TPI PETROLEUM INC. - Executive Summary |
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1General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities June 15,1999 file name rmp.txt 1. Accidental Release Prevention and Emergency Response Policies We at TPI Petroleum Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by 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. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass this facility manufactures motor fuels from crude oil (oil refinery). We have 19 regulated substances present at our facility. These substances include Butane, Isobutane [Propane, 2-methyl], Propane, Isopentane [Butane, 2-methyl-], Pentane, Propylene [1-Propene], Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid], Hydrogen sulfide, Ethane, Butene, Hydrogen, Methane, Chlorine, Ammonia (anhydrous), Ethylene [Ethene], 1-Pentene, 2-Butene, Ammonia (aqueous) and Sulfur dioxide (anhydrous). . Butane is used for gasoline vapor pressure blending or is sold. Isobutane [Propane, 2-methyl] is used for converting light olefins to gasoline. Propane is sold as a finished product. Isopentane [Butane, 2-methyl-] is used for gasoline blending. Pentane is used for gasoline blending. Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] is used as a catalyst. Propylene [1-Propene] is used for alkalation unit feed and is sold. Hydrogen sulfide is a byproduct that is converted to elemental sulfur. Ethane is used for fuel gas in the heaters. Butene is used for alkalation unit feed. Hydrogen is used for desulfurizing oil and fuel. Methane is used for fuel gas. Chlorine is used for cooling water biocide treatment. Ammonia is used for refriger ation. Ethylene [Ethene] is used for fuel gas. 1-Pentene is used for gasoline blending. 2-Butene is used for alkalation unit feed. Sulfur dioxide (anhydrous) is a byproduct of combustion. The maximum inventory of Butane at our facility is 2722005.66 lb. while Isobutane [Propane, 2-methyl], Propane, Isopentane [Butane, 2-methyl-], Pentane, Propylene [1-Propene], Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid], Hydrogen sulfide, Ethane, Butene, Hydrogen, Methane, Chlorine, Ammonia (anhydrous), Ethylene [Ethene], 1-Pentene, 2-Butene, Ammonia (aqueous) and Sulfur dioxide (anhydrous) are present at our facility in quantities of 2112724.80 lb., 1707791.27 lb., 600171.84 lb., 373710.70 lb., 339007.44 lb., 226421.78 lb., 52592.14 lb., 41689.14 lb., 40489.60 lb., 35807.97 lb., 21768.05 lb., 20000.00 lb., 16669.55 lb., 6223.79 lb., 4653.97 lb., 3540.12 lb., 107.60 lb. and 70.76 lb. respectively. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), i ncluding administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from the ALKY unit. In this scenario 70000 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 11 miles is obtained corresponding to a toxic endpoint of 0.016 mg/L. An additional worst case release scenario for Program 2 and 3 toxics, involving a catastrophic release from the A LKY unit, is also included In this scenario 33251.21 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 7.5 miles is obtained corresponding to a toxic endpoint of 0.016 mg/L. An additional worst case release scenario for Program 2 and 3 toxics, involving a catastrophic release from the warehouse yard storage , In this scenario 2000 lb. of Chlorine is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 5.4 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. An additional worst case release scen ario for Program 2 and 3 toxics, involving a catastrophic release from the ALKY unit, In this scenario 8243.93 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 4.0 miles is obtained corresponding to a toxic endpoint of 0.016 mg/L. One alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a release from the ALKY unit. The scenario involves the release of 51000.00 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 20 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydroge n fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 2.4 miles. One alternative release scenario for Chlorine involves a release from the cooling towers south. The scenario involves the release of 2000 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 2.0 miles. Another alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a release from the ALKY unit. The scenario involves the release of 33251.21 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 30 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of H ydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 1.4 miles. Another alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a release from ALKY unit. The scenario involves the release of 8243.93 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 1.4 miles. Another alternative release scenario for Chlorine involves a release from CFHT cooling tower . The scenario involves the release of 1947.63 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather co nditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 1.4 miles. Another alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a release from the ALKY unit. The scenario involves the release of 33251.21 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 60 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 0.99 miles. Another alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a release from the ALKY unit. The scenario involves the release of 2196.10 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 0.12 minutes. The release is also assumed to be controlled by emergency shutdown system(s). Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 0.81 miles. Another alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a release from ALKY unit. The scenario involves the release of 1824.27 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by deluge system(s), flare(s), scrubber(s) and neutralization. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 0.62 miles. Another al ternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a release from the ALKY unit. The scenario involves the release of 490.79 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 20 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 0.19 miles. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from LPG storage west . In this scenario 2186024.89 lb. of Flam. Mix.: Isopentane [Butane, 2-methyl-], Butane, Isobutane [Propane, 2-methyl] is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a va por cloud explosion. Under worst case weather conditions, the calculated distance of 1.05 miles is obtained corresponding to an endpoint of 1 psi overpressure. An additional worst case release scenario for Program 2 and 3 flammables, involving a catastrophic release from LPG storage east In this scenario 976851.01 lb. of Isobutane [Propane, 2-methyl] is released It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.80 miles is obtained corresponding to an endpoint of 1 psi overpressure. An additional worst case release scenario for Program 2 and 3 flammables, involving a catastrophic release from LPG storage east, is also included in the RMP . In this scenario 237359.67 lb. of Flam. Mix.: Isopentane [Butane, 2-methyl-], Butane, Isobutane [Propane, 2-methyl], Propylene [1-Propene], Propane i s released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.50 miles is obtained corresponding to an endpoint of 1 psi overpressure. One alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from LPG storage west . The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 2186024.89 lb. of Flam. Mix.: Isopentane [Butane, 2-methyl-], Butane, Isobutane [Propane, 2-methyl] in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.70 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from LPG storage east. The release is assumed to result in a BLEVE. The scenario involves the rele ase of 237359.67 lb. of Flam. Mix.: Isopentane [Butane, 2-methyl-], Butane, Isobutane [Propane, 2-methyl], Propylene [1-Propene], Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 is 0.56 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from LPG storage east. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 976851.01 lb. of Isobutane [Propane, 2-methyl] in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.41 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with the following cod es and standards in place when equipment was built and installed, Piping is built to ASME B31.3 code. Pressure Vessels built to ASME section 8 Division 1. Boilers subject to ASME section 1. ASME section 8 covers pressure relief valves. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. We also have an air operating permit ID under Title V of the Clean Air Act. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information TPI Petroleum Inc. 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. T he methodology used to carry out these analyses is Checklist, What If/Checklist (combined), and HAZOP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 11/26/1998. Operating Procedures For the purposes of safely conducting activities within our covered processes, TPI Petroleum Inc. maintains written 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 a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training TPI Petroleum Inc. has a comprehensive training program in place to ensure that employees who are operating p rocesses are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed. Mechanical Integrity TPI Petroleum Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, 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. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at TPI Petroleum Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance proce dures was performed on 04/07/1999. 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 TPI Petroleum Inc.. The most recent review was performed on 09/18/1998. 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 TPI Petroleum Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 04/23/1998. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation TPI Petroleum Inc. 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 TPI Petroleum Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly 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 in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and const ruction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. TPI Petroleum Inc. 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 TPI Petroleum Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, the number of accidental releases has been reduced to a minimum. The RMP guidance document suggest facilities review their OSHA 200 forms looking for injuries associated with the release of covered flammables and toxics This was done and is reported below. There have been 4 accidental releases of regulated substances from our facility within the last 5 years. The first release took place on 12/ 26/94 and involved 0.01 lb. of Ethyl mercaptan [Ethanethiol]. The incident was a result of human error, as the employee spilled the material on his boot and then went inside a small enclosure to wait for a rail car of Propane to fill. The odor resulted in flu like symptoms involving the single employee. Due to this accident, 0 people offsite received medical treatment. Onsite, there was1 injury. Another release, of 0.01 lb. of Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid], occurred on 11/08/95 due to equipment failure (glove). An employee had a pin hole in his glove while drawing an acid sample for the lab. He received a small burn on his finger. Due to this accident, 0 people offsite received medical treatment. Onsite, there was 1 injury. Another release, of 748 lb. of Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid], occurred on 05/06/96 due to equipment failure. In this release the pump failed internally damaging both pump seals. Employees put on totally encapsulated suits and closed the valves stopping the release within minutes. No deaths or injuries occurred offsite as a result of this accident. Onsite, there were no injuries. There was some onsite property damage to the pump. Another release, of 400 lb. of Fuel gas , occurred on 07/13/98 due to equipment failure. No deaths or injuries occurred offsite as a result of this accident. Several evacuations were issued to the asphalt roofing plant to the south. Onsite, there were no deaths or injuries. There was some onsite property damage to the equipment involved. 6. Emergency Response Plan TPI 6/15/996/15/996/15/99. carries 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, evacuations, 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 promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Carter County Civil Emergency Management is the lead agency of the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The employees at this facility participate in an employee driven and managed behavior based safety process, these along with an audit based safety management system are the reason for our safe operations. In the future we will apply for OSHA VPP Star or Merit program. This application will be sent to OSHA department of Volunteer Compliance Programs in 1999. 1 Summaryfinal.doc 1 |