Wood River Refining Company - Executive Summary |
|
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Wood River Refining Company, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs for workplace safety, the public safety, and protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency RMP response program * An overview of planned improvements at the facility to h elp prevent RMP accidental chemical releases from occurring and minimize the potential impact of such releases. * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our EPA risk management program STATIONARY SOURCE AND RMP REGULATED SUBSTANCES Equilon Enterprises LLC Wood River Refinery employs approximately 1,140 people who live in communities near the facility. Our products are used throughout the mid-west to keep cars, trucks, and other machinery operating. Our facility is a producer of quality petroleum products, such as gasoline, diesel fuel, aviation fuel, and lubricating oils using a variety of chemicals and processing operations. In our processes, we use the following chemicals that EPA has identified as having the potential to cause certain types of offsite consequences in the event of an RMP accidental release: Chlorine is stored in 2000 lb cylinders and used in water treatment. Twenty-two flammabl e substances (listed below) are also present in various quantities as components in flammable mixtures in various stages of process. Butane 1-Butene Butene 2-Butene-cis 2-Butene-trans [2-Butene, (E)] Ethane Ethylene [Ethene] Ethyl mercaptan [Ethanethiol] Hydrogen Isobutane [propane, 2-methyl] Isopentane [Butane, 2-Methyl-] Isoprene [1,3-Butadiene, 2-methyl-] Methane 3-Methyl-1-butene 2-Methyl-1-butene 2-Methylpropene [1-Propene, 2-methyl-] isobutylene Pentane 1-Pentene 1-Pentene, (E)- 2-Pentene, (Z)- Propane Propylene [1-Propene] Our accidental release prevention programs and our contingency planning efforts help us effectively manage the recognized hazards associated with the use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about some of the k ey administrative controls and mitigation measures in place to limit the potential exposure distances for each scenario: RMP Worst-case Release Scenario(s) - RMP Regulated Toxic Chemicals The worst case release scenario associated with RMP toxic substances is the failure and subsequent release of 2000 lbs of chlorine over a 10-minute period. Because chlorine is used and stored in different areas in the complex, four separate but identical scenarios are included in the plan: Distilling/Utilites, Cracking/Alky, Aromatics East, and Lubricants areas. Although we have numerous safeguards to prevent such a release, no credit for administative controls or mitigation was assumed in evaluating these scenarios in accordance with the EPA's requirements. RMP Alternative Release Scenario(s) - RMP Regulated Toxic Chemicals The alternative release scenario for chlorine is an accidental release from a 3/8" diameter piece of tubing of 660 lbs over a 10-minute period, at the Lubricants area. 10- minutes is the approximate time necessary for operating personnel to don protective equipment and stop the release. No other controls or mitigation was assumed in evaluating this scenario in accordance with EPA's requirements. RMP Worst-case Release Scenario(s) - RMP Regulated Flammable Chemicals Four separate worst case release scenarios associated with RMP flammable substances or mixtures are included in the plan. They involve an accidental vapor cloud explosions of: a) contents of the largest butane storage vessel in north property (2.84 million lbs), b) contents of the largest vessel at the Alkylation unit (1.46 million lbs), and c) propane released from the piping at the east and also the west underground propane storage caverns (1.22 million lbs and 300,700 lbs respectively). Both cavern releases assume the propane is released over a 10-minute period. Although we have numerous safeguards to prevent such releases, no credit for administrative controls or mitigation was assu med in evaluating these scenarios in accordance with EPA's requirements. RMP Alternative Release Scenario(s) - RMP Regulated Flammable Chemicals The alternative release scenario for RMP flammable substances or mixtures is an accidental release from a 3/4" bleeder valve of 12,186 lbs over a 10-minute period, at the Sats Gas Plant. 10-minutes is the approximate time necessary for operating personnel to stop the release. No other controls or mitigation was assumed in evaluating this scenario in accordance with EPA's requirements. We are using this information to help us with our emergency response planning activities. GENERAL RMP ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The following is a summary of the general RMP accident prevention program in place at Wood River Refinery. Because processes at the refinery that are regulated by the EPA RMP regulations are or may also be subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the RMP accident prevention program. * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * PSM compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors These individual elements of our prevention program work together to help prevent RMP accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. Specific details are included in the WRRC Prevention Program and the WRRC Management System Summary sections of our plan. RMP FIVE-YEAR ACCIDENT HISTORY We keep records for accidental chemical releases that occur at our facility. The following is a brief summary of the one accidental chemical release involving materials covered under EPA's RMP rule during the past five years: 1994 1995 1996 1997 1998 Number of RMP releases: 0 0 0 0 1 This incident involved the release of 700 lbs of a flammable substance in an oil mixture which resulted in some property damage to the community on 2 July 1998. There were no known off-site injuries, no evacuations were necessary, but homes and property required clean up as a result. Following this incident, we conducted a formal incident investigation to identify and correct the root cause(s) of the events. An upgrade of the process equipment resulted from this process. EMERGENCY RESPONSE PROGRAM The Wood River Refining Company (WRRC) has an emergency response program in place. The WRRC emergency response plan addresses response to emergency situations both from a general employee perspective and from an on-site emergency response team perspectiv e. WRRC emergency plans outline general employees response to different types of emergencies that may occur within the refinery. These plans are outlined in the WRRC Emergency Manual and include guidelines on such elements as emergency reporting and communications, evacuation, response to various types of emergencies (i.e. fires, spills/releases, medical, rescue, radiation, severe weather, civil disorders, etc.), incident operations, and fire prevention and protection. Additionally, each process area has emergency prodedures that provide guidance for process/operations personel to respond to various operational upset/emergencies that could potentially affect the areas. Refinery employees receive training on the emergency plans as well as training on emergency equipment, such as fire suppression equipment, respiratory protection, personal protective equipment and alarm systems. The refinery maintains an on-site emergency response team to respond to any potential emergencies that may occur within the refinery. The all-volunteer response team provides fire, rescue, medical, hazardous materials response and various support services to the refinery on a 24 hour a day, 365 day a year basis. The response team maintains response vehicles that include pumping apparatus, rescue/medical vehicles, haz mat vehicle, and miscellaneous support apparatus and trailers. All response team members receive emergency response training. Additionally, standard operating guidelines have been developed to manage response team operations. Training and standard operating guidelines are routinely tested through periodic emergency drills. WRRC maintains response plans for Spill Prevention Control and Countermeasures, Multi-injury Operations, Disaster Operations, Oil Pollution Act of 1990 (OPA 90) Facility Response Plan, and Marine Fire Response. These plans provide guidance for managing certain types of incidents. The Wood River Refining Company coordinates emergency response activities with the local municipalities and other local industries. WRRC is an active member of the Twin Rivers Community Awareness and Emergency Response (CAER) Council, the Region IV Disaster Committee, Alton Memorial Hospital EMS System, the River Industry Mutual Aid Group (RIMAG), the Madison County Local Emergency Planning Committee (LEPC), and the Madison County Fire Chiefs Association. WRRC personnel routinely attend meetings of these organizations and help coordinate development of mitigation plans for refinery incidents that may have offsite activities. WRRC maintains access to the Community Alert Network (CAN) which is a computer telephone system that is designed to alert area residents of potential emergency situations. WRRC has procedures in place on how to quickly activate the CAN system to deliver evacuation or shelter-in-place instructions to the general public if needed. PLANNED CHANGES TO IMPROVE SAFETY WRRC resolves all findings from PHA's, some of which resul t in modifications to the process. PHA mitigations are planned in the following areas: Process instrumentation and/or control revisions in identified units. Pressure relief device revisions in the Alkylation Unit (ALKY). Shutdown system revisions at the Sulfur Recovery Unit (SRU). Safe work practices review/revisions in identifed areas. Written operating procedures review/revisions in identified areas. Installation of flare autoignitor at the Kerosene Hydrotreater Unit (KHT) Continue to eliminate "dead leg" piping in identified units. Installation of new equipment such as more effective valves and more effective pump seals in identified units. Heat tracing and insulation revisions in identified areas. CERTIFICATIONS The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete as of the issue date of this RMP. Name: Signature: Title: Date: RMP DATA ELEMENTS The f ollowing pages present additional information about our RMP risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: * Registration * Offsite consequence analysis * Five-year accident history * Program 3 prevention program * Emergency response program |