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.
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