Motiva Enterprises LLC - Delaware City Refinery - Executive Summary |
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Motiva Enterprises LLC 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. Our objective is to continuously improve our safety, health and environmental performance. The Company operates, maintains and designs improvements to the Delaware City Refinery to minimize environmental impact and to protect employees, contractors, and the public from injury and illness. Safety, health, and environmental performance is a key factor in selecting and periodically evaluating contractors. The Company routinely audits safety, health, and environmental performance to assure compliance and improvement. The Company is prepared to respond quickly and effectively to any incidents involving the refinery, its equipment or products under its control. The Refinery has had an active process safety management (PSM) program since 1989. Motiva Enterprises has held local public meetings to discuss the Risk Management Plan (RMP) program and the related refinery safety programs. The Company has also led or participated in Chemical Industry Council and Local Emergency Planning Committee (LEPC) public meetings to explain the RMP program and accidental release prevention policies and preparedness practices. The Delaware City Refinery is a complex facility consisting of 13 operating process areas. Each area has its own staff, control system, operator building, and process specific procedures. Some of these areas do not require Risk Management Plan (RMP) registration since they do not contain sufficient quantities of regulated toxic or flammable substances. However, refinery policy requires each operating area to be included in the activities for PSM release prevention and emergency response. The refinery is designed and operated to process crude oil into fuels including propane, butane, gasoline, home heating oil and diesel fuel. The process units may use heat, pr essure or catalyst to separate and recombine the chemicals in crude oil to produce components for the fuel products. Anhydrous ammonia is the only toxic material regulated by RMP that is stored in the refinery. Hydrogen sulfide is present in several processes but is not stored and does not exist in sufficient quantity for EPA or OSHA regulation coverage. Hydrogen sulfide is registered with the Delaware state RMP program. There are four process areas that lack sufficient quantities of RMP listed hazardous materials to be included in this filing but may require registration with the Delaware state RMP program. These areas are designed, operated, and maintained in the same manner as the EPA RMP Program Level 1 and 3 process areas. Process areas not requiring registration in the EPA RMP program are the Crude Unit, Fluid Coker, Stack Gas Scrubber, and Sulfur Recovery. There are two Program Level 1 process areas. These are the Low Pressure Reformer and the Naphtha Fractionation & Tet ra Area. There are seven Program Level 3 process areas. These are Utilities Area, Blending Storage, Hydrocracker & Hydrogen, Poly & Alkylation Units, Desulfurizer & Ether Units, Catalytic Cracking & Gas Plant, and the Chemical Complex. The Utilities Area contains intermediate product storage, piping between process areas, flare system, fire water system, and anhydrous ammonia storage. The anhydrous ammonia is stored as a liquid in a pressure tank and piped to a process unit. The tank has a level indicator, dual pressure relief valves and is protected from damage by barricades. Fire water monitors and hoses in the area can be used to control ammonia gas from leaving the site if a leak were to occur. Operators and refinery emergency responders are trained to use self contained breathing apparatus when responding to an ammonia release. The ammonia tank inventory is administratively limited to 65,000 pounds. The highly unlikely worst case is the release of 65,000 pounds of anhydro us ammonia in 10 minutes through a large pipe or vessel break. The EPA RMP*Comp program calculates a narrow elliptical cloud of potentially hazardous ammonia concentration reaching 3.8 miles downwind from the tank. Depending on wind direction, this unlikely release could reach the residential areas of Delaware City, St. Georges, Kirkwood, Bear, Red Lion, Glendale, Springfields, Bear Crossing, Bear Landing, Pigeon Run, Meadow Knoll, Rutledge, Monterey Farms, Kingston Acres, Moores Acres, Glasgow Pines, Garwood Estates, Tolham Estates, Country Woods, Smith Lane, Emerald Ridge, Red Lion Terrace, Lauren Farms, Porter Station, Sylvan Park, Oakwood, Chandeleur Woods, Caravel Hunt, Fieldstone Crossing, Hunters Run, York Farms, Knightsbridge Estates, Harbor Estates, Countryside Farms, Williamsburg, Rolling Meadows, Corbit Glen, Wrangle Hill, Birds Corner, Dragon Run Terrace, or Gams Crest. The release might also reach Eden Square Shopping Center, Fort Delaware, Fort DuPont and Ommelanden Pa rks, Chesapeake and Delaware Canal Wildlife Area, Gunning Bedford Middle School, Commodore MacDonough Elementary School, Delaware City Elementary School, May B. Leasure Elementary School, National Guard Training Station, or Governor Bacon Health Center. The nearby industrial facilities of Oxychem, Air Products & Chemicals, Kaneka Delaware, Formosa Plastics, Air Liquide America, Chloramone, Metachem Products, or VPI Mirrex could also be affected. The alternative release scenario for anhydrous ammonia is the shearing of the 2 inch pipe used to unload ammonia from trucks into the storage tank. The release rate of flashing ammonia liquid was calculated to be 660 pounds per minute. RMP*Comp shows that a hazardous concentration of ammonia could reach 0.43 miles downwind. The hazardous concentration from this release will not reach any residences or other public receptors. The Blending Storage area contains tanks of crude oil, blending component oils and finished petroleum products. Propane and butane are stored here as liquids under pressure. Propane is also stored in a special refrigerated in-ground tank with its own pressure relief system and flare. These tanks are instrumented with temperature indicators and with level indicators and alarms. Their safety systems include pressure relief valves. The above ground propane and butane tanks have remotely operated shutoff valves and water spray deluge systems. The unlikely worst case would be the release of a full 500,000 gallon butane tank as a vapor which ignites. RMP*Comp calculates that this explosion could cause a 1 pound per square inch (psi) overpressure out to 1.1 miles in all directions from the tank. The industrial facilities of Kaneka Delaware, Oxychem, Air Products & Chemicals, Air Liquide America, Chloramone, Metachem Products and VPI Mirrex are within this circle. There are no residences or other public receptors in the area. The alternative release scenario is a pipe failure releasing 20,000 pounds of butane. The ignition of this release could reach 360 feet with a 1 psi overpressure. No public receptors would be affected by the 1 psi overpressure. The Hydrocracker and Hydrogen area includes a process for converting high sulfur gas oil into heating oil and gasoline and a process for producing purified hydrogen. The Hydrocracker is a high pressure process with alarms on all critical operating parameters and the capability to safely depressure the process to the flare system in an emergency. The worst case release would be the autoignition of 16,000 pounds of hydrogen from the reactor system. The 1 psi overpressure area could reach 0.3 miles. The Air Liquide America industrial site is the only public receptor in this range. The alternative release scenario is the failure of a pipe releasing 5600 pounds of hydrogen. Mitigation includes emergency depressuring to the flare system. The affected area could be up to 0.2 miles for a 1 psi overpressure. There are no publi c receptors in this area. The Polymerization (Poly) and Alkylation Units combine light gases into gasoline blending components by the use of catalysts. The flammable worst case release scenario is the unlikely emptying of a full feed tank containing 2,200,000 pounds of isobutane. The RMP*Comp program calculates a 1 psi overpressure up to one mile away. Public receptors in this area include the industrial facilities of Formosa Plastics, VPI Mirrex, Air Liquide America, Air Products and Chemicals, Metachem Products, Kaneka Delaware, and Oxychem. There are baseball fields within the area but no residences. The tank is inspected regularly and is instrumented with emergency pressure relief valves, pressure indicator and alarm, temperature indicator and alarm, and liquid level indicator and alarm. The alternative release scenario is the failure of a pipe releasing 24,700 pounds of isobutane. The affected area could be up to 0.1miles for a 1 psi overpressure. There are no public recep tors in this area. The Desulfurizer and Ether Units use heat and catalyst to promote desirable chemical reactions. Five Desulfurizer Units remove sulfur from raw gasoline, kerosene, and light fuel oils. The Ether Unit produces the oxygenate gasoline components of methyl tert-butyl ether (MTBE) and tertiary amyl methyl ether (TAME) for use in EPA mandated gasoline formulations. The flammable worst case release scenario is the release of 200,000 pounds of pentane from the TAME fractionation section which, upon ignition, may cause a 1 psi overpressure to extend 0.5 miles. The Air Liquide America industrial facility is the only public receptor in the potential overpressure area. The alternative release scenario of 53,000 pounds calculates to less than 0.1 miles to the lower flammability limit. There are no public receptors in the potentially affected area. The Catalytic Cracker and Gas Plant uses a catalyst to break gas oils down into fuel oil, gasoline and light gases. The Gas Pla nt removes sulfur from light gases from many refinery processes and produces fuel gas for process heating and the power plant. The flammable worst case release would be 215,000 pounds of mixed light gases, primarily butane, which could produce a 1 psi overpressure to a distance of 0.5 miles. The only public receptor in this area is the Air Liquide America industrial facility. This butane release scenario is much smaller than that from the Blending Storage butane tank. The alternative release scenario of 73,000 pounds could produce a 1 psi overpressure to a distance of 0.2 miles. There are no public receptors in this area. The Chemical Complex consists of a heavy Olefins Fractionation Unit, a heavy gasoline hydrogenation unit or SHU, and a Methanol Unit. There are no EPA RMP regulated materials in the Olefins Fractionation Unit. Hydrogen is used in the SHU but a sufficient quantity is not present for regulatory purposes. The Methanol Unit produces syngas (hydrogen and carbon mon oxide) from natural gas and other refinery streams. The syngas is used to make methanol and hydrogen gas. The worst case release scenario is the release of 14,000 pounds of hydrogen rich gas that could cause a 1 psi overpressure up to 0.3 miles away. The Air Liquide America industrial site is on the outer edge of this area. There are no other public receptors for the Chemical Complex worst case scenario. The alternative release scenario of 2400 pounds could produce a 1 psi overpressure to a distance of 0.1 miles. There are no public receptors in this area. The Low Pressure Reformer uses a catalyst at high temperature to rearrange desulfurized naphtha molecules into high octane material. Hydrogen is a byproduct of the reforming reaction and is piped to other refinery processes. The flammable worst case release scenario is 12,000 pounds of propane from a distillation system. Ignition of this vapor cloud could cause a 1 psi overpressure up to 0.2 miles away. There are no public receptors within this area. The process was started in 1983. It has never had an incident meeting RMP reporting requirements and qualifies as a Program Level 1 process. The Naphtha Fractionation and Tetra Unit separates reformed naphtha into blending components and benzene using heat and solvent extraction. The worst case release scenario is 25,000 pounds of pentane from a distillation system. RMP*Comp calculates a 1 psi overpressure to 0.2 miles. There are no public receptors within this area. There have not been any incidents meeting RMP reporting requirements in the past five years. The Naphtha Fractionation and Tetra Unit qualifies as a Program Level 1 process. The Delaware City Refinery has complied with Delaware's Extremely Hazardous Risk Management Act since its promulgation in 1989 and the OSHA Process Safety Management regulation 29 CFR 1910.119 of 1992. The Refinery keeps updated process safety information including equipment data, piping and instrument drawings, and material safety data sheets (MSDS). The process equipment is regularly inspected and maintained. Each inspection is compared with previous ones and to applicable company and industry standards to help plan maintenance and prevent accidental releases from equipment failure. Operating procedures are updated as needed and reviewed annually. Operators receive thorough training to qualify for each position they work. Operator skills are maintained through documented refresher training every 3 years. An initial process hazard analysis (PHA) study was done for each process unit. Revalidation PHA studies are done every 5 years. Recommendations from the PHA studies are tracked to their resolution. The Refinery performs a self audit of process safety management compliance every 3 years. The Motiva Enterprises parent companies and Delaware's Accidental Release Prevention group have also made periodic PSM inspections. The refinery looks forward to these inspections as a way to continual ly improve the activities and documentation that can help prevent incidents and accidental releases. The Delaware City Refinery has had one PSM incident in the past five years. The incident occurred in 1997 when a gas containing hydrogen backpressured into a process solution storage tank during the Hydrogen Unit shutdown procedure. The hydrogen ignited in the nearly empty tank, ripping its floor seam and releasing the solution. A contractor employee was injured while trying to run from the scene. The vapor release did not leave the process area. As a result of the incident investigation, the shutdown procedure was improved and the piping and replacement tank were modified to prevent similar incidents. The first line of emergency response in the Refinery is the process operators. They have been trained in emergency operation and shutdown procedures. Most of the operators have also had firefighting training at the refinery fire fighting training facility or Delaware Fire School . The Refinery has trained emergency response teams for firefighting, medical emergency, rescue, hazardous material (Hazmat) incident, and oil spill response. The Refinery Fire Department has a high ladder truck, ambulance, rescue truck, foam truck, water cannon, and several pumpers. The emergency contact person for the refinery at any time is the "Night Superintendent." If there is a significant fire or release, the Refinery notifies the New Castle County 911 center and potentially affected neighboring industrial facilities by telephone or radio. The 911 center can call additional fire departments, emergency units, and Local Emergency Planning Committee (LEPC). The Delaware Department of Natural Resources and Environmental Control (DNREC) hotline is notified. The Incident Commander and DNREC are responsible for notifying and protecting the community. Community notification may be by a 3 to 5 minute siren blast, emergency vehicle loud speakers, door to door notification, or loca l radio station announcements. The Delaware City Refinery participates in the New Castle County LEPC and Delaware City Community Awareness and Emergency Response group (DC CAER) emergency planning and training exercises. The Refinery maintains a close relationship with local fire companies to which many employees and contract workers belong. |