CIT-CON Oil Corporation - Executive Summary |
|
2964 LADEQ Facility ID Number 1.0 Executive Summary The CIT-CON Oil Corporation, has a long standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as the training of personnel, investing in "state of the art" process management systems and the application of inherently safer designs in the installation, operations 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 fully equipped and trained personnel will respond to control and contain the release. 2.0 Description of the Stationary Source and Regulated Substances The CIT-CON Oil Corporation, located in Lake Charles Louisiana, USA, operates a variety of processes which converts partially refined feedstock to produce various lubricating oils and waxes. 3.0 Hazard Assessment Results The CIT-CON Oil Corporation ha s a toxic worse case scenario determined from regulated substance in Program 3 process. The worse case toxic is defined as a liquid release of 18,000 lbs of ammonia from a drum, when filled to the greatest amount allowed results in a toxic cloud release which reach an offsite endpoint and since the facility is located in a populated area, also reaches public receptors. Although CIT-CON Oil Corporation has numerous controls to prevent such release and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this scenario. The alternative toxic case scenario is ammonia, which is considered a program 3 process. The ammonia alternate case scenario is modeled after pipe leak resulting in a toxic cloud release of 7300 lbs. of ammonia which reach an offsite endpoint and since the facility is located in a populated area, also reaches public receptors. These scenarios are based on the use of the active mitigation of the leak, and the response of the appropriate emergency personnel / equipment to the alternate case scenario scenes. The worse case scenario from a program 3 process associated with a release of flammable substances at the facility is a vapor cloud explosion involving 255,000 lbs of propane in a process drum which reach offsite endpoint and since the facility is located in a populated area, also reaches public receptors. No administrative controls are in place per the appropriate part or rule to limit the storage inventory in the vessel; therefore the full tank inventories of each regulated substances is assumed released, completely vaporize, and ignite resulting in a vapor cloud explosion. Although CIT-CON Oil Corporation has numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating these worse case scenario. The alternate case scenario from a program 3 process for flammabl e substances at the CIT-CON Oil Corporation is a vapor cloud explosion resulting from the release of propane from a pipe leak. Approximately 800 lbs are released which reaches an offsite endpoint and since the facility is located in a populated area, also reaches public receptors. These scenarios are based on the use of the administrative and engineered controls, active mitigation of the leak, and the response of the appropriate emergency personnel / equipment to the alternate case scenario scenes. The toxic release scenario and the flammable scenario are selected as being practical scenarios for use in emergency planning and response Under the Louisiana Department of Environmental Quality Title, the application of a "General Duty Clause" is included within the enforcement of the EPA "Accidental Release Prevention" program. The CIT-CON Oil Corporation explored all other regulated substances as required by the part or rule. Additionally, there are amounts of hydrogen sulfide pres ent within some processes; however are below the threshold quantity requirements. The same process vigilance and response capabilities are ready to mitigate any release of these additional regulated substances within or outside the limits of our facility. 4.0 Five Year Accident History The CIT-CON Oil Corporation has an excellent record of accident prevention over the past 5 years; the frequency being consistently low with efforts to reduce or eliminate all accidental releases from the stationary source. The CIT-CON Oil Corporation has had very few excursions of toxic or flammable releases of regulated substances and have not issued a shelter in place within the past 5 years. The facility investigates every incident very carefully to determine ways to prevent similar incidents from occurring. From June 21, 1994 to June 21, 1999, CIT-CON Oil Corporation has no accidents involving RMP covered processes and meeting the criteria set forth in the EPA regulation. 5.0 General Accide ntal Release Prevention Program Steps The following is a summary of the general accident prevention program in place at the CIT-CON Oil Corporation. Because processes at the facility are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program Employee Participation The CITGO Petroleum Corporation Lake Charles Manufacturing Complex's Facility 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 (PHA) team. Employees have access to all information created as part of the Facility Accident Prevention Program . Specific ways that employees can be involved in accident prevention program are document ed in an Employee Participation Procedure, maintained at the facility and addresses each accident program element. In addition, the facility has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process safety and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and facility management. Process Safety Information The CIT-CON Oil Company keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameter, specific chemical inventories, and equipment design basis / configuration information. Various departments within the facility are assigned responsibility for maintaining portions of process safety information.. Chemical specific information including exposure haz ards and emergency response / exposure treatment consideration, is provided in Material Safety Data Sheets (MSDS's). This information is supplemented by documents that specifically addresses known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g. temperature, level, composition) in key process parameter documents. The facility 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 facility also maintains numerous technical documents that provides information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical ratings of equipment, etc. This information, in com bination with written procedures and trained personnel provide 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 The CIT-CON Oil Corporation has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within the program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The CIT-CON Oil Corporation primarily uses the Hazards and Operability (HAZOP) analysis technique 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. The team identifies and evaluates hazards o f 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 a PHA findings is based on a relative risk ranking assigned by the PHA team. The 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 complete. 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 CIT-CON Oil Corporation periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted on 5 years intervals a nd 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. Operating Procedures The CITGO Petroleum Corporation Lake Charles Manufacturing Complex's Facility maintains written procedures that address various modes of process operation such as (1) initial startup of a new unit, (2) normal operations, (3) temporary operations (4) emergency shutdown, (5) normal shutdown and (6) unit startup. These procedures can be used as reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained current by revising them as necessary to reflect changes made through the management of change process In add ition, the CIT-CON Oil Corporation maintains a key process parameter documents which provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with the written operating procedures is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, CIT-CON Oil Corporation has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in the facility operations if they are not already familiar with such 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, skill demonstration) having adequate knowledge to perform the duties and tasks in a safe and r esponsible 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 testing 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 this training Contractors To complement the written procedures for process operations, CIT-CON Oil Corporation utilizes contractors to supplement its work force. Because some contractors work on or near process equipment, the facility 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 of their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform facility personnel of any haz ards that they find during their work or may introduce in the course of performing their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety & health hazards, (3) emergency response plan requirements, and (4) safe work practices before beginning their work. In addition, the CIT-CON Oil Corporation evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre Startup Review The CIT-CON Oil Corporation conducts a Pre Startup Safety Review (PSSR) for any new facility or facility modifications 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. This review provides one addition al check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The CIT-CON Oil Corporation 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 safe operating condition. The basic aspects of this program include (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality control measures. In combination, these activities from a system that maintains the mechanical integrity of the process equ ipment. 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 task in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. 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). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible) or a team and/or department will review the use of the equipment and determine what actions are necessary to ensure the safe operation of that equipment. Another integral part of the mechanical integrity program is quality assurance. The CITGO Petroleum Corpor ation's Lake Charles Manufacturing Complex Facility incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made Safe Work Practices The CIT-CON Oil Corporation has long-standing safe work practices in place to help ensure worker and process safety. Examples of this include (1) - control of the entry/presence/exit of support personnel, (2) - a lockout/tagout 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) - a 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 p rocess to help ensure that operations and maintenance activities are performed safely. Management Of Change The CITGO Petroleum Corporation Lake Charles Manufacturing Complex's Facility has a comprehensive system to manage change to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes to 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 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 CITGO Petroleum Corporation Lake Charles Manufact uring Complex's Facility promptly investigates all incidents that resulted in or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incidents or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to the facility management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHA's and PHA revali dations Compliance Audits To help ensure that the PSM/Accident Prevention Program part or rule is functioning properly, the CIT-CON Oil Corporation in conjunction with the Corporate Safety Group periodically conducts an audit to determine whether the procedure and practices required by the applicable PSM / Accident Prevention part or rule are being implemented. Compliance audits are conducted at lease every 3 years. The audit team can consist of a broad base of management and or hourly personnel from the facility or from other operating units of CIT-CON Oil Corporation and/or contract third parties. The audit team develops findings that are forwarded to facility management for resolution. Corrective actions taken in response to the audit team's findings are tracked until complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. 6.0 Chemical Specific Prevention Steps The processes at the CIT-CON Oil Corporation have ha zards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all of the Program 3 processes EPA RMP-covered processes at the CIT-CON Oil Corporation. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failure and (2) human error. In addition to the accident prevention program activities, the CIT-CON Oil Corporation has safety features on many of its units to help (1) contain / control a release, (2) quickly detect a release and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes. Release Detection 7 Hydrocarbon Sensors 7 Heat Detection heads and sensors Release Containment / Control 7 Process relief valves that discharge to a flare to capture and incinerate episodic releases 7 Valves to permit the isolation of the processes (manual and automatic) 7 Automated shutdowns for specific process parameters (e.g. high temperature, high level etc..) 7 Curbing or diking to contain liquid releases 7 Redundant equipment and instrumentation (e.g. uninterruptible power supply for process controllers, backup firewater systems. 7 Atmospheric relief devices Release Mitigation 7 Fire Suppression and Extinguishing Systems 7 Deluge system for specific equipment 7 Trained emergency response Personnel 7 Personal Protective Equipment 8.0 Emergency Response Program Information The CIT-CON Oil Corporation maintains a written emergency response program, which is in place to protect public safety, worker safety and 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 reponse, 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. In addition, the CIT-CON Oil Corporation has procedures that address maintenance, inspection and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The overall emergency response program for the CIT-CON Oil Corporation is coordinated with the Calcasieu Parish, LA Local Emergency Planning Committee (LEPC). The CIT-CON Oil Corporation has around-the-clock communication capability with appropriate LEPC officials and emergency response organizations (e.g., fire departments). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In additi on to periodic LEPC meetings, the CIT-CON Oil Corporation conducts periodic emergency drills that involve the LEPC and emergency response organizations. 7.0 Planned Changes to Improve Safety The CIT-CON Oil Corporation resolves all findings from PHA's, some of which result in modification to the process. The following types of changes are planned. 7 Decrease in process chemical inventories where feasible 7 Improve ammonia detection 7 Improve mitigation capacity, both fixed and mobile |