Javelina Company (Partnership) - Executive Summary |
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EXECUTIVE SUMMARY Accidental Release Prevention and Emergency Response Policies Javelina Company has a longstanding commitment to both employee and public safety. Such commitment is demonstrated by the resources that are invested in accident prevention, personnel training, and emergency response preparedness. Safety is of prime consideration in the design, installation, operation, and maintenance of all Javelina processes and equipment. Javelina's policy is to implement reasonable controls to prevent foreseeable releases of regulated substances, and to be prepared to respond quickly and effectively to any releases which may occur. Detailed procedures designed to fulfill this policy are found in the following documents: - Javelina Company Emergency Plan - Process Safety Management Manual - Safety Procedures Manual - Standard Refinery Procedures Manual Facility Description and Regulated Substances Handled Javelina Company is a refinery gas processing plant. Refiner y gas is created during the refining process, and is typically used as a fuel in refinery boilers and heaters. This gas contains components, such as ethylene, ethane, and hydrogen, which are more valuable as chemical and plastic feedstocks than they are as fuels. Each of the six refineries in the Corpus Christi area produce this gas, but not in sufficient volumes at each refinery to economically justify the investment needed for a processing facility to separate the components. The Javelina facility was built in 1989-90 to process gas from the various refineries. The facility began processing gas from the refineries in late 1990. With all refineries on line, Javelina processes approximately 138 million standard cubic feet per day of refinery off-gas. From this is produced more than 25,000 barrels of liquid hydrocarbons, including ethylene, ethane, propylene, propane, butane, and natural gasoline, plus 30 million standard cubic feet of hydrogen. Ethylene and propylene are class ified as basic petrochemicals, while ethane, propane, and butane are considered feedstocks. Pentane, also called natural gasoline, is routed to the refineries for further processing. Hydrogen is widely used in the chemical and refining industries. The Javelina facility does not contain any toxic chemicals listed in 40 CFR '68 above the threshold quantities. The facility does not store large quantities of regulated flammable substances, but the processing equipment does contain several of the regulated flammable substances above the threshold quantities listed in Table 3 of '68.130. These substances include butane (mixture of n-butane and isobutane), ethylene, propylene, ethane, propane, hydrogen, and methane. Worst Case Scenario The worst case scenario at the Javelina facility involves the release of a mixture of ethane and ethylene from the C2 Splitter. The C2 Splitter is a fractionation tower designed to separate ethylene from ethane. It is 276 feet tall, 12= feet in diamete r, and contains approximately 280,000 lbs of an ethane/ethylene mixture (30% ethylene, 70% ethane) at maximum liquid height. For the worst case analysis, this entire quantity was assumed to be released as a vapor over a ten minute period, with a resulting vapor cloud explosion. Although numerous controls are in place to prevent such releases and manage their consequences, no credit was taken for mitigation in evaluating this scenario. Using the equations from the EPA Offsite Consequence Analysis Guidance (equation C-1), the distance to 1 psi overpressure is calculated as 2,800 feet (0.53 miles) from the source. Alternative Release Scenario The alternative release scenario selected for the Javelina facility involves an ethylene leak due to a flange separation on the suction side of the ethylene product pumps. This leak was assumed to release 16,500 pounds of ethylene over a ten minute period. Although the ethylene in the plant is a liquid at this point, it was assumed to instant ly vaporize for the purposes of this analysis. The resulting vapor cloud was assumed to ignite, resulting in a vapor cloud explosion. This release was selected as a practical scenario for emergency response planning purposes. The distance to 1 psi overpressure for this scenario was also calculated using equation C-1 from the EPA Offsite Consequence Analysis Guidance. However, a 3% yield factor was used instead of 10%, as recommended in the guidance document. The distance to a 1 psi overpressure is calculated as 735 feet (0.14 miles) from the source. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps Javelina accident prevention programs encompass four different areas: design, operation, maintenance, and auditing. The facility is subject to the OSHA PSM regulations, and has developed a program to maintain compliance with those regulations. Some of the elements of the Javelina accident prevention program are outlined below. Designing for Safe ty - Materials of construction are chosen to provide mechanical integrity - Flammable gas and Hydrogen Sulfide monitors provide early warning in case of leaks - Vessels are equipped with level, pressure, and temperature alarms - Pressure vessels are equipped with pressure relief valves to prevent overpressure Operating Safely - Operators are trained, tested, and qualified according to Occupational Safety & Health Administration standards - The process is continually monitored by computerized control systems and operators - Operational procedures are based on Process Hazards Analyses - Operators follow approved procedures - Pre-startup safety reviews are conducted before starting new or significantly modified equipment Maintaining the Plant - Maintenance personnel are trained, experienced, and qualified - Maintenance personnel are an important part of the plant safety programs - A work order and permit system is used to control maintenance work on process equipment - Preventative inspection and testing of critical equipment is performed on a scheduled basis Auditing Operations - Safety audits are conducted periodically - Safety meetings are conducted at least monthly - Safety equipment is inspected monthly - Accidents are investigated and corrective actions are taken to prevent recurrence - Independent loss prevention inspections are conducted - Process Hazards Analyses have been conducted on all processes and are being revalidated on a rotating schedule Five Year Accident History Javelina has had no chemical releases reportable under 40 CFR '68.42 in the past five years. A precautionary evacuation of immediate neighbors was initiated in March of 1998 during a situation which had the potential for a chemical release. Emergency Response Program The Javelina emergency response program can be divided into two components: preparation and response. The elements of each of those components a re briefly described below. Training and Preparation - Plant emergency response plan is in place and updated as necessary - All employees are trained for their role in the emergency response plan - All operations personnel are included on the emergency response team, and have been trained in fire fighting and hazardous materials response - The City of Corpus Christi Fire Department provides primary response capabilities for the facility - Refinery Terminal Fire Company will respond if required to back up Fire Department personnel - Drills are conducted periodically and critiqued - Hazardous Waste Operations and Emergency Response training is conducted annually for all emergency response team members - Emergency response team members are trained on live fires at Lamar University and Texas A&M Response - Sensors detect the leak and notify control room personnel - In-plant emergency alarms are activated by personnel in the control room - Operations personnel will assess the situation and request assistance from Corpus Christi Fire Department and/or Refinery Terminal Fire Company if the situation warrants - Operations personnel will notify public safety providers and local emergency management who will inform citizens by various means - Operations personnel will attempt to isolate the source of the release - If outside assistance has been requested, operations personnel will establish a command center upon arrival of the fire department - Off-site emergency alarms are activated from the control room if there is any concern that the release will travel beyond the plant fence line Planned Changes to Improve Safety The Javelina accident prevention policies currently in place include provisions to continually review and update those policies as new information becomes available. Information sources include PHA revalidations, accident (and near-miss) investigations, new regulations, rev iew of incidents at other facilities, etc. No major changes are currently planned for Javelina's safety policies, but the policies will be continually fine-tuned to minimize the risk to employees and the surrounding community. |