PVD Midwest Refining, LLC - Executive Summary |
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Refinery Risk Management Plan: Executive Summary Accidental Release Prevention and Response Policies The CITGO Petroleum Corporation Lemont Refinery believes that Safety, Environmental Stewardship, and being a good corporate neighbor are core business values. To demonstrate these values substantial resources have been invested into the refinery in accident prevention. It is our policy to include accident prevention in every part of our business, design, operations, and maintenance systems. However, if a release should occur, substantial resources (trained response personnel and equipment) will respond to control and contain the release. Description of the Stationary Source and Regulated Substances The CITGO Petroleum Corporation Lemont Refinery operates a variety of processes to produce petroleum products from raw crude oil. The refinery has several regulated flammable products, such as propane, butane, etc. In addition, the refinery uses Hydrogen Fluoride and Ammonia in pro cesses to produce consumer hydrocarbon products. Hazard Assessment Results The Worst-Case Release (WCS) Scenario for toxic substances in the refinery is assumed to be the rupture of one of the Rapid Deinventory (RADI) System Drums, which contains Hydrogen Fluoride. Up to 272,000 lb. of HF is transferred to each RADI drum during emergencies and during maintenance turnaround (approximately 30 days every 4 years). Although numerous controls to prevent such release and manage their consequences exist, no credit for administrative controls or mitigation measures were taken into account in evaluation of this scenario. The maximum distance to the level of concern of 30 PPM was determined. EPA's Offsite Guidance Analysis Document was used to calculate the distance. The Worst-Case Release (WCS) Scenario for flammable substances in the refinery is assumed to be the rupture of one of the Isobutane Storage Spheres. The sphere contains 2,800,000 lbs. of Propylene/Butlylene. Although numerous controls to prevent such release and manage their consequences exist, no credit for administrative controls or mitigation measures were taken into account in evaluation of this scenario. The maximum distance to the level of concern of 1 psi for this WCS was calculated. EPA's Offsite Guidance Analysis Document was used to calculate the distance. The alternate release scenario (ARS) for HF assumes that a line is sheered from the Acid Settler Rerun line. After release, HF Detection would immediately detect and alarm to the unit operators. It is assumed that for this size of a release, it would take 1.5 minutes for the operators to react, start the water curtains and water cannons, and for them to become fully operational. After the water curtain was activated and the water cannons were trained in on the leak, the HF release would be assumed to be mitigated. After 5 minutes all HF would be transferred to the RADI system. At this time, the emergency would effectively be over. The maxim um distance to the level of concern of 30 PPM for this ARS was calculated. The ARS for Ammonia assumes the release of ammonia from a hole/tear/connection leak in the loading hose. Operations personnel at the ammonia tank would call a release and summons the fire brigade. A fire brigade member in SCBA would isolate the emergency isolation valve on tank discharge line. The total time to mitigate these types of events is estimated to be between 10-20 minutes. The maximum distance to the level of concern of 200 PPM for this ARS was calculated. The ARS for flammable substances at the refinery assumes that in the pressurized product storage area, the pump seal for the Isobutane Produc t Pump fails and releases liquid Isobutane to the atmosphere. Hydrocarbon gas detectors in the area would detect the hydrocarbon and transmit an alarm to operations w/in one-minute. Operations would summon the fire brigade. The pumps would be shutdown and isolated by the fire brigade and operations. The total time to mitigate these types of events is estimated to be between 10-20 minutes. During this event, the released vapors could travel offsite and a flash fire could occur. The resulting radiant heat exposure area of 5 KW/M2 was calculated. General Accidental Release Prevention Program The following is a summary of the accident prevention program in pace. The Lemont Refinery is designed to be safe as well as operate safely. Our Accident Prevention Program is a structured program, emphasizing management controls. The Program contains different elements, which are highly structured and are purposefully redundant. They are intended to prevent releases and/or minimize the consequ ences of a release should one occur. Employee Participation The Refinery has a written plan to encourage employee participation in its prevention program. All plant employees are to have their ideas and suggestions considered. Employees give input into the program in many different ways; some of these include: Process Hazard Analysis participation, Member of Accident Investigations, writing and reviewing Operating Procedures, developing Unit Specific Training requirements, Safe Practice Standard Committee Membership, etc. Process Safety Information The foundation for safe plant operations is the knowledge of how it is designed, and how it should operate. This knowledge must provide for identifying and understanding the hazards of the chemicals and processes of the plant. It is required that this knowledge be documented. Process Safety Information comprises three categories: 7 Hazards of materials 7 Technical information 7 Equipment design information This information is made av ailable to all employees of the refinery. Process Hazard Analysis The Refinery conducts a Process Hazard Analysis on each operation within the plant. These analyses identify and evaluate the operational hazards, and analyze what protective measures are in place to control them. From these analyses, it is then determined what additional actions can be taken to improve the safety of the process. The Hazard Analysis Team then makes recommendations to improve the process. The recommendations are reviewed by Management, scheduled for implementation, or further study. A management system is in place to ensure the recommendations are dealt with in a timely manner. Employees are informed about what actions are taken to resolve the findings and recommendations of the studies. Operating Procedures Operating procedures that clearly and completely describe how to safely start-up, operate, temporary operate, and shut-down are maintained. These procedures address the steps for each operatin g phase, operating limits, safety and health considerations, and safety systems and their functions. Training Operators are trained in the specific procedures required to operate their process unit. Refresher training is required every three (3) years. The Refinery ensures and documents that the training has been received and understood by the employee. Records documenting both the performance and effectiveness of the training are maintained. Contractors The Refinery considers contractors' safety programs and performance when hiring them. Contractors are informed about the hazards, safety requirements and emergency action plans. Contractor employees are required to know how to do the job safely. Contractor employers are required to ensure that the plant's safety rules are being followed. The refinery audits the contractors to ensure they are meeting the requirements. Pre-Startup Safety Reviews The Refinery performs a Pre-Startup Safety Review(PSSR) for new facilities and/ or modified facilities when the modification is significant enough to require a change in the process safety information. This element of the program closely tied to the Management of Change program. The PSSR confirms that: 7 Construction and equipment meet design specifications; 7 All procedures are in place; 7 A safety review has been completed and all recommendations have been resolved or implemented; and 7 Training has been completed. Mechanical Integrity The Refinery maintains plant equipment in good operating condition. In addition to repair, the plant has a Preventive Maintenance schedule for tests and inspections, conduct those tests and inspections, and repair any deficiencies that are found. The Preventive Maintenance Program follows manufacturers' recommendations, or good engineering practices. The refinery Mechanical Integrity Program ensures that any new equipment meets design requirements and was installed properly before it is placed in service. The refinery also ensures that spare parts and other maintenance materials are the correct ones for the job. Safe Work Practices The Refinery has many safe work practices that govern many aspects of operations and maintenance of the facility. These practices are designed to ensure that all work in the refinery is completed safety. Examples include the refinery's general Safety Manual, Safe Work Permits, Hazardous Energy Control, Hot Work Procedure, Confined Space Entry, Fall Protection, Respiratory Protection, etc. and many more. Employees are trained on these practices and they are strictly enforced for any work in and around the refinery processes. Management of Change The Refinery has a written procedure for managing changes that occur in the processes. The procedure requires a technical and safety review, making needed operating procedure changes, and a management authorization for the changes. When changes are made, all effected employees are to be trained in or informed of the change, and equipment information and other process safety information is updated to document the change. Incident Investigation Whenever an incident or accident occurs that caused, or might have resulted in a release of toxic/flammable material, fire or explosion, environmental loss, or personal injury, it is promptly investigated. The objective of the investigation is to determine the root cause(s) that lead to the incident and take appropriate action to prevent their reoccurrence. The Refinery uses a team investigation approach includes 2-6 people (including contractors if necessary) from many related disciplines that ensures that best technical recommendations are taken. Management systems are in place to ensure that recommendations are reviewed by management and promptly implemented. Compliance Audits The Refinery performs an audit every three (3) years to ensure compliance with all elements of the OSHA Standard. This audit is preformed by an outside entity (Corporate or Contracto r). If non-compliance is discovered, then any deficiencies in procedures and/or practices are corrected. In addition to regulatory required audits, refinery management is constantly reviewing and testing all PSM programs and Safety Practices to ensure that they are followed and in good standing. 5 - Year Accident History The Lemont Refinery has an excellent record of accident prevention over the last 5 years. While minor releases of regulated chemicals have occurred, in the last 5 years no release was large enough to have an offsite impact. Emergency Response Program Information The refinery maintains a Refinery Emergency Plan that ensures that all incidents are properly planed for and dealt with. This plan includes procedures for organization and administration of emergency response resources for any size event that occurs in the refinery. It details specific duties and responsibilities for emergency responders and incident management. The plan includes procedures for no tification of Local Responders, the Local Emergency Management Agency, as well as State and Federal Agencies. The plan includes procedures for responding to fires and releases of toxic materials, incident assessment and mitigation, evacuation, hazardous material cleanup, and emergency medical information. The Refinery employees trained and certified Emergency Response and Medical Professionals that are at the facility 24 hours a day. In addition, numerous shift operations personnel are trained to respond and mitigate incidents. The Refinery maintains numerous pieces of emergency response equipment from fire trucks to hazardous material response vehicles and equipment. It also maintains a state of the art firewater system that can supply ample firewater for fire and toxic vapor release mitigation. The Emergency Response Program is coordinated with the Will County Emergency Management Agency and the Will County LEPC. The plan is also coordinated with the Lemont and Romeoville Fi re Departments (local responders). Periodically, response training and coordination is conducted to ensure the refinery response organization and local responders are familiar with each others emergency response procedures and systems. Planned Changes to Improve Safety Through the Prevention Program Process the refinery is continually looking for and implementing changes that improve the safety of the process. The following are some of the planned changes to improve process safety: 7 Install Remote Isolation for Light Hydrocarbon Pumps 7 Install Hydrocarbon detectors around LPG Storage Area 7 Analyze reliability and improve Safety Shutdown Systems 7 Install Secondary Seals (Release Containment) 7 Firewater System Improvements |