CASE STUDY

BOS 3640 Unit VII Case Study

Question #1. Discuss the hazards posed by the interaction of the hazardous materials present at the refinery and adjacent facilities, including the resulting by-products of the incident fire and acid gas release.

Petroleum hydrocarbons naturally occur in crude oil. When these products are released into the atmosphere through leaks, spills, or fire, for example, physical, chemical, and biological changes take place. Aliphatic hydrocarbons found in crude oil are naturally unreactive, however combined with oxidizing agents such as nitric acid, oxygen, and heat, they can generate an extremely hot fire and produce carbon dioxide and water .

Crude oil also contains sulfur. When sulfur burns, it produces sulfur dioxide. Sulfur dioxide, according to NIOSH, at 400 to 500 ppm is considered dangerous for even short periods of exposure (CDC, 2011). In addition, sulfur dioxide reacts with water to form sulfurous acid (H2SO3). Sulfurous Acid (H2SO3) is a strong corrosive and causes burns through all entry points and is included in OSHA’s List of Highly Hazardous Chemicals .

The principal fuel products of the refinery are naphtha, gasoline, kerosene, and diesel. The most significant danger is fire. When the vapor of any of the products reaches or is near their flashpoint, and the ambient temperature is within range, they can ignite and cause fire or explosion.

A commonly recycled plastic is polyethylene terephthalate (PETE). Polyethylene is combustible when exposed to an ignition source it produces “voluminous amounts of smoke, carbon monoxide, and other hazardous gases, vapors, and fumes” including “hydrogen chloride, ammonia, hydrogen cyanide, sulfur dioxide, and nitrogen dioxide .”

Acid gases can be carried great distances affecting nearby residential areas. Sulfur gases are especially critical. Sulfuric acid droplets can form in the air when sulfur dioxide is released from the burning of coal, oil, and gas . Again, as stated earlier, sulfuric acid is very corrosive and can cause irritation of the eyes, respiratory tract, skin, and gastrointestinal tract. Sulfuric acid is also linked to larynx, paranasal sinus, and lung cancer.

Chemical reactions where high temperatures cause decomposition, can produce powerful explosions . Shrapnel from these explosions can travel long distances into the adjacent neighborhoods and nearby traffic causing serious injury and deaths. In addition, shrapnel can pierce storage tanks, towers, and reactors causing them to leak triggering even more reactive conditions.

Question #2. As the lead refinery representative on the unified incident command (UIC), what actions should be taken by the UIC to respond to this incident (please consider all receptors).

Emergency Responders need to be fully prepared for toxic chemical releases. The incident commander should understand the reactive nature of the chemicals involved at the incident scene. OSHA defines the unified incident command (UIC) as, “a structure that brings together the ‘Incident Commanders’ of all major organizations involved in the incident in order to coordinate an effective response while at the same time carrying out their own jurisdictional responsibilities .” As the lead refinery representative, one is responsible for the safety of all responders, while minimizing the impact of the incident on the surrounding areas, and protecting the environment and property while still achieving the objectives of the incident response. The first in the initial response is to notify the proper authorities. In the instance of the case study, the IC must notify the National Response Center immediately when hazardous materials are discharged into the environment and when any oil spill has taken place. After the proper authorities have been notified it is the responsibility of the commander to establish command and the organization’s structure. From that point, an initial assessment needs to conducted, which includes:

· “verifying vital information about the incident;

· ensuring that the incident scene is secure;

· conducting an assessment of the incident situation, actions taken, safety concerns, incident worst-case potential, and resources required; and

· Establishing an appropriate IMS structure .”

Once the initial assessment has been conducted, a response is implemented. The global oil and gas industry association for environmental and social issues published guidelines on incident management and emergency response personnel. It provides guidelines on oil spill preparedness and response topics .

Question 3. If the polymerization unit is engulfed in the fire, how will this affect your response?

There are several hazards associated with responding to a polymer fire. Polymer fires are extremely hot and produce thick, black, gaseous smoke. Gas vapors including hydrogen cyanide and nitrogen dioxide produce an inhalation hazard. Fire fighters can quickly suffer asphyxiation from inhaling hydrogen cyanide. The OSHA permissible exposure limit (PEL) for hydrogen cyanide is 10 ppm as an 8‑hour time-weighted average (TWA) concentration . At levels <1000ppm symptoms can occur after only 15 minutes of exposure and is fatal . Therefore the use of respiratory equipment is extremely important when responding to hydrogen cyanide and other poisonous gas fires. “Occupational Safety and Health Administration regulations (see 29 CFR 1910.1000) require the use of a full-face piece, pressure demand self-contained breathing apparatus (SCBA) meeting the requirement of the National Fire Protection Association Standard 1981 (see rules for Open-Circuit Self-Contained Breathing Apparatus for Fire Fighters available at http://www.nfpa.org) when entering structures in firefighting efforts .”

Chemicals that are used in polymerization can undergo spontaneous polymerization when exposed to extreme heat or water. Heat from nearby fires, for example, can heat containers causing run-a-way reactions that lead to breaches and explosions. Precautions must be made to keep first responders safe from possible explosions and additional chemical releases.

Water reacts with some chemicals to cause a violent reaction. . For example, potassium phosphide release phosphine gas when it comes in contact with water. Before fire fighters go in and start dousing everything with water, thorough assessment, with the help of a HAZMAT team should be done to determine what the best method of securing the scene and extinguishing the fires.

Question 3. All emergency responders participated in the post-incident critique. What corrective actions should be implemented by the refinery to prevent the reoccurrence of this incident?

Communication, education, and awareness are essential for preventing incidents and accidents. According to a study done by the U.S. Chemical Safety Board (CSB), 90% of the accidents in the study contained information on the hazards were obtainable from publicly available literature . The board recommended that to better understand reactive hazards, and their processes, companies should consult multiple sources of information. The American Chemistry Council (ACC) has many resources available to companies to aid in this process. In 1989, ACC developed the Responsible Care Process Safety Code 60 to prevent fires, explosions, and accidental chemical releases .

The author found several deficiencies in the management of the turnaround including incompleteness and lack of documentation, lack of communication and training, engineering failures, scheduling errors, and failure to comply with OSHA regulations including emergency response and management plans, improper containment, and missing SDS.

Many of the problems outlined in the case study are the result of deficient education and awareness. For example, “a shift turnover for the night contractor crew did not happen due to mandatory safety training that delayed their arrival at the worksite.” In this example, starting and stopping points where not communicated. Supervisors are responsible for proper turnovers regardless of what else is scheduled for the day. All key areas of the turnaround should be represented. Ideally, you want all involved to be on the same page including the plant’s administrative personnel, operations, maintenance, quality assurance, and safety and health. Again, communication is central to a successful turnaround. A sloppily planned, as illustrated in the case study, turnaround can be disastrous. This can be illustrated by the scheduled 12-hour shifts, 24 hours a day work load. Clearly manpower was not thought out and the result was the overextension of manpower. A better solution may have been to hire more workers or to split shifts.

In addition to procedural and scheduling conflicts, the author found outdated and inadequate safety procedures, including the lack of back-up plans. Safety guidelines are important and play a significant role in the planning and scheduling of a turnaround. OSHA requires a safety plan be in place and offers recommendations on completing them. According to the OSHA, “An employer must have an emergency action plan whenever an OSHA standard in this part requires one. The requirements in this section apply to each such emergency action plan .” SJV Refinery is a refinery that processes crude oil. CFR 29 CFR 1926.64 applies to Process safety management of highly hazardous chemicals and is designed to prevent or minimize the effects of releases of toxic, reactive, flammable, or explosive chemicals. In addition to OSHA standards, it is recommended that the organizations go beyond the recommendations of OSHA and develop an individual plan that addresses all current and all foreseeable abnormal conditions .

Once you break a line, as illustrated in the case study, you have to have a form of retrieval. The author also recommends that engineering controls be designed such as retrieval and defense systems to avoid leaks, and injury.