LaGloria Oil and Gas Company - Executive Summary |
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La Gloria Oil and Gas Company seeks to provide a safe work environment for their employees as well as ensure the safety of those offsite. In addition, La Gloria is keenly aware of the potential environmental impacts of their operations and they are committed to minimizing the negative effects of their processes on the environment. In meeting their goals, La Gloria Oil and Gas has commissioned Det Norske Veritas to prepare their EPA Risk Management Plan in compliance with 40 CFR Part 68. The following documentation includes the information referred to by the EPA as the Data Elements that will be transmitted to the EPA using their submission methods. In addition, an explanation of the consequence analysis is provided as well as a Certification Statement required by the EPA. According to EPA 40 CFR 68, part 68.155, the Executive Summary should contain the following items: a) The accidental release prevention and emergency response policies at the stationary source. b) The stationary source and regulated substances handled. c) The worst-case release scenario(s) and the alternative release scenarios(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. d) The general accident release prevention program and chemical-specific prevention steps. e) The five-year accident history. f) The emergency response program. g) Planned changes to improve safety. A. Accidental Release Prevention and Emergency Response Policies The following describes the prevention steps in place at the LaGloria Refinery. The LaGloria Refinery is required to comply with OSHA PSM. Employee Participation LaGloria encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation include updating procedures to participating as a member of a process hazard analysis (PHA) team. Process Safety Information LaGloria maintains and updates a variety of technical documen ts that are used to ensure safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure, hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS). The refinery has documented safety-related limits for certain process parameters, such as, temperature, level, and composition, in its Unit Operating Procedures manuals. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The refinery also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. 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 process are not compromised. Process Hazard Analysis (PHA) LaGloria 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 hazards and ensure that adequate controls are in place to manage these hazards. The LaGloria refinery primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates 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 findings are forwarded to management 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 completed. 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 design safety features, the LaGloria refinery periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequ ency until the process is no longer operating. The team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained. Operating Procedures The LaGloria Refinery maintains written procedures that address various modes of process operations, such as unit startup, emergency shutdown, and normal shutdown,. These procedures are periodically reviewed to ensure that they are current and accurate. These procedures are also updated whenever a change is implemented that affects the process chemicals, technology, or equipment in an operating process. In addition, LaGloria Refinery maintains in its Unit Operating Procedures manual procedures that provide guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. Training To complement the written procedures operations, the LaGloria Refinery has a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery operations. After successfully completing this training, a new operator is paired with a senior operator 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. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The LaGloria Refinery has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what th ey should do in the event of an emergency, and (5) understand and follow site safety rules. This is accomplished by providing contractors with information about safety and health hazards and emergency response plan requirements prior to their beginning work. In addition, the La Gloria refinery evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) The LaGloria Refinery conducts a PSSR for any new facility or significant facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. Mechanical Integrity The LaGloria Refinery has well-established practices and procedures to maintain press ure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. 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). Inspections are performed both "on-line" and when the equipment is scheduled down for inspection and repairs. Another integral part of the mechanical integrity program is quality assurance. The LaGloria Refinery incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and the proper materials and spare parts are used when repairs are made. Safe Work Practices The LaGloria Refinery has 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/t agout 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) permit and procedure to control spark-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. Management of Change The LaGloria 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 operating conditions), procedures, and other facility changes are 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 change. Incident Investigation The LaGloria Refinery investigates all incidents that resulted in, or reasonably could have resulted in, a catastrophic release of highly hazardous chemicals. 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 recurrence, and forwards these results to refinery management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. Compliance Audits To help ensure that the accident prevention program is functioning properly, the LaGloria Refinery periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. B. Description of Stationary Source and Regulated Substances Handled The La Gloria Oil and Gas Company (located in Tyler, Texas), a wholly owned subsidiary of Crown Central Petroleum Corporation, operates a typical petroleum refinery of approximately 50,000 barrels per day. The refinery is divided into several process units that work in combination to produce the end products of gasoline, butane, propane, etc. from raw crude oil. The refinery has several regulated flammable substances such as butane, propane, and mixtures. The refinery does not have any regulated toxic substances in quantities above the threshold quantities. C. Offsite Consequence Analysis The EPA RMP requires offsite consequence analysis to include the worst case flammable and toxic release scenarios as well as alternative cases for at least one flammable and all toxic substances. Worst Case Toxic: Not applicable. The LaGloria Refinery does not have any regulated toxic substances in quantities above the threshold quantities. Alternate Case Toxic: Not applicable. The LaGloria Refinery does not have any regulated toxic substances in quantities above the threshold quantities. Worst Case Flammable: 1.5 m/s wind with F stability - Description: Rupture of isobutane Storage Tank TK 166. - Location: High pressure Storage Tank Area - Material: Isobutane - Phase before release: Liquefied under pressure - Temperature: Ambient - 75 F - Pressure: 150 psig - Quantity: 200,000 lbs - Duration: 10 minutes - Distance to endpoint: 0.47 miles - Notes: Using EPA Lookup Table 9. - The maximum number of people effected is estimated to be 200. Alternate Case Flammable: 3.0 m/s wind with D stability - Description: 1 inch leak in isobutane Storage Tank TK 166. - Location: High pressure Storage Tank Area - Material: Isobutane - Phase before release: Liquefied under pressure - Temperature: Ambient - 75 F - Pressure: 150 psig - Quantity: 200,000 lbs - Duration: 60 minutes - Distance to endpoint: 0.08 miles - Notes: Modeled using PHAST V. 5.2. Weather conditions of 6.7 mph, D stability, padded liquid. - It is not expected that this scenario would impact any people offsite. D. General Accidental Release Prevention Program Steps The following describes the prevention steps in place at the La Gloria Refinery. The La Gloria Refinery is required to comply with OSHA PSM by completing Process Hazard Analysis Studies. In all, the refinery maintains current studies on over 20 process and storage units. These studies involve employees and are available for the employees to review. In addition, The La Gloria Refinery maintains current on other elements of the Prevention Program, including: Training O perating Procedures Maintenance Compliance Audits Accident Investigations Management of Change Safe Work Practices Contractor Safety E. Five-Year Accident History The La Gloria Refinery is very concerned with maintaining a safe work environment for their employees and preventing any negative impacts on the surrounding community. There has been one reportable accident in the previous 5 years despite attempts to provide a safe working environment. This accident had no impact on the environment or the safety of the surrounding residents, but did cause injury to one onsite employee. The accident involved the explosion of a steam boiler that released 500 pounds of flammable substances. F. Emergency Response Program The La Gloria refinery maintains a written emergency response program that 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 f ire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs. The overall emergency response at the La Gloria Refinery is coordinated with the Smith County Local Emergency Planning Committee (LEPC). The La Gloria Refinery has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department, police department). G. Planned Changes to Improve Safety The La Gloria Refinery is constantly seeking to improve the safety of the plant. Many safety recommendations result from Process Hazard Analyses and other safety reviews. The following comments highlight some of the changes being considered: Improvements to the Emergency Response and Acti on Plan for releases. Improved Emergency Response Training. Installation of remote isolation valves for select operations. Revisions to written operating procedures. Revisions to written safety procedures and retraining of personnel. |