Pennzoil-Quaker State Company Shreveport Refinery - Executive Summary |
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19971 LDEQ Facility ID Number - Accidental Release Prevention and Response Policy The Pennzoil-Quaker State Company Shreveport Refinery has a history of commitment to public and employee safety. Our commitment shows in the resources invested in accident prevention such as safety and operations training for our personnel, incident investigations, and the standards for design, installation, operation and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. To integrate environmental, safety and health management into business activities worldwide, Pennzoil-Quaker State Company will: * Pursue excellence in the design, construction, operation and restoration of all properties and facilities; * Assess the potential risks of business activities; * Be a responsible steward of all products and services;* Comply with all applicable laws and regulations; * Prepare for emergencies and other contingencies; * Participate in the development of new laws, regulations and technologies; * Communicate openly regarding business activities; * Review performance and communicate progress; and * Assign clear responsibilities to all employees and contractors * Expect continuous improvement. * Provide employees with resources and training to meet assigned responsibilities. General Description The Pennzoil-Quaker State Company Shreveport Refinery has been a member of the Shreveport corporate community since 1923. The Shreveport Refinery is Louisiana's oldest refinery, stretching across 240 acres in west Shreveport, with a processing capability of 50,000 barrels per day of crude oil. The facility consists of processing units, a tank farm, loading facilities, a maintenance department, office buildings, and a warehouse. The refinery manufactures fuels, lubricants, refined waxes and speciality products. The major hazards at the facility are fire or explosion from various forms of hydrocarbons includ ing Liquefied Petroleum Gas (LPG). The refinery employs 344 people in and around the Shreveport area. Regulated Substances The Risk Management Program rule requires companies that use certain (threshold) quantities of toxic and flammable chemicals to develop scenarios that estimate the potential community impact from an accidental release. The following summarizes how these rules apply to the Pennzoil-Quaker State Company Shreveport Refinery: Toxic Chemicals The refinery does not have any Risk Management Program (RMP) regulated toxic chemicals over the reporting thresholds. Hydrogen sulfide, a toxic gas, is present in the refinery at quantities below the threshold. Sulfur compounds, which may become hydrogen sulfide in the refining process, are a naturally occurring part of crude oil. Flammable Substances The refinery has five flammables above the threshold quantity of 10,000 pounds. These are: * Propane * Butane * Isobutan e * Pentane * Propylene General Accidental Release Prevention Program Our Plant Manager has the overall responsibility for ensuring that our facility operates in a safe and reliable manner. This responsibility includes overseeing the implementation of the elements of our risk management program. To ensure that our risk management program is appropriately developed and implemented, our Plant Manager has designated a Process Safety Management/Risk Management Program (PSM/RMP) Coordinator with the necessary background, training, and experience. The PSM/RMP Coordinator has the responsibility for the development, implementation, and integration of the Environmental Protection Agency (EPA) RMP elements and the elements of Occupational Safety and Health Administration's (OSHA's) PSM program (where applicable) as required under Section 68.15 of the RMP rule. The PSM/RMP Coordinator serves as the chairman of the facility's Safe Operating Committee (SOC). This co mmittee includes members with responsibilities for developing and managing specific elements of our risk management and process safety programs. Currently, the members of the Safe Operating Committee include the following: 7 PSM/RMP Coordinator 7 Plant Manager 7 Director of Optimization 7 Director of Safety and Reliability 7 Lubes Business Manager 7 Fuels Business Manager 7 Human Resources Manager 7 Safety Manager 7 Employee Representatives The following sections identify the specific responsibilities for each aspect of our risk management and process safety management programs. Hazard Assessment The Director of Optimization has the responsibility for: (1) ensuring that offsite consequence analysis for each regulated process are consistently performed and documented in accordance with Sections 68.20 through 68.39 and (2) selecting the scenarios that will be reported in the facility RMPlan as required under Section 68.165. Preventive Programs The PSM/RMP Coordinator has the responsibility for ensuring that the facility has an integrated, effective, and compliant prevention program that meets EPA RMP (Sections 68.65 through 68.87 of the RMP rule) and OSHA PSM requirements. Although the PSM/RMP Coordinator has some specific individual responsibilities, many of the responsibilities for specific program elements are assigned to other members of the Safe Operating Committee (as listed in the following sections). Process Safety Information The responsibility for process safety information (PSI) (Section 68.65 of the RMP rule) is divided into three areas. The Safety Manager has responsibility for process chemical information, the Director of Optimization has responsibility for process technology information and the Director of Safety and Reliability has responsibility for equipment information. The PSM/RMP Coordinator has the responsibility of ensuring that all of this information is readily acce ssible for use. Process Hazard Analysis In accordance with Section 68.67 of the RMP rule, the PSM/RMP Coordinator has the responsibility for ensuring that process hazard analyses (PHAs) are scheduled, conducted, and documented by trained personnel for all regulated processes. PHA team leaders from within the facility receive appropriate training before leading PHAs. Outside contractors may lead PHAs when appropriate. The other members of the Safe Operating Committee are responsible for: (1) ensuring that the information and personnel necessary to conduct PHAs are available according to the PHA implementation schedule and (2) resolving recommendations that are assigned to their respective areas. Operating Procedures In accordance with Section 68.69 of the RMP rule, the Fuels and Lubes (Operations) Business Managers have the responsibility for ensuring that complete and accurate operating procedures are in place for all regulated processes. The Operations Business Manage rs work closely with the PSM/RMP Coordinator and process specialists to develop and maintain the facility's safe work practices (start-up, emergency shutdown, normal shutdown, normal operating, temporary operations and initial start-up of a new process). All controlled procedures are stored in the plant's electronic document control system. Training In accordance with Section 68.71 of the RMP rule, the Operations Business Managers and the Director of Optimization have the responsibility for: (1) ensuring that operations employees receive and understand training applicable to their specific jobs and the associated processes, (2) at least every 3 years, all operators in the same job receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level, and (3) documenting the training. The Director of Safety and Reliability has the responsibility for: (1) ensuring that all facility employees receive and understand training in safe work practices applicable to their jobs and (2) addressing and documenting training for maintenance workers under the mechanical integrity program. Mechanical Integrity In accordance with Section 68.73 of the RMP rule, the Director of Safety and Reliability has the responsibility for developing the mechanical integrity program with specific emphasis on written procedures, equipment and instrumentation inspection/test programs and documentation, and equipment deficiency resolution. The Director of Safety and Reliability has the responsibility for implementing the mechanical integrity program and maintenance training. The Materials Manager works with the Maintenance/Reliability Manager to insure that appropriate quality assurance procedures are followed for all types of equipment acquisitions, installations and repairs. Management of Change In accordance with Section 68.75 of the RMP rule, the PSM/RMP Coordinator has the responsibility for the overall man agement of change (MOC) program; however, the Director of Optimization, the Director of Safety and Reliability, and the Operations Business Managers have responsibility for ensuring that the overall MOC program is effectively implemented in their areas. Pre-Startup Review In accordance with Section 68.77 of the RMP rule, the PSM/RMP Coordinator has the responsibility for the overall pre-startup review program, which is closely related to the MOC program. However, the Operations Business Managers have the primary responsibility for ensuring that this program is effectively implemented before affected operations begin. Compliance Audits In accordance with Section 68.79 of the RMP rule, the PSM/RMP Coordinator has the responsibility for ensuring that compliance audits occur at least every three years and are documented to verify that the prevention program is working and meets EPA/OSHA requirements. Members of the Safe Operating Committee have responsibility for resolving any identified deficiency in their area. Incident Investigation In accordance with Section 68.81 of the RMP rule, the Safety Manager has the responsibility for designing and managing the incident investigation program, including tracking resolution of investigation findings and recommendations. The Safety Manager also has the responsibility of ensuring that only trained personnel lead our investigations. Each department manager has responsibility for ensuring that all incidents in their areas are reported and investigated and the investigation findings are resolved, documented, and communicated to the affected personnel. Employee Participation In accordance with Section 68.83 of the RMP rule, the PSM/RMP Coordinator, working with the employee representatives on the Safe Operating Committee, has the responsibility of involving employees in the planning and implementation of the facility's prevention program elements. Hot Work Permits In accordance with Section 68.85 of t he RMP rule, the Safety Manager, working closely with the Operations Business Managers and Maintenance/Reliability Manager, has the responsibility of developing and maintaining the facility's hot work permit program. Contractors In accordance with Section 68.87 of the RMP rule, the Director of Safety and Reliability has the overall responsibility for the contractor program; however, the Maintenance/Reliability Manager and the Materials Manager are responsible for ensuring that the requirements of the program are implemented. Chemical-Specific Prevention Steps In addition to our accident prevention program we have safety features on many units that help to quickly detect a release, contain and control a release and reduce the consequences of (mitigate) a release. We have the following types of safety features in various processes: Release Detection 7 Hydrocarbon detectors with alarms 7 Hydrogen Sulfide detectors with alarms 7 Fire detection with alarms 7 Smoke detectors and alarms 7 Routine visual inspections Release Containment/Control 7 Process relief valves that discharge to a flare to capture and incinerate episodic releases 7 Scrubbers to neutralize chemical releases 7 Manual or automatic valves that permit process isolation 7 Automatic shutdown systems, normal operating and emergency shutdown procedures for units 7 Vessels that permit partial removal of the process inventory in event of a release 7 Curbing or diking to contain liquid releases 7 Redundant equipment and instrumentation 7 Uninterrupted power supplies and backup firewater pumps 7 Process Hazard Analysis of all units 7 Preventive/Predictive Maintenance Program 7 24 hour monitoring of all processing units. Release Mitigation 7 Deluge systems and automatic fire suppression systems for specific equipment 7 Personal Protective Equipment 7 Fire fighting equipment such as a foam pumper and dry chemical truck Five Year Accident History Pennzoil-Quake r State Company Shreveport Refinery has a good accident prevention record . We have not had a release of any RMP regulated substance that caused an injury in the refinery or has gone off site in the past five years. We investigate all releases as part of our ongoing accident prevention program. Emergency Response Program Pennzoil-Quaker State Company Shreveport Refinery has an Integrated Emergency Response Plan. This means that we work with internal and external groups in responding to emergencies. Our 65 fire brigade members volunteer to serve the refinery and surrounding community in fire prevention and suppression. They receive training at Shreveport Fire Academy with the Shreveport Fire Department, Louisiana State University, Texas A & M, and the Northeast Texas Fire School. The Shreveport Fire Department comes in the refinery several times a year to tour the operating units, participate in emergency drill exercises and preplan emergency operations. Our emergency re sponse plans are coordinated with the Caddo LEPC, the Caddo/Bossier Office of Emergency Preparedness, the Shreveport Fire and Police Departments. We have 24-hour communications capability with those organizations. In addition, we subscribe to the First Call Network for quickly notifying our community with any necessary emergency information. Key Offsite Consequence Analysis Scenarios Worse Case Scenario A worst case scenario is defined by EPA, as the rapid and complete release of the largest container of the chemical under conditions that would maximize its potential impact. It also assumes that none of the site's mechanical controls or safety systems requiring energy or human intervention are operational. The EPA definition requires us to develop a scenario that is actually a series of highly unlikely events, each one reaching its end point before it is followed by the next unlikely event, until the worst case scenario results. A worst case scenario is extremely unlikely to occur. Under this definition, catastrophic failure of our largest storage tank of liquefied petroleum gas would be our Worst Case Release of a regulated flammable substance. Our largest affected tank is a butane sphere tank that can contain up to 2,081,235 pounds of butane. In the scenario, the tank fails and releases the entire contents in a 10-minute period and then ignites. We estimate, using EPA guidelines and certain weather conditions, that the resulting vapor cloud explosion could have a pressure wave of over 1 pound per square inch for a distance of about one mile. We believe that an event of this type is extremely unlikely because of the preventive controls that are in place and the very low probability that a catastrophic release of the entire tank's contents could occur. Alternate Release Scenario (A More Realistic Scenario) EPA also requires that an alternate release scenario be prepared giving a more realistic scenario. The scenario can take into account prev ention and response schemes at the facility, but must still have a potential for off-site impact. We selected a loading line failure during a butane truck delivery for the required alternate release scenario. In this scenario, the truck begins the unloading process into the refinery butane storage tank when the loading line ruptures completely. Should there be a release from the truck loading line, the loading rack check valves stop the flow of butane from plant storage. The truck could continue to offload until it is manually shut off at the truck valve. Liquid butane would continue to flow from the truck at a rate of about 1,000 pounds per minute and may form a butane cloud. We feel confident that we could shut the truck down within five minutes using permanent mitigation equipment in the loading area, resulting in a cloud of about 5,000 pounds. Should the butane ignite and explode or burn we estimate a pressure wave of over one pound per square inch would go about 317 feet usin g EPA calculation methods. Mitigation equipment in the area consists of firewater monitors, hydrocarbon alarms, and multiple shut down stations in the loading area capable of shutting in the entire loading dock system. Drivers are required to watch trucks loading or unloading at all times and our trained emergency response personnel would immediately respond to the incident. Further, we inspect loading lines regularly to detect wear or damage and replace them as needed to preclude releases such as those described here. In the event of a release, we would activate our Emergency Operating Procedure and notify local agencies and emergency responders. Our Emergency Operation Center would notify our neighbors to shelter in place or evacuate through the First Call Network. Recent Safety Improvements The following is a list of key improvements the facility has or is committed to implementing: In 1998, we installed a new 3,000-gpm Diesel firewater pump and 25,000-bbl water storage tank to supplement our fire protection system. An additional jockey pump was installed that uses our wastewater discharge to maintain minimum pressure and volume in our firewater system. We have recently restructured our safe work policy and permits and updated the operation training manuals. Plans are being developed to install foam chambers on gasoline, kerosine, and naphtha storage tanks. Plans are also in the developmental stages to install a deluge system to the Light Straight Run spheres. |