Specified Fuels & Chemicals - Executive Summary

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Executive Summary for Specified Fuels & Chemicals 
1.  Accidental Release Prevention and Emergency Response Policies 
We at Specified Fuels & Chemicals are strongly committed to employee, public and environmental safety.  This commitment is inherent to our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release.  Specified Fuels & Chemicals is a Responsible Care. company and a member of the Texas Clean Industries 2000. 
2.  The Stationary Source and the Regulated Substances Handled 
Specified Fuels & Chemicals, L.L.P. (SFC) operates as both a petroleum refinery and a specialty chemical tolling facility.  As 
a refinery, SFC produces research and reference fuels to the automobile and engine oil manufacturing industries.  As a chemical manufacturer, SFC produces high volumes of specialty chemicals requiring multiple processing steps.  Since 1990, SFC has been a commercial scale toll and custom chemical producer with emphasis on the manufacture of esters and acetates used in water-based paints, adhesives, paper coatings, textile finishing and safety glass.  The quantities listed below represent the maximum amount of a regulated substance that could be onsite. 
Chemical                                                                              CAS No.                            Maximum Inventory (lbs) 
Toxic Substances: 
Vinyl acetate monomer [Acetic acid ethenyl ester]             108-05-4                                      7,500,000 
Flammable Substances (Liquid Form): 
Propane                                                                                 74-98-6                           
Butane                                                                                  106-97-8                                           39,000 
Isobutane [Propane, 2-methyl]                                               75-28-5                                            40,000 
Pentane                                                                                109-66-0                                           22,500 
Isopentane [Butane, 2-methyl]                                               78-78-4                                         242,500  
3.  The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
SFC is the owner and operator of a stationary source that has more than the threshold quantity of a regulated substance in a process, as determined under 40 CFR 68.115 and therefore is subject to 40 CFR Part 68 - Chemical Accide 
nt Prevention Provisions.  SFC is a Program 3 level facility because the processes covered under RMP are also subject to the OSHA process safety management standard, 29 CFR 1910.119.  
To evaluate the worst case scenarios, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance.  For alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance.  The following provide details of the chosen scenarios. 
Toxic Substance Scenarios 
The worst-case release scenario for toxic substances, as a class, involves a catastrophic release of Vinyl acetate monomer [Acetic acid ethenyl ester].  The scenario involves the instantaneous release of 7,500,000 lbs. of Vinyl acetate monomer in a liquid form over 10 minutes and is completely contained within a diked area. 
 Evaporation from that pool within the dike occurs over a 60-minute period.  Calculations take into account the worst case weather conditions (stable, low wind speed) in an urban setting, and are calculated to a toxic endpoint of 0.26 mg/l. 
The alternative release scenario for Vinyl acetate monomer involves a release from a ruptured disk or a relief valve failure.  The scenario involves the release of 5,770 lbs. of Vinyl acetate monomer. It is assumed that the release takes place for 60 minutes before it is brought under control.  The toxic liquid is contained in a pool, from which surface evaporation takes place over the 60 minutes.  Passive mitigation controls such as dikes are taken into account to calculate the scenario.  The release is also controlled by active mitigation measures that include automatic shut off valves, booms, foam and sorbent to confine the release.  These active mitigation controls are expected to limit the extent of the spill and reduce the amount released by 
over 99%.  Under the most common weather conditions, the maximum distance to the toxic endpoint of 0.26 mg/l of Vinyl acetate monomer is less than the distance to the nearest public receptor. 
Flammable Substance Scenarios 
The worst case release scenario for flammable substances, as a class, involves a catastrophic release of Isopentane [Butane, 2-methyl].  The scenario involves the release of 39,000 lbs. of Isopentane.  It is assumed that this quantity is released as a vapor, which finds an ignition source, with the entire released quantity participating in a vapor cloud explosion.  Under worst case weather conditions (stable, low wind speed) in an urban setting, the endpoint is calculated to be 1-psi overpressure. 
The alternative release scenario for flammable substances involves a release of Isopentane from a valve failure at the bottom of a tank. The scenario involves a 60-minute release of 17,000 lbs. of Isopentane that is completely contained within a diked area.  It is assume 
d that the release results in a pool fire.  The release is also controlled by active mitigation measures that include fire monitors and "dry" fire extinguishers.  Under the most common weather conditions the endpoint of 5 kilowatts/square meter (flash burns), which is the distance at which the radiant heat effects could cause second degree burns from a 40-second exposure, is less than the distance to the nearest public receptor. 
4.  The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
SFC has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.  The petroleum refinery and specialty chemical tolling processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119.  SFC is also subject to EPCRA Section 302 notification requirements.  The following sections briefly describe the elements of the release prevention program that is in place at our statio 
nary source. 
Process Safety Information 
SFC maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The checklist method is used to carry out our process hazard analyses.  The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated on a regular basis or when there is a change in the process.  Any findings related to the hazard analysis are addressed in a timely manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, SFC maintains written standard operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency  
shutdown, emergency operations, normal shutdown and startup after maintenance.  The information is regularly reviewed and is readily accessible to operators involved in the processes. 
SFC has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with those processes.  New employees receive training and are tested for competency before starting work.  Refresher training is provided on a regular basis. 
Mechanical Integrity 
SFC carries out documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes among others; pressure valves, storage tanks, hoses and piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices and are offered specialized training as needed.  Any equipment de 
ficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at SFC to manage changes in chemicals being manufactured, technology, equipment and procedures.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at SFC.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
SFC will conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  These audits will be carried out at least every 3 year 
s and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
SFC promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
Employee Participation 
SFC believes that process safety management and accident prevention is a team effort.  Company employees are encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses.  There is a Safety, Health & Environmental committee at the site, which is made up of hourl 
y employees as well as management employees. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, an evaluation of the contractor safety performance is carried out.  SFC has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
5.  Five-year Accident History 
SFC has had an excellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, no accidental release has occurred during this period. 
6.  Emergency Response Plan 
SFC has a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuat 
ions, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced.  In addition, the plan is regularly updated to reflect any pertinent changes taking place within our processes that would require modifications to emergency response. 
7.  Planned Changes to Improve Safety 
Since the implementation of the various elements of our accidental release prevention program, there have been no developments or findings that indicate the immediate need to improve safety at our facility.  We have a continuous improvement policy in place that includes safety issues. 
8.  Certification Statement 
The undersigned certifies that to the best of their knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
Name:    George B. Freda 
Title:    Vice President, Safety Health & Envir 
onmental Affairs 
Date signed: June 16, 1999
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