Caribbean Petroleum Refining Limited Partnership - Executive Summary
Executive Summary |
Caribbean Petroleum Refining Limited Partnership
Bayamon Refinery - Risk Management Plan
Facility description and the regulated substances handled.
Caribbean Petroleum Refining Limited Partnership owns and operates an oil refinery in Bayamon, Puerto Rico. Caribbean Petroleum Refining L. P. enjoys a unique position on the island of Puerto Rico - that of not only operating its own refinery but also operating its own retailing outlets across the island (250 service stations), owning an oil dock, and having pipelines connecting the refinery to the Puerto Rico Electric Power Authority and all major marketers' bulk terminal facilities.
Caribbean Petroleum Refining Limited Partnership operates the Bayamon, Puerto
Rico, Refinery. The Bayamon Refinery has a capacity of 48,000 barrels of crude oil per day. The refinery currently employs about 200 people. Inside the refinery the following units process the crude oil stream into the various products for distribution and sale:
1. Two crude processing units.
2. Vacuum unit.
3. Gasoline Stabilizer unit.
4. Fluid Catalytic Cracking unit.
5. Gas concentration unit.
6. Poly unit.
7. Deethanizer and Propane-Butane Splitter units.
8. Platformer and Pre-Treating unit.
9. Gulfining unit.
10. Merox Treating unit.
11. Amine unit.
12. Sulfur Recovery and Tail Gas Treating units.
13. Storage tanks for the various intermediates and products.
April of 1995 the refinery stopped processing crude oil due to market conditions. The refinery recommenced processing crude oil in May of this year (1999) once the fuel market improved. The refinery does not have an HF Alkylation unit nor does it use chlorine as the primary biocide at the cooling tower, and, hence, there are no toxic chemicals in quantities that are covered by the Risk Management Plan regulation. Toluene is not refined separately and stored as a product. It exists only as a minor component of the gasoline produced at the refinery and, hence, is not reportable under the RMP regulations.
The refinery does, however, produce and store propane and butane in a number of smaller bullets and one butane sphere and, thus, has covered flammable materials above the threshold quantity of 10,000 Lbs. The quantities of methane and ethane are below the threshhold quantities.
The flammable worst case scenario to be reported is the scenario of the release of the butane sphere con
tents and a subsequent vapor cloud explosion at or near the butane sphere. This was chosen as the worst case scenario because the butane sphere is the largest single vessel which contains the flammable liquid under pressure.
The flammable alternate case scenario to be reported is that of a rupture of a 2" LPG (butane) truck loading hose at the LPG truck loading island near the West property line of the refinery. This alternate (or more likely) case scenario was chosen because of its proximity to the property line and the fact that if it should occur, the consequence would have some limited offsite impact.
A third alternate case scenario was calculated - the scenario of the loss of containment of an entire butane bullet (filled to a level of 80%) over a ten-minute period and subsequent vapor cloud explosion. This scenario when calculated using RMP*Comp had an affected radius of 0.2 miles; however, due to the location of the storage bullets approximately in the center of the facil
ity, this distance was still within the property lines of the facility. Thus, this scenario did not have an off-site impact.
The accidental release prevention and emergency response policies at the refinery.
Caribbean Petroleum Refining Limited Partnership has developed an overall safety and health policy to prevent accidental releases of flammable materials to the environment. This policy is supported by many programs such as, the compliance with OSHA's 1910.119 Process Safety Management regulation which includes communication of risks and hazards to the employees and contractors, the development of an employee training and retraining program with written operating procedures. Since the refinery is subject to 29 CFR 1910.119, it qualifies as a Program 3 facility under the EPA's Risk Management Plan regulation.
The refinery management also stresses the development and documentation of the process safety information, a management of change procedure, prestart-up safety reviews, e
mployee participation in safety reviews and an equipment mechanical integrity inspection program for all major equipment items and piping systems, as well as, new equipment purchases. The refinery operations personnel also issue Hot Work Permits and Cold Work Permits for maintenance activities within the operating units.
The refinery also conducts the following safety inspections on the basis as noted:
1. Work areas - weekly.
2. Portable fire extinguishers - monthly.
3. Fire protection system - every 2 months.
4. Boilers - annually.
5. Pressure vessels - every 5 years, or as required by API RP 510.
6. Extension cords, motorized hand-tools - every 3 months.
7. Yards, parking lots, roofs, etc. - annually.
8. LPG storage vessels - annually.
Compliance audits are also conducted every three (3) years as required by OSHA's CFR 191
0.119 regulation. In addition, incident investigations are conducted immediately after any accidental release or incident occurs. The root cause of the incident is determined and appropriate steps are taken to prevent recurrence of the event.
The refinery also has an emergency response plan in the event of a release of a flammable material. There is an employee staffed emergency brigade which can be mobilized rapidly should a release occur and subsequently develop into a fire. The emergency brigade is well trained and practices annually at the on-site training area. Once per year, the emergency brigade chief and several members are sent to the Texas A & M Fire Fighting Training Center for additional training in fire fighting techniques. The following provide back-up support for the plant emergency brigade:
1. Bayamon Fire Department.
2. Catano Fire Department.
3. San Juan Fire Department.
Nuevo Fire Department.
In addition to the emergency brigade, the refinery has a deluge system installed at the sphere with spray nozzles at numerous points around the upper hemisphere of the butane sphere. Also, at the LPG truck loading station there are two (2) fire monitors, as well as, four (4) area combustible gas detectors that alarm in the immediate area when there has been a release of either propane or butane
The refinery engineering staff also follows and adheres to guidelines set forth in American Petroleum Institute (API) standards and recommended practices, National Fire Protection Association (NFPA) codes for fire protection systems, National Boiler Inspection Codes (NBIC) for fired boilers, the American Society of Mechanical Engineers (ASME) pressure vessel and piping codes, and the National Electric Codes for flammable environments.
The worst-case and alternate case release scenarios.
The worst case release as defined by the RMP regulation is the release of the ent
ire contents of the butane sphere (at the 80% level) over a ten (10) minute period with a subsequent vapor cloud explosion as the flammable vapor cloud finds an ignition source. This worst case scenario was chosen because the butane sphere is the single largest vessel which contains a flammable liquid under pressure.
The refinery has administrative (procedural) controls established to prevent the filling of the butane sphere above the 80% level.
For the alternate release scenario, the refinery has chosen the rupture and subsequent vapor cloud explosion of a 2" hose at the LPG loading station for the alternate case scenario. This choice was made since the LPG loading station is located near the West property line of the facility and the consequence of this scenario would have an offsite impact.
A third alternate case scenario was calculated - the scenario of the loss of containment of an entire butane bullet (filled to a level of 80%) over a ten-minute period and subsequent vapor c
loud explosion. This scenario when calculated using RMP*Comp had an affected radius of 0.2 miles; however, due to the location of the storage bullets in the center of the facility, this distance was still within the property lines of the facility. Thus, this scenario did not have an off-site impact.
The general accidental release prevention program and chemical specific prevention steps.
Caribbean Petroleum Refining Limited Partnership has implemented numerous procedures to ensure the safety and well being of its employees and the general environment surrounding the refinery. The process units and storage tanks have been inspected and repaired or rebuilt as necessary prior to the introduction of hydrocarbons into the refinery. During the period of December 1998 through January 1999, the refinery staff performed a thorough, prestart-up safety analysis of each unit using a HAZOP-based methodology.
Since the refinery is an OSHA covered facility, the various units have undergone th
e initial Process Hazards Analysis (PHA). The initial PHAs and subsequent safety analyses included employee participation at the unit operator level.
The refinery has a policy of periodic mechanical integrity inspections, depending on the type of equipment and as based on the applicable American Petroleum Institute Codes and Recommended Practices. The safety relief valves that protect vessels, tanks and piping systems, are integral parts of this program. The last mechanical integrity inspection of the butane sphere was conducted on September 7, 1998, per American Petroleum Institute Code 510 and Recommended Practice 572. The next inspection is scheduled to be performed in September of this year.
The refinery also has a facility-wide fire protection system with emphasis on the areas of the refinery where releases and subsequent fires are more likely to develop. The fire protection system is also tested on a periodic basis. The fire protection system has two firewater pumps one d
riven by a gasoline engine and the other driven by a diesel engine. Firewater is stored in a tank with a capacity of 1,050,000 gallons of fresh water.
The refinery also operates and maintains a foam truck which is used to disperse a water and foam mixture on existing fires or on released flammable liquids to prevent their ignition.
The butane sphere and the smaller propane and butane bullets are specifically protected by deluge systems that are remotely and manually operated in the event of a fire.
The five year accident history.
With the fact in mind that the refinery did not process crude oil from April of 1995 to May of 1999, the five year incident history encompasses only the time period from May of 1994 through April of 1995 and May of 1999. During this time period the refinery did not produce any propane or butane.
The refinery had no releases of covered flammable materials within the last five (5) year period.
The emergency response program.
The Caribbean Petroleum Re
fining L. P. emergency response plan is designed to address the refinery's main hazard - the hazard of fires and/or explosions. The response plan covers office-building fires specifically during working hours and outside of working hours on weekdays, weekends and holidays. The responsibilities for various functions during the emergency are clearly defined in the response plan. Gathering places for employees evacuated from the office building by the fire are also listed.
The emergency response plan also addresses fires that occur in the refinery away from office buildings. The response plan contains reporting procedures for employees when the fire is too large to be extinguished by a portable handheld fire extinguisher. At that point the fire alarm is sounded by the security guard at the gate which mobilizes the shift supervisor, the assistant shift supervisor and the company-staffed emergency brigade. The shift supervisor and/or his assistant assess the situation and decide whet
her to call for additional assistance (the Puerto Rico Fire Department) and whether to call for a partial or total evacuation of the plant.
A Command Center is established where key personnel summoned by the security guard will direct the emergency response efforts. The emergency brigade reports to the security building and prepares to fight the fire. Access to the refinery is tightly controlled by the security guard at the gate. All visitors are escorted to safety by the employee in charge of the visitor. Fire fighting efforts are coordinated with the Puerto Rico Fire Department if they have been called. The Shift Supervisor and emergency brigade advise and work with the Puerto Rico Fire Department to control the situation.
After the fire has been extinguished, the plant alarm is used to signal the all clear. In order to maintain the necessary skills, the emergency brigade practices fire fighting techniques on a semi-annual basis. Fire drills (announced and unannounced) in th
e plant are held at a frequency of two (2) drills per year.
Planned changes for improved safety.
The refinery has plans to install flammable gas detection instrumentation around the perimeter of the propane and butane storage bullets and spheres. These would provide the operators with 24-hour monitoring of the area for flammable gas releases.