American Refining Group - Executive Summary |
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EXECUTIVE SUMMARY FOR ARG ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At American Refining Group Inc., Lubricant and Specialty Products Division, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility produces Lubricants, Specialty Solvents, and Gasoline using a variety of chemicals and processing operations. The Lubricant and Specialty Product division includes a refinery which consists of a Crude Unit, Platformer, ROSE Unit, Extraction Unit, MEK Unit, Bulk Loading and Tank Farm. In our ROSE and MEK processes, we use the following chemical that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: RMP-regulated flammable chemicals , quantities handled/stored, and at the facility Propane MEK UNIT - propane is stored in D-23 vessel (60,000 lbs) at MEK Propane is used for chilling the products charged at the MEK for dewaxing ROSE UNIT - propane is unloaded from trucks to E-1 storage vesse (121,000lbs)l at ROSE unit. Propane is used to extract light ends from cylinder stock charge. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst Case release scenario(s)--Regulat ed Flammable Chemicals MEK - propane vessel splits dumping 60000 lbs of propane instantaneously Propane release - full vessel 60000 lbs Estimated exposure distance 0.32 miles No administrative controls or mitigation measures were used Recepters-residences, public recreational areas, commercial, office and industrial area Temperature of D-23 was ambient ROSE unit - Failure of propane storage vessel E-1 Propane resease - full vessel 121,000 lbs Estimated exposure distance 0.4 miles No administrative controls or mitigation measures were used Temperature was above ambient Recepters-residences, public recreational areas, commercial, office and industrial area Alternative Release Scenario(s) - Regulated Flammable Chemicals The Propane vessel E-18 user side (at MEK) suction line rupture- one inch leak - duration 13.2 minutes Propane release- 20000 lbs Estimated exposure distance 0.06 miles Temperature of E-18 was above ambient No administrative controls or mitigation measures we re used Receptors involved- residences We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Propane sensors installed at MEK and ROSE Documented unloading procedures for Propane Sensor for Propane in cooling water leaving ROSE unit Preventative maintenance checks on MEK Propane compressor Preventative maintenance program for critical pumps at MEK and Rose units These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: We have had no accidental releases of under EPA,s RPM rule in the past five years. EMERGENCY RESPONSE PROGRAM We maintain an Emergency Response Plan, which consolidates state, and local regulatory requirements for emergency response planning. Our facility maintains volunteer emergency response teams for responding emergency situations. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: American Refining is proactive in Environmental and Safety/Health within the company. We are continuously improving our procedures and equipment. We also use audits/hazop's and inspections of equipment to aid in improving the Environmenal/Safety/Health of our employees. |