Shell Deer Park Refining Company - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
The Shell Deer Park Refining Company (SDPRC) has a long-standing commitment to worker and public safety. This commitment is demonstrated by the amount of resources invested in accident prevention, such as training of personnel and considering safety in the design, installation, operation, and maintenance of our processes.
Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained emergency response personnel will respond to control and contain the release to minimize impact to our employees and the public.
FACILITY DESCRIPTION AND REGULATED SUBSTANCES HANDLED
The Shell Deer Park Refining Company (SDPRC) is located in Deer Park, Texas along the Houston Ship Channel some 20 miles east of downtown Houston. SDPRC operates a variety of processes to produce such products as gasoline, jet fuel, kerosene, diesel fuel, heating oil, propa
ne, butane, asphalt, petroleum coke, and chemical feedstocks. The Refinery has several regulated flammables, such as butane, butene, isobutane, pentane, isopentane, and mixed flammables throughout several process units. In addition, the Refinery uses chlorine in some of its processes and stores epichlorohydrin (ECH) for use at our neighboring Chemical Plant. Chlorine and ECH are regulated toxic substances.
HAZARD ASSESSMENT RESULTS -WORST CASE AND ALTERNATIVE RELEASE SCENARIOS
The facility performed off-site consequence analyses of accidental releases of regulated substances to estimate potential affects to the public or the environment. The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario" and an "alternate release scenario". SDPRC does not expect a worst-case release scenario to ever occur given the multiple levels of protection in place to prevent such a scenario. The alternative release scenarios that have been developed are bas
ed on more likely potential accidental releases. These have been shared with the Local Emergency Planning Committee (LEPC) to assist them in improving the community emergency response plan.
SDPRC participated with local industry in delivering the risk management plan message to a broad-base of community through industry open houses, speakers programs, newspaper stories and newspaper advertisements. SDPRC continues to address RMP with the local emergency planning committees.
Distances to toxic and flammable endpoints were calculated based on the EPA RMP Offsite Consequence Analysis Guidance. The meteorological data used for the modeling was the EPA standard for the worst case scenario and EPA suggested values for the alternative release scenario. The Landview. III program was utilized to estimate the number of persons living within this distance from the location of the potential release point. USGS maps were used to identify the public and environmental receptors located within
this distance. The following information summarizes the off-site consequence analysis performed by SDPRC:
Chlorine - RMP Toxic Substance; Worst-case and Alternate Release Scenarios
The "worst-case scenario" involving a toxic substance at this facility would involve the catastrophic failure of one ton cylinder of chlorine. This scenario assumes a maximum inventory of chlorine would be released and evaporates within a 10-minute period. Under the EPA defined worst weather conditions, the chlorine gas cloud would potentially travel 1.3 miles before the concentration diminished below the ERPG-2 concentration of 3ppm. Although we have numerous controls to prevent such releases and to manage their consequences, no credit is taken for passive or active mitigation in the analysis. Potential public receptors include schools, residences, and industrial areas. There are no environmental receptors within this distance from the release point. The EPA RMP Guidance for Wastewater Treatment Pla
nts document was used in evaluating this scenario.
An "alternate release scenario" for chlorine involves the failure of a =-inch transfer hose connected to a chlorine cylinder. The expected amount discharged would be released over a 10-minute period. Active mitigation accounted for in the analysis includes operator intervention to close the valve(s) and isolate the leak. No credit is taken for passive mitigation. Under the EPA alternate release weather conditions, the expected amount of chlorine discharged would travel a sufficient distance to go off-site and affect some industrial neighbors, but would not affect residential areas before the concentration diminished below the ERPG-2 concentration of 3ppm. There are no environmental receptors within this distance from the release point. The EPA RMP Guidance for Wastewater Treatment Plants document was used in evaluating this scenario.
Epichlorohydrin - RMP Toxic Substance; Alternate Release Scenario
An "alternate release scenari
o" for epichlorohydrin (ECH) involves a failure of a 3-inch storage tank discharge line inside the tank dike. This line failure results in an epichlorohydrin spill into the tank dike. Credit is taken for passive mitigation (e.g. the dike walls). Under the EPA alternate release weather conditions, this release would travel 0.19 miles before the concentration diminished below the ERPG-2 concentration of 20ppm. There are no public or environmental receptors within the area potentially affected by the spill. The EPA OCA Guidance document was used in evaluating this scenario.
Pentane - Worst-case Scenario
The "worst-case scenario" involving a flammable substance would involve the catastrophic failure of a pentane storage tank. This flammable substance release scenario assumes the entire contents of the tank is released and vaporizes to form a vapor cloud that subsequently ignites. In this scenario, a pressure of 1-psi over normal atmospheric pressure is used as the endpoint for a vapo
r cloud explosion. Although, we have numerous controls to prevent such releases and to manage their consequences, no credit is taken for active or passive mitigation. Under the EPA defined worst weather conditions, the pentane explosion could potentially affect areas up to 1.8 miles away before the pressure diminished below the 1-psi endpoint. Potential public receptors include schools, residences, and industrial areas. There are no environmental receptors within this distance from the release point. The EPA OCA Guidance document was used in evaluating this scenario.
Propane - Alternate Release Scenario
An "alternate release scenario" for propane involves the failure of a 6" discharge line from a propane storage tank to a pipeline. For this scenario, the expected amount of propane was released and vaporizes to form a vapor cloud that subsequently ignites. A pressure of 1-psi over normal atmospheric pressure is used as the endpoint for a vapor cloud explosion. Although, we have nume
rous controls to prevent such releases and to manage their consequences, no credit is taken for active or passive mitigation. Under the EPA defined worst weather conditions, the propane explosion could potentially affect areas up to 0.38 miles away before the pressure diminished below the 1-psi endpoint. There are no environmental receptors within this distance from the release point. Typical weather conditions in our area (considered urban) and the PHAST Modeling tool were used in evaluating this scenario.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
The following is a summary of the general accident prevention program in place at SDPRC.
The SDPRC President/CEO with support from the Health & Safety Manager has the responsibility for overseeing the implementation of the elements of the risk management program, including prevention activities. The RMP Coordinator with support from the Process Safety Management/Process Hazar
d Analysis (PSM/PHA) Coordinator and the Emergency Response Coordinator has the responsibility for the development, implementation, and integration of the Risk Management Program.
The Shell Deer Park Refining Company (SDPRC) recognizes the value of employee participation and provides for and encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis team. Employees have access to all information created as part of the refinery accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the Refinery and addresses each accident prevention program element. In addition, SDPRC has a number of initiatives under way that address proc
ess safety and employee safety issue. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management.
Process Safety Information
The Shell Deer Park Refining Company maintains a variety of technical documents that are used to help sustain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis information. Specific departments within the Refinery are assigned responsibility for maintaining this process safety information up-to-date. A table summarizing the reference documents and their locations is readily available to help employees locate any necessary process safety information.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment conside
rations, is provided in Material Safety Data Sheets. This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the Refinery has documented safety-related limits for specific process parameters (e.g. temperature, level, composition) in a Key Process Parameters Document. 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).
Process Hazard Analysis
The Shell Deer Park Refining Company (SDPRC) 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.
SDPRC primarily u
ses a hazard evaluation technique called hazard and operability (HAZOP) analysis to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. 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 incident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes it is necessary.
The HAZOP team findings are forwarded to local management for resolution. Implementation of corrective actions to respond 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 corrective actions taken in response to the PHA team findings are tracked until they are completed. T
he final resolution of each finding is documented and retained.
To help ensure that the process hazard controls and/or process hazards do no eventually deviate significantly from the original design safety features, the Refinery periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained.
The Shell Deer Park Refining Company maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a re
ference by experienced operators and provide a basis for consistent training of new employees. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process.
In addition, the Refinery maintains a Key Process Parameter Document that addresses response to exceeding the upper or lower limit for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safety perform their job tasks.
To complement the written procedures for process operations, the Shell Deer Park Refining Company has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery operations before being assigned to
a specific unit. After successfully completing this training, a new employee is paired with a senior employee to learn process-specific duties and tasks. After employees demonstrate (e.g., tests, skills demonstration) having adequate knowledge to perform the duties and task in a safe manner on their own, they can work independently. In addition, all employees periodically receive refresher training in the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every three years. All of this training is documented for each employee, including the means used to verify that the employee understood the training.
The Shell Deer Park Refining Company has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic asp
ect of this program include (1) conducting training, (2) developing written procedures, (3) performing inspections and test, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process.
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and test are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness). In the event that a deficiency is identified, employees (if possible) will correct the deficiency before placing t
he equipment back into service, or a group of experts will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.
Another integral part of the mechanical integrity program is quality assurance. The Refinery incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper material and spare parts are used when repairs are made.
Management of Change
The Shell Deer Park Refining Company has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be 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 h
ave not been compromised by the change. Affected chemical 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 to change.
The Shell Deer Park Refining Company conducts a pre-startup reviews know as PSSRs of any new facility or 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 to startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. For complex or extensive modifications, the PSSR team uses checklists to verify all aspects or readiness. A PSSR involves field verification of the c
onstruction and serves a quality assurance function by requiring verification that other prevention program requirements were properly implemented.
To help ensure that the accident prevention program is functioning properly, the Shell Deer Park 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 three years. Both hourly and salaried personnel participate as audit team members. The audit team develops findings that are forwarded to refinery management for resolution. Corrective actions taken in response to the audit teams' findings are tracked until they are completed. The final resolution of each finding is documented, and the two most recent audit reports are retained.
The Shell Deer Park Refining Company promptly investigates all incidents that resulted in or reasonably could have resu
lted in a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury which affects personnel, the public or environment. 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 a 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 completed. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees who could be affected by the findings. Incident investigation reports are retained for at least five years so that the reports can be reviewed during the next PHA.
Hot Work Permit (Safe Work Practices)
The Shell Deer Park Refining Company has long-standing
safe work practices, including hot work permits that are in place to help ensure worker and process safety. Examples of these could include (1) control of the entry /presence/exit of support personnel, (2) isolation of energy sources for equipment that is being worked on through the use of lockout/tagout procedure, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) control over spark-producing activities through the use of a permit and procedure, 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 in a safe manner.
The Shell Deer Park Refining Company uses contractors to supplement its workforce during periods of intense maintenance or construction activities. Because some contractors work on
or near process equipment, the 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 they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Shell personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the Shell Deer Park Refinery evaluates contractor safety programs and performance during the selections of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
FIVE-YEAR ACCIDENT HISTORY
The Shell Deer Park Refining Company has an excellent recor
d of accident prevention over the past 5 years; there have been no releases of covered chemicals from covered processes during this time. The injury rates for employees and contractors have continually decreased; currently the OSHA recordable incident rate is an industry-leading rate.
EMERGENCY RESPONSE PROGRAM
The Shell Deer Park Refining Company maintains a written emergency response program 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 fire 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, and post-incident cleanup and decontamination requirements.
nt personnel are trained in the plant alarm system, sheltering-in-place, and evacuation procedures.
The written emergency response plan complies with the following federal and state contingency plan regulations:
7 OSHA 29 CFR 1910.38(a) - Employee Emergency Action Plans
7 OSHA 29 CFR 1910.119 (n) - Process Safety Management of Highly Hazardous Chemicals
7 OSHA 29 CFR 1910.120(p) and (q) - Hazardous Waste Operations and Emergency Response
7 OSHA 29 CFR 1910, Subpart L - Fire Protection
7 EPA 40 CFR 302.6 - Notification Requirements
7 EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Plan
7 EPA 40 CFR 355.40 - Emergency Planning and Release Notifications
7 EPA 40 CFR 112 - Spill Prevention, Control and Countermeasures Plan
7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention
SDPCP maintains an emergency response team trained in the Emergency Response procedures, and is available around-the-clock to respond to in-plant chemical emergencies
. The facility's offsite transportation response team is called the Response Action Team. The team maintains a mobile hazardous materials vehicle with the necessary equipment to respond to chemical emergencies. In addition, SDPRC has procedures that address maintenance, inspection, and testing of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to refinery processes or other refinery facilities. The emergency response program is reviewed annually by all employees.
The SDPRC emergency response program is coordinated with the Deer Park, Texas - Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. SDPRC has 24 hour a day communications capability
with appropriate LEPC officials, municipal emergency response organizations, and industrial mutual aid emergency response organizations. SDPRC conducts periodic emergency drills that involve the Deer Park LEPC, local municipal fire departments, and the Channel Industries Mutual Aid Organization.
PLANNED CHANGES TO IMPROVE SAFETY
SDPRC constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, process hazard analysis, joint union and management health and safety committee, and a program for soliciting health, safety and environmental suggestions from plant employees.