Sour Lake Storage Facility - Executive Summary |
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1.0 ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Motiva Enterprises LLC - Port Arthur Refinery has a long-standing commitment to the safety of workers and the public and protection of the environment. This commitment is expressed in the Company's policy statement: Motiva is committed to protecting the health and safety of employees and others in our workplaces and protecting the environment and public wherever we conduct business activities. We are committed to the belief that all occupational injuries and illnesses are preventable and that serious or fatal injuries resulting from our activities are unacceptable. Each employee has a personal and vital responsibility to contribute to safe work performance. Our objective is to continuously improve our Safety, Health and Environmental performance, and in so doing, to be recognized as a leader in our industry. We will comply with all safety, health, and environmental laws and regulations and will manage performance in the se areas in the same manner as other aspects of our business. In accordance with this policy Motiva will: Assure compliance and continuous improvement using management systems that set targets and report performance. Devote sufficient resources to ensure outstanding Safety, Health and Environmental performance. Design, maintain, and operate facilities to minimize environmental impact, and to protect employees, contractors, and the public from injury and illness. Foster awareness and provide training with the objective of protecting employees, the community, and the environment. Integrate Safety, Health and Environmental processes into line operations, hold all employees accountable for performance and make this performance a key factor in evaluating and rewarding personnel. Emphasize Safety, Health and Environmental performance as a key factor in selecting contractors and require contractors to manage Safety, Health and Environmental matters in accordance with this policy. Rout inely audit Safety, Health and Environmental performance on all our operations to ensure compliance with laws and company policies. Respond quickly and effectively to Safety, Health and Environmental incidents involving our facilities, equipment, and products under our control. Foster constructive dialogue with federal, state, and local governments and communities in analyzing emerging Safety, Health and Environmental issues, finding solutions to problems and developing cost effective, scientifically-based standards and regulations. Require subsidiaries and joint ventures under our control to manage Safety, Health and Environmental performance in line with this policy, and use our influence to promote it in other ventures. Port Arthur Refinery's commitment is demonstrated by the resources invested in accident prevention, such as training of personnel and considering safety in the design, installation, operation, and maintenance of processes. 2.0 DESCRIPTION OF THE STATIONARY SOUR CE AND REGULATED SUBSTANCES The Sour Lake Storage Facility consists of four underground caverns, leached from salt domes, that are used to store excess butanes for the operation of Port Arthur Refinery. These caverns, or wells, have a capacity of approximately two million barrels and contain brine as well as butane. When butane is pumped into a cavern, the brine is displaced and stored in brine pits. When butane is transported to Port Arthur Refinery from the Sour Lake Storage Facility, brine is pumped from the pits into the cavern to displace the butane. The Sour Lake caverns contain flammable hydrocarbons above the EPA RMP threshold quantity. Hydrogen sulfide is also present but in quantities below the EPA RMP threshold quantity. 3.0 HAZARD ASSESSMENT RESULTS The Worst Case Scenario (WCS) associated with the release of flammable substances at Sour Lake Storage is the separation of a four inch diameter butane line at the well-head of a cavern. The result is the release of 75 6,000 pounds of butane to the atmosphere which ignites, resulting in a vapor cloud explosion (VCE). The scenario is expected to have offsite consequences. Although numerous controls are in place to prevent such a release and to manage the consequences, no credit for passive mitigation was taken into account in evaluating this WCS. The Alternative Release Scenario (ARS) for flammables is the over-filling of a cavern with liquid hydrocarbon. This scenario results in all of the brine being displaced; a total of 120,000 pounds of hydrocarbon being released into a brine pit; and the ignition of vapors resulting in a VCE. This scenario is also expected to have offsite consequences. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at Port Arthur Refinery. Because processes at the Sour Lake Storage Facility that are regulated by the EPA RMP regulations are also subject to the OSHA Process Safety Manag ement (PSM) Standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. 4.1 Employee Participation Port Arthur Refinery encourages and incorporates employee participation in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team or incident investigation team. Employees have access to all information created as part of the Refinery accident prevention program. In addition, Port Arthur Refinery incorporates employee participation in The Safety Steering Committee, The PSM Oversight Committee, The Joint Health & Safety Committee, Monthly Safety Meetings, Unit Team Meetings, Task Teams, The Safety Promotions Committee, The Emergency Response Team, and The Contractor Safety Committee. 4.2 Process Safe ty Information Port Arthur Refinery maintains a variety of technical documents that are used to help maintain safe operation of the Sour Lake Storage Facility. These documents address the hazards of the chemicals in the processes, the technology of the processes, and the equipment used in the processes. Standard Procedure H-9.5, Process Safety Information Required for PSM Compliance, outlines the Port Arthur Refinery procedure for developing, updating, and compiling process safety information. Employees and contractors are informed of the location of process safety information that is relevant to their work. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). MSDSs are readily available through Port Arthur Refinery's computer system. Port Arthur Refinery also maintains numerous technical documents that provide information about the design and construction of proces s equipment. 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 processes are not compromised. 4.3 Process Hazard Analysis Port Arthur 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 reasonably foreseeable hazards and ensure that adequate controls are in place to manage these potential hazards. Port Arthur Refinery 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 experience as well as engineering expertise. This team identifies and evaluates potential 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's findings are entered into a computer database (ORBIT) and assigned to appropriate departments 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 process hazard analysis, Port Arthur Refinery periodically updates and rev alidates the hazard and analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are entered into a computer database and assigned to appropriate departments for resolution. Final resolution of the findings is also documented in the database. 4.4 Operating Procedures Port Arthur Refinery maintains Standard Procedure H-11, Operating Procedures and Operator Training, that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) 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 cu rrent and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. Operating procedures are readily available to operators and for other personnel as necessary to safely perform their job tasks. Upper and lower operating limits, consequences of deviation, and steps required to correct or avoid deviation from critical parameters, such as pressure, temperature, level, etc, are included in operating procedures. In addition to Operating Procedures, Port Arthur Refinery has long-standing safe work practices in place 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 sp ark-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. 4.5 Training To complement the written procedures for process operations, Port Arthur Refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery operations if they are not already familiar with such operations. After successfully completing this training, a new operator receives on the job training 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. Skills are maintained through re fresher training. The operating procedures are grouped into modules, and each operator is required to review the assigned modules and pass the prescribed tests over a period of three years. Thus, refresher training is a continuing effort. All operating training is documented for each operator, including the means used to verify that the operator understood the training. 4.6 Contractors Port Arthur Refinery uses contractors for routine maintenance activities, maintenance during shutdown periods, and for construction activities. Port Arthur Refinery also uses contractors for less safety sensitive work, such as security, janitorial, ground maintenance, engineering, clerical, etc. In addition, the Sour Lake Storage Facility is staffed by contractors. Contractors performing the more safety sensitive work dealing with direct maintenance and construction activities are subjected to more stringent safety requirements to assure that they: (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards of the workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Sour Lake Storage Facility personnel of any hazards that they find during their work. This is accomplished by: (1) evaluating the safety programs and performance of prospective contractors, (2) basic safety training of contract employees by approved outside agencies, (3) site specific orientation training of contract employees, (4) prework conference with contractor supervision, (5) providing contractors with process overview information, and (6) monitoring contractor performance to ensure that contractors are fulfilling their safety obligations. 4.7 Pre-Startup Safety Reviews (PSSRs) Port Arthur Refinery conducts a PSSR for any new facility or facility modification that requires a significant change in the process safety information. The purpose of the PSSR is to ens ure 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 requiring verification that accident prevention program requirements are properly implemented. 4.8 Mechanical Integrity Port Arthur 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: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. These procedures are addressed in the following Standard Procedures: H-9, Mechanical Integrity Procedures for Process Equipment, H-9.2, Preventive Maintenance and Critical Alarm & Shutdown Integrity Management (CASIM) Procedures, H-9.3, Spare Parts, Equipment, and Materials Used in Process Areas, and M-4, Positive Identification of Alloy Materials Used to Process, Store, or Handle Hazardous Material. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Applicable written procedures help ensure that work is performed in a consistent manner and provide a basis for traini ng. 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). If a deficiency is identified, employees will correct the deficiency before placing the equipment back in service unless special approval is given to use of the equipment, after it is determined what actions are necessary to ensure the safe operation. Another integral part of the mechanical integrity program is quality assurance. Port Arthur 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. 4.9 Hot Work Permit Port Arthur Refinery utilizes a comprehensive work permit system to safely manage all work performed at the facility. In addition to hot work, the work permit system also includes requirements for entry into confined spaces, as well as requirements for other than hot work. The existing work permit system serves as a framework for all other safe work practices. 4.10 Management of Change Port Arthur 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 operation conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards, and (2) 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 changes. 4.11 Incident Investigation Port Arthur Refi nery promptly investigates 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, develops recommendations to prevent a recurrence, and enters the information into a computer database for tracking. Each recommendation is promptly assigned to an appropriate department for resolution. The final resolution of each finding or recommendation is documented in the database, available for review by all employees and contractors who could be affected by the findings. Incident investigation reports are retained for at least five years so that the reports can be reviewed during future PHAs and PHA revalidations. 4.12 Compliance Audits To help ensure that the accident prevention progra m is functioning properly, audits are periodically conducted to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three years. The audit team develops findings that are forwarded to Port Arthur Refinery's 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 in a computer database, and the two most recent audit reports are retained. 5.0 CHEMICAL SPECIFIC PREVENTION STEPS The Sour Lake Storage Facility has hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA RMP-covered processes at the Sour Lake Storage Facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failu res and (2) human errors. In addition to the accident prevention program activities, the Sour Lake Storage Facility has safety features designed to help (1) quickly detect a release, (2) contain/control a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used at this facility: Release Detection 1. Hydrocarbon detectors with alarms. 2. Facility is manned around the clock. Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases. 2. Remotely activated valves that discharge to a closed flare system for emergency depressuring. 3. Manual and remotely operated emergency shutdown valves to permit isolation of the process. 4. Alarms for specific process parameters (e.g., high/low level, high temperature, etc.). 5. Automated emergency shutdown systems for specific process parameters (e.g., high/low level, high temperature, etc.). 6. Curbing or diking to contain liquid releases. 7. Redundant equipment and instrumentation (e.g., spare process pumps, etc.). Release Mitigation 1. Fire extinguishers. 2. Trained emergency response personnel (e.g., City of Sour Lake, Port Arthur Refinery) 3. Personal protective equipment (e.g., protective clothing). 6.0 FIVE-YEAR ACCIDENT HISTORY The Sour Lake Storage Facility has not had any incidents. Every incident would be carefully investigated to determine ways to prevent similar incidents from occurring. 7.0 EMERGENCY RESPONSE PROGRAM INFORMATION Sour Lake Facility maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including reporting of an emergency, emergency resp onse, first-aid and medical treatment for exposures, evacuation plans, accounting for personnel, notification of local emergency response, and post-incident cleanup and decontamination requirements. In addition, the Sour Lake Storage Facility has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to the facility The overall emergency response program at the Sour Lake Storage Facility is coordinated with the Local Emergency Planning Committee (LEPC) of Hardin County. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local governmental officials, and industry representatives. Port Arthur Refinery has aroun d-the-clock communications capability with appropriate LEPC officials, who have direct communications with local police and fire departments. Hardin County has an Emergency Alert System (EAS) in place which provides residents with instructions as to what to do in the event of an emergency. The EAS provides a means of notifying the public of an incident if necessary, as well as facilitating quick response. In addition to periodic LEPC meetings, Port Arthur Refinery conducts periodic emergency drills that involve the LEPC, as well as, local emergency response organizations. 8.0 PLANNED CHANGES TO IMPROVE SAFETY Port Arthur Refinery is committed to continuous improvement in all phases of operation. PHAs and incident investigations are conducted by experienced participants and all findings are tracked to completion. Training of operating personnel, who are usually the first line of defense in the prevention of incidents, is continuous. In addition, Port Arthur Refinery has long-sta nding established programs in mechanical integrity, process safety information, and management of change. All programs are reviewed and updated as needed to ensure the safe operation of the Sour Lake Storage Facility. Port Arthur Refinery has a core group of incident investigation team leaders trained in root cause investigation techniques. The team leaders guide investigations to determine causes of incidents with the aim of continuous improvement and prevention. Port Arthur Refinery has also agreed to participate in the Triangle of Prevention Program (TOP) which is sponsored by the Paper, Allied-Industrial Chemical and Energy Workers (PACE) International Union (formerly OCAW). This program is designed to go well beyond the achievements of current industry or government regulations in maximizing prevention. In addition, the following types of changes are either planned or have already been implemented: Revised process instrumentation and/or controls Hydrocarbon release detecti on systems in some areas Additional pressure relief devices on some pieces of equipment Additional and/or revised shutdown systems Revised safe work practices Revised written operating procedures Additional training on specific topics |