Rogas - Executive Summary |
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EOTT Energy Operating Limited Partnership (EOTT Energy) acquired the Rogas Facility on December 1, 1998. The Rogas Facility is a Liquefied Petroleum Gasoline (LPG) storage and transfer facility. The process is regulated by Cal OSHA Process Safety Management of Acutely Hazardous Materials, Title 8 California Code of Regulations 5189. The facility has implemented the prevention program described below. EOTT Energy has a commitment to employee and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in design, installation, operation, and maintenance of covered processes. EOTT Energy's policy is to implement reasonable controls to prevent foreseeable releases. However, if a release does occur, trained personnel will respond to control and contain the release. The prevention program is based on 40 CFR Part 68 and Title 19 CFR 2735 and includes the following: Employee Participation, Proces s Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractor Evaluation, Contractors and Visitor Orientation, Pre-Job Start-Up Review, Mechanical Integrity, Code of Safe Work Practices (Hot Work Permit, Confined Space Entry, Control of Hazardous Energy), Management of Change, Incident Investigation, Emergency Planning and Response, and Compliance Audits. Planned changes to improve safety have been established based on compliance with the process safety management audits and revalidation of the process hazard. Training includes employee responsibilities in the process safety management program, emergency response, hotwork permit procedure, code of safe work practices, and operating procedures. The facility stores and unloads natural gasoline. There are 2 tanks with a capacity of 30,000 and 20,000 gallons respectively. The tanks are administratively controlled to hold liquefied petroleum gasoline at 90% maximum capacity; therefore the worst case flammabl e scenario is based on a 27,000 gallon release. EOTT ENERGY CORP Operating Limited Partnership maintains an emergency response plan in compliance with local emergency response agencies. The Rogas Facility has a Hazardous Materials Business Plan on file with the Kern County Environmental Health Department - Certified Unified Program Agency. In the event of an accidental release, the facility operators are trained to shut off the source from a safe location or activate one of the emergency shutdown devices, contact 9-1-1 and secure the area. The 9-1-1 system is used to notify the Fire Department. Based on the criteria set forth 40 CFR 68.10 and 19 CCR 2735.4, this facility has not had an accidental release. This information was verified by the reviewing of records from the Kern County Environmental Health Department - Certified Unified Program Agency. The worst case release scenario is based on the Environmental Protection Agency Offsite Consequence Analysis Guidance equations an d model. The worst case scenario and alternate release scenario were based on n-butane as the modeled substance. The facility stores and transfers primarily natural gasoline, of which n-butane is a component. The worst case release of 135,110 lbs of liquefied petroleum and indicates a 1 psi overpressure distance of 0.41 miles. This distance impacts public receptors of an adjacent farm, chemical storage facility and a resident population of 22. In addition, although there are numerous controls in place, no credit was taken into account for evaluating the worst case scenario. The Alternative Release Scenario for this process is a break in railcar transfer hose connection. This scenario could result in release of 180 lbs of liquids over a 10 minute period. The maximum distance for this scenario is 0.05 miles. While no other mitigation measures were taken into account in evaluating the alternative release scenario, the process does have relief valves, check valves, manual shutoff val ves, automatic shutoffs, startup and operating procedures, grounding equipment, and excess flow devices. The facility operator is in attendance during transfer operations. The engineering and administrative controls in place have been established to reduce the risk of an accidental release of identified hazards. EOTT Energy is committed to operations which are safe for employees and the surrounding community. |