accomplished on several levels both formally and informally. Seven specific procedures and programs

are:



* Employee Participation - S&HG (Safety and Health Guideline) #38

* Krotz Springs Refinery Employee Safety Team (KREST)

* Safety Field Visits

* Employee Safety Suggestion Program

* Process Hazard Analyses (PHA)

* Job Safety Analyses (JSA) - S&HG #44

* Krotz Springs Star Team S&HG #17



The Employee Participation S&HG #38 describes how employees are involved in the

development, implementation and maintenance of each element of the accident

prevention program. The procedure also describes how safety and health policies and

procedures are developed and approved through the Rules and Procedure Committee

whose membership consists of a mixture of hourly employees and management


personnel.



The Krotz Springs Refinery Employee Safety Team (KREST) is a voluntary employee committee whose purpose is to elevate safety awareness of all employees through activities, organized meetings, promotional contests, etc. The end result desired is to achieve a reduction of risky behaviors associated with injuries both on and off the job.

Some of the awareness improvement programs implemented include a Safety Incentive

Program, a safety slogan contest, and a safety calendar contest for children and

grandchildren of employees.



Safety Field Visits are performed by salaried and hourly employees to provide

informal forums for discussion of safe job performance and concerns. Potential

safety concerns are identified while a job is in progress and addressed before

they result in injuries or near misses.



The Employee Safety Suggestion Program is designed to provide another avenue for

employees to voice any safety issues. These safety issues are reviewed and

addressed by the supervision who then assigns the safety item to refinery

employees to resolve the issue when needed.



The Process Hazard Analyses (PHA) is conducted by a team of Krotz Springs Refinery employees and is lead by an outside consultant. At a minimum, the Krotz Springs Refinery team always consists of members representing engineering, maintenance and operations. Other employees and contract personnel with specialized expertise may be called in to participate on an as needed basis. (See Section 3.0 Process Hazard Analyses for more detail.)



A Job Safety Analyses (JSA) is a technique utilized by employees to break a small or

large job into its basic steps before performing the work. Each step is analyzed to

identify potential hazards that may cause an injury. Safe work practices are then

identified to prevent the potential injury identified while the work is performed.



The Krotz Springs Refinery Star Team consists of hourly employees. The purpose of this

com
mittee is to provide direction and evaluation of the Refinery safety programs,

review incidents, make operational or internal program evaluations.





2.0 Process Safety Information



At Krotz Springs Refinery, many written documents are available which provide guidance on how to

safely operate the various processes within the refinery. The documents related to

process safety information are utilized for training of employees and contractors to

identify and understand the hazards associated with each process. The documents are

also utilized as a resource when conducting process hazards analyses, and are

utilized as a reference during unit operations.



This documentation consists of information pertaining to:



* Chemical hazards

* Process technology

* Equipment in the process



The written documentation for chemical hazards is addressed through the use of

Material Safety Data Sheets (MSDSs) for both purchased and refinery made hazardous

materials. MSDSs are made available in hard copy format at the "right to know" station in the safety building and in electronic format through the refinery computer network. Specific chemical information describing the toxicity, reactivity, corrosivity, etc. is included in each MSDS. In addition, information pertinent to emergency response and first aid treatment for various routes of exposure is provided.



Many technical documents are maintained to provide information to employees

concerning the technology of the process. The technology of the process is

documented through process flow diagrams, process overviews, unit mechanical data

books, and operating procedures. All of these documents are readily available to

employees on a daily basis and are utilized in initial and refresher training of

company employees and contractors.



Many technical documents, policies and procedures are maintained to provide

information to employees concerning the equipment in the process. This informatio
n

includes, but is not limited to:



* Piping and Instrument Diagrams

* Piping Isometrics

* Instrument Loops

* Electrical One-Lines

* Unit Mechanical Data Books, etc.



These documents provide technical information including materials of construction,

electrical ratings, design codes and standards, relief system and safety system

design. These technical documents combined with written and implemented

maintenance and inspection procedures performed by highly trained personnel assist

in assuring that equipment is installed and operated as designed.





3.0 Process Hazard Analyses



Krotz Springs Refinery utilizes PHA's to ensure that controls are in place to minimize, manage and control hazards that may potentially affect both on-site and off-site personnel and the environment. By reviewing hazards associated with anticipatable changes in the process, PHA's are designed to assist in identifying operability problems, safety issues and environmental concerns, and the associated causes, consequences, safeguards and risks. In addition to performing PHA's that are triggered by changes, PHA's are also performed to revalidate unit PHA's at least every five years.



The primary style of PHA used within the Krotz Springs Refinery for both initial and

revalidation PHAs is the hazard and operability (HAZOP) study technique. This type

of PHA is accepted by industry as a very thorough and systematic hazard analysis

technique. The HAZOP is conducted by a team of Krotz Springs Refinery employees and is lead by an outside consultant. At a minimum, the Krotz Springs Refinery team always consists of members representing engineering, maintenance and operations. Other employees and contract personnel with specialized expertise may be called in to participate on an as needed basis. The HAZOP team identifies and evaluates potential hazards and any environmental, safety, and operational concerns which may have a deleterious effect either on site or off
site. Depending on the likelihood of an event or process change and the seriousness of the consequences, recommendations are formulated by the HAZOP team which are presented to refinery management to review and address as necessary. Recommendations are intended to improve process design, improve operability and improve safety.



Plant management will in turn assign each recommendations to individuals with the

experience and knowledge to address and close out each recommendation. Depending

on the potential impact of the hazard identified, target completion dates are

established for implementing the approved changes. These dates, in conjunction

with the Management of Change Authorization procedure, Pre-Startup Safety Review

procedure and the Work Order system are used as part of the tracking mechanism

to close out each item.





4.0 Operating Procedures



Krotz Springs Refinery has a fully developed set of operating procedures for all processes within

the refinery. These operating procedures have been developed to be consistent

with process safety information, and are maintained as such through annual reviews

by operating personnel and through the use of the Management of Change Authorization

(MOCA) procedure when changes to existing procedures are needed. Written

procedures address all aspects listed by the OSHA PSM standard and the RMP

regulations. Steps for each operating phase such as initial startup, normal

operations, temporary operations, emergency shutdown, etc. describe in a clear

and concise manner tasks to be performed. Other aspects of the manuals include

operating limits which detail the operating conditions to be met as well as

consequences of deviations from these safe limits. Safety and health

considerations are also included throughout these procedures and are also

addressed in a separate specific section.



Operating manuals have many uses, and are available throughout the refinery. Some

of the uses incl
ude training of new employees, refresher training for existing

employees and quick referencing for routine and non-routine tasks. Operating

manuals are available in hard copy format at the respective control rooms and

throughout the refinery on the computer network.





5.0 Training



Krotz Springs Refinery has a comprehensive training program in place for employees involved in

operating a process. This program is designed to address the needs of new employees

and experienced operators. New employees receive basic safety and process operator

training before being assigned to a process area. The basic training consist of

classroom lectures, videos, hands-on process training on "live" process models and

testing of all course material. Safety and health training is also provided by

reviewing and testing in-plant safety and health guidelines. After successfully

completing the basic training, a new operator is assigned to a process unit and

paired-up with an experienced operator until certification is completed for that

unit.



Experienced operators periodically receive refresher training to ensure that

knowledge is maintained at an acceptable level.





6.0 Contractors



Contractors performing maintenance or repair, turnaround, major renovation, or

specialized work on or adjacent to a covered process must meet certain training and

safety performance requirements. To ensure that contractors meet the minimum

training and safety performance requirements before being allowed into the refinery,

each contractor must be pre-qualified by submittal of certain safety record

information, meet any applicable safety training/certification requirements and be

approved before performing any work in the refinery. If a contract company is

awarded work by Krotz Springs Refinery, their employees' performance and continued qualification

while on site are periodically monitored to ensure that company standards are met

on an on-going basis
.





7.0 Pre-startup Safety Review (PSSR)



As required by OSHA and EPA regulations and in keeping with good operating practice,

Krotz Springs Refinery conducts pre-startup safety reviews when a modification to a process is

significant enough to change process safety information. As an integral part of our

Management of Change Authorization procedure, a PSSR ensures that operability,

design parameters, environmental concerns and safety issues are met prior to

commissioning the change. It also ensures that all employees and contractors

affected by the change are notified and/or trained prior to commissioning the

change. Where necessary, field verification occurs to ensure that actual

construction meets the design standards specified in the Management of Change. If

the change were determined to be too extensive or complex for a PSSR, a PHA would

be performed in addition to a PSSR.





8.0 Mechanical Integrity



Krotz Springs Refinery has practices and procedures in place to ensure that equipment has been

designed, constructed, installed and maintained to contain the chemicals in the

process. Any equipment or system used to store, process and handle highly hazardous

chemicals is included in the mechanical integrity program. Also, any other process

equipment, safety equipment and backup safety systems used to minimize the impact of

a release are included in the program.



Mechanical components and systems including pressure vessels, storage tanks, piping

systems, piping components, relief systems, vent systems, emergency shutdown

systems, safety equipment, monitoring devices, pumps, etc. are maintained through:



* Written procedures

* Training

* Inspection and testing (predictive and preventive maintenance)

* Safely/quickly correcting equipment deficiencies

* Quality assurance



Written procedures supply the guidance necessary to correctly repair, install and

perform predictive/preventive maintenance on critica
l equipment in a consistent,

safe manner.



Training is supplied through craft procedures and specialized training applicable

to the craft and process. This training and the procedures are kept current through

the management of change process. All of this training is intended to provide

craftsmen with the knowledge to maintain equipment integrity, or repair equipment

while performing the work in a safe manner.



Both the type and frequency of initial and on-going inspection and testing of

equipment are based on applicable codes, standards, and/or manufacturer's

recommendations. The results of these inspection and testing methods are used

to modify or create predictive and preventive maintenance protocols where

appropriate.



Inspection and testing assist in identifying deficiencies in equipment, and work

orders are written to correct the deficiencies. Each work order is prioritized

to help assure that an equipment problem is corrected in a timely manner to better

assure more reliable and safe operation. Additionally, the frequency of the

inspection and testing is adjusted accordingly to improve the predictive

and preventive maintenance.



Quality assurance is an integral part of mechanical integrity. Throughout

all aspects of this element, the mechanical integrity program provides

appropriate checks and balances to assure that equipment, spare parts,

maintenance materials are installed properly, meet design specifications

and follow manufacturers instructions.





9.0 Hot-Work/Safe Work Permit Practices



Krotz Springs Refinery has many safe work practices in place to safely perform job task in or

near refinery process areas. Issuance of Hot Work Permits is only one of the

many procedures used. Examples of others include:



* Lock, Tag, Try Procedure (S&HG #11) - procedure to provide safeguards or barriers

at those points where unwanted energy flow could result in injury and/or damage.

* Working with Inert Atmospheres (S&H
G #32) - procedure to protect Krotz Springs Refinery and

contractor personnel while working in or near an inert atmosphere.

* Trenching and Excavation Procedure (S&HG #19) - procedure to ensure the safety

of refinery and contract personnel engaged in trenching and excavation work.

* Hot Tapping/In Service Welding (S&HG #7) -- procedure written to ensure that

established safe work practices are used when welding on or cutting into process

lines that are kept in service.

* Refinery Blinding Procedures (S&HG #6) - procedure written to ensure that when

preparing process vessels or piping is removed from service for entry or other

intrusive work, blinds (or blanks) are inserted as part of preparing the

equipment for the work to be performed.

* Safe Work Permit Guideline (S&HG #3) - procedure written to ensure that certain

established safe work practices are used when preparing process equipment for

maintenance activities.



These procedures and others along with proper training of employees and contractors

ensure that operations and maintenance activities are performed safely.





10.0 MOCA



The refinery's written Management of Change Authorization procedure provides a

system to thoroughly evaluate a process change as it relates to chemicals handled or

processed, design or technology employed, equipment use or maintenance, procedures

for operation and changes to ancillary facilities affected by the process.

The procedure as practiced assures that the following are addressed prior to a

change:



* Technical basis

* Actual or potential impact on employee safety and health

* Actual or potential impact on the public and environment

* Effects of temporary changes

* Operating procedure modifications

* Process Safety Information documentation issues

* Employee, contractor notification and training

* Management authorization/approval requirements



All changes (except for "replacement in kind" changes) are routinely evalu
ated as

specified above, and the complexity is also assessed to determine whether a Pre-

Startup Safety Review (PSSR) is required, or if a more in-depth Process Hazards

Analysis (PHA) is appropriate. If a PSSR or a PHA is required, employees are

assigned task(s) to:



* Update process information or maintenance schedules or procedures

* Provide employee and/or contractor training

* Revise operating procedures

* Compose and implement new safety procedures as appropriate, etc.



All of the above actions are be performed before the change is commissioned

through the final PSSR. A PHA, if performed, would identify additional action items

to be addressed, many of which would also have to be addressed prior to start up of

the change in the process.



This procedure assures that all information involved in all elements and aspects of

PSM and RMP are managed and kept current. Through this system, all necessary

documentation is updated, temporary changes are tracked, approvals are obtained and

all responsibilities for each MOCA is assigned to individuals and tracked to

completion.





11.0 Incident Investigation



A written incident investigation and reporting guideline (S&HG #9) has been

developed and implemented by refinery management. This guideline formalizes the

process by which an accident must be reported and can be investigated by employees

(and contractors when appropriate) to determine the direct and contributing

causes of an incident. Both types of causes are used to help formulate corrective

action(s) intended to prevent the possibility of a reoccurrence of the specific

accident or a similar event. These corrective actions are assigned to

appropriate refinery personnel for their follow-up and completion.



Incidents are reported in two different formats depending on the severity of the

occurrence. For all minor and serious incidents, a "First Report of Incident" form

is completed. If the incident is determined to b
e a less than serious occurrence,

one that results in a minor injury, minor equipment damage or minor release/spill,

the completion of this form is sufficient. If the incident is determined to be:



* A serious occurrence,

* One that has the potential to result in a lost work-day case,

* One that resulted or could have resulted in damage to health, environment,

property,

* One that resulted in (or had the potential to result in) a catastrophic

release of a hazardous or regulated substance,



an incident investigation is started within 48 hours. Reports, once finalized,

are publicized to employees, contractors when appropriate, and to other

company locations.





12.0 Emergency Planning and Response



The refinery's programs and capabilities for emergency planning and response

are discussed in detail in a later section of this plan.





13.0 Compliance Audits



It is the company's policy to conduct an audit at least every three years on the

elements of OSHA's PSM standard and EPA's RMP regulation. This will assure that the

procedures and practices developed are adequate and are being followed. Various

employees including hourly and salaried employees participate in the audit by

gathering required documentation, researching requested documentation, verifying

information and participating in interviews. The results of the two most recent

OSHA PSM audits are fully documented and kept on file. The filed documents

include the protocol of the audit and the results of the audit in which all

deficiencies are recorded, assigned to qualified employees and tracked to

completion.









Chemical Specific Prevention Steps



The Accident Prevention Programs described above ensure the safe operations and

management of the chemical hazards. In addition to these programs and procedures,

there are safety systems and equipment installed in the refinery to provide various

levels of safety. The levels of safety include:

1) Prevention
;

2) Quick detection;

3) Containment/control; and

4) Mitigation



Specific safety features used in various processes are described below:



* Release prevention

1. Emergency shutdown systems designed with interlocks and/or trips

2. High/Low alarm systems to manage operating variables such as pressure,

temperature and flow



* Release detection

1. Flammable gas detectors with alarms

2. Fixed and personal hydrogen sulfide detectors with alarms



* Release containment/control

1. Process safety valves that discharge to the flare to safely incinerate

releases

2. Atmospheric relief devices

3. Manual and automatic valves to isolate chemical releases

4. Emergency shutdown systems designed with interlocks and/or trips

5. Curbs and dikes to contain liquid spills

6. Redundancy in some equipment and instrumentation such as electrical

generators, firewater pumps and water sources, pressure relief valves, and

process alarms



* Release mitigation

1. Trained emergency response personnel

2. Deluge systems for specific equipment

3. Scrubber to neutralize ammonia releases

4. Fire suppression provided through the use of fixed monitors, hydrants

and pumper fire truck

5. Personnel protection equipment provided such as fire retardant clothing,

self-contained breathing apparatus, bunker gear, etc.

6. In order to protect personnel while shutting down operations in the

event of an emergency, the control rooms are equipped with breathing air

systems, are pressurized and are equipped with H2S sensors and a

combustible gas detector.









EMERGENCY RESPONSE PROGRAM





1.0 Emergency Response Plan



The refinery has a comprehensive emergency response plan consisting of several

elements which have been written to address the various types of anticipatable

emergencies that might occur at the refinery:

* SHG 1 - Emergency Procedures

* OPA 90 Plan

* SPCC Plan

* RCRA Conting
ency Plan



SHG 1 (Safety & Health Guide) is an employee/refinery safety procedure. These

emergency procedures contain the following information and instructions:

* Notification - A description of how emergencies are reported and personnel

within the refinery as well as the community are notified when appropriate.

* Personnel Muster/Evacuation Procedures - A description of where personnel report

to in a severe emergency for roll checking and potential evacuation as may be

required.

* Emergency Response Team - An overview of the roles/functions of the personnel

designated and trained to respond to refinery emergencies.

* Incident Command Organization - A description of the duties and responsibilities

of the significant individuals and groups that respond to and mitigate an emergency.

* Bomb Threat Procedure - A description of the protocols used in response to a bomb

threat. These protocols have been modeled after the guidance provided by the

United States Federal Bureau of Investigation.

* Hurricane Guidelines - A review of the responsibilities and practices used to

help prepare the refinery for a hurricane.

* Tornado Guidelines - A review of the responsibilities and practices used to help

prepare the refinery for a tornado.

* Oil and Hazardous Substances Contingency Guidelines - Instructions for employees

on reporting and responsibilities in the event of an oil or hazardous substance

release.



In addition to the above discussions and descriptions, SHG 1 has the following

attachments:

* Emergency Telephone Numbers & Notifications

* Emergency Response Team Membership Listing & Organization

* Outside Agencies & Telephone Numbers

* Description of the Refinery Emergency Warning System



The OPA 90 Plan organizes emergency response information and procedures needed

for organizing and executing oil spill response on the Atchafalaya River and

surrounding conveyances that empty into the river. The plan is organized in
to

three main sections - general facility information, the core plan and associated

support information or "annexes" - and provides this information in a format

designed to meet EPA and Coast Guard requirements specified in 40 CFR 112.20

and 33 CFR 154.1010-1065.



The plan describes response objectives and priorities, mobilization and

implementation of response resources including the OSRO (Oil Spill Response

Organization) retained for larger responses and detailed information concerning:

* Facility layout

* Required notifications

* Response management organization and responsibility assignments

* Incident documentation, critique and follow up

* Training & drills

* Prevention

* Required certifications

* Consistency with area and national contingency plans





The SPCC (Spill Prevention, Control and Countermeasure) Plan & Hazardous

Materials Contingency Plan contains all of the elements required by 40 CFR 112.7

(SPCC Plans) and 262.34. Specifically, the present plan contains the following

information:

* General Site & Refinery Operational Description

* Identification of Potential Spill Sites, Drainage and Containment

* Contingency Plan for Spills, Fires or Explosions

* Listing of Emergency Response Equipment

* Evacuation Plan for Refinery Personnel

* Inspection Methods and Procedures for Early Detection of Releases/Spills

* Chemical/Waste Inventory

* Security

* Description of EPA and Louisiana Requirements for Preparation of SPCC Plans



Attachments and addendums to the plan include drawings on the refinery process

areas, drainage patterns, locations of emergency equipment and evacuation routes.

Other information attached includes tank inventories, telephone notification lists,

chemical and waste inventory lists, and checklists used to ensure more consistent

response to refinery oil and hazardous material release emergencies.



All of the above plans have been written to properly coordinate emergency respo
nse

actions to try to assure the protection of refinery personnel, the community and the

environment. Regular emergency planning meetings and drills are held

with appropriate officials of Krotz Springs and the St. Landry Parish Office of

Emergency Planning to determine ways in which coordination, communication and

interactions can be improved.



2.0 Emergency Response Equipment Inspection, Testing & Maintenance



The refinery has a well developed inspection, testing and maintenance program

for all safety systems and emergency response equipment. The program is

described in detail in the Safety Systems Inspection and Testing Manual that

exists on-line in an Impact database. The following table summarizes the

refinery's general inspection frequencies.



EMERGENCY EQUIPMENT/SYSTEMS INSPECTION FREQUENCIES



Safety System Equipment Description Inspection Frequency





Suppression System None Monthly



Foam Systems Fixed & Subsurface Annually



Fire Pumps Jockey, Diesel, Electric Weekly, Annually



Fire Water Tanks Fire Water Storage Tanks Every ten years



Water Systems Fire Hoses Annually

Fire Mains Annually

Post Indicator Valves Annually

Hydrants Annually

Monitors Annually



Sprinkler Systems Deluge Monthly, Quarterly, Annually

Wet Pipe Monthly, Quarterly, Annually,





Foam Types AFFF, Universal Annually



SCBA's SCBA's Monthly, Annually, Hydrostatic

test every 3 or 5 years



In-Line Masks Monthly, Annually

Escape Masks Monthly, Annually



Emergency Vehicles Fire Truck Weekly

Rescue Vehicle Weekly



Emergency Equipment HAZMAT Trailer Weekly

Terminator T-2000 Monthly

Response Boat/Boom Trailer Weekly



Fall Protection Equipment Semi-annually



Eyewashes & Safety Showers Monthly



Portable Gas Testing Equipment Monthly



Fire Extinguis
hers Dry Monthly, Annually

Chemical Monthly, Annually

CO2 Monthly, Annually

Wheeled Monthly, Annually

Halon Monthly, Annually





Specifics of what aspects of each of the above equipment or systems are inspected

are included in checklists designed for each type of equipment. The protocols on

what is examined and checked are based on NFPA or manufacturer recommendations.

These checklists also contain a listing of the types of emergency response

equipment on site. Records of listed inspections are maintained in either

paper files or a electronic database.





3.0 Mutual Aid Participation



The Krotz Springs Refinery participates in BRAMAS (Baton Rouge Area Mutual Aid

System). Due to the more remote location of the refinery, however, close mutual aid

ties have also been made with the Fire and Police Departments of the town of Krotz

Springs as well as other parish emergency response resources through the St. Landry

Parish Office of Emergency Preparedness. Monthly emergency planning meetings are

held with the Mayor, Fire Chief and Police Chief of Krotz Springs. One to two

representatives from the St. Landry Office of Emergency Preparedness also

participate. Through these meetings, well defined communications protocols

between Krotz Springs Refinery and the town and parish have been established. In addition, a

new community alert signal, evacuation and shelter in place protocols have

been put into place.





4.0 Training for All Employees in Relevant Procedures



Employees receive training primarily through regular monthly emergency response

drills composed to simulate conceivable unplanned events that either could or

have happened in the refinery. Through these drills, employees receive

training on reporting of various types of emergencies, responding to plant

alarms, mustering and roll checking, evacuation and sheltering in place.



Emergency response team members participate in m
onthly training sessions and

monthly drills. The monthly training/drills include topics and events which

rehearse the following types of responses, either singularly or in a complex

combination:

* Fire or flammable gas release response

* Medical response

* Rescue/extrication

* Chemical or spill response

* Oil spill response

* Gas testing

* Emergency response organization (incident command system)









Planned Changes to Improve Safety



Future plans to improve safety are developed through several venues including the

Employee Safety Hazard Reporting & Follow Up, the KREST Committee, Process Hazard Analyses,

and the Employee Safety and Health Committee. These safety action items are implemented

through individual employees, employee committees or teams, and are completed through the

use of the work order system, the management of change procedure and the pre-startup safety

procedure. The following types of changes are planned:



1. Continue to train employees in all aspects of their job.

2. Continue to consider and implement recommendations from Process Hazard

Analyses where technologically feasible, and there is a proven benefit to the

safety and/or operations of the process.

3. Continue to consider and implement recommendations from Incident

Investigations where technologically feasible, and there is a proven benefit to

the safety and/or operations of the process.

4. Improve electrical reliability for the entire refinery.

5. Evaluate and Install ESD for additional critical systems.

6. Purchase updated equipment to improve refinery's overall fire fighting capability.