Claiborne Energy - Executive Summary |
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EXECUTIVE SUMMARY Claiborne Energy, LLC Claiborne, Alabama Accidental Release Prevention and Emergency Response Policies Claiborne Energy handles flammable substances considered hazardous by the U.S. Environmental Protection Agency (EPA). It is necessary to observe certain safety precautions in handling flammable substances to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of our community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends on the manner in which we handle flammable substances combined with the safety devices inherent in the design of the facility combined with the safe handling procedures that we use and the training of our personnel. Claiborne Energy is committed to employee, public, and environmental safety. This commitment is demonstrated by our accidental release prevention program that covers areas s uch as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If an accidental release should occur, the facility is prepared to work with the Mexia Fire Department, and other authorities, to mitigate any release and minimize the impact of the release to people and the environment. Facility Description and Regulated Substances Handled Claiborne Energy fractionates liquefied petroleum gas into natural gasoline, butane, iso-butane, and propane. Transfer pumps are used to transfer feedstocks and product between the storage tanks and truck transports. Access to the facility is restricted to authorized facility employees, authorized management personnel, and authorized contractors. However, a trucking company is co-located on the same property as the facility. The regulated substances handled at Claiborne Ene rgy are butane, iso-butane, and propane. The maximum quantity of butane that can be stored at this facility is 460,000 pounds. The maximum quantity of iso-butane that can be stored at this facility is 350,000 pounds. The maximum quantity of propane that can be stored at the facility is 440,000 pounds. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario The EPA defines worst-case release scenario as the failure of our largest storage tank when filled to the greatest amount allowed. The entire contents of the tank are assumed to release as a vapor cloud, which finds an ignition source. Ten percent of the released quantity is assumed to participate in the resulting explosion. The worst-case scenario as defined by the EPA is highly unlikely to occur. During the evaluation, the scenario assumes none of the facility's mechanical controls or safety systems are operational, assumes no emergency response efforts take place, and assumes it occurs under the worst weather conditions. Claiborne Energy's worst-case flammable release scenario would result in a release of 230,000 pounds of butane. To evaluate the worst-case release scenario, we have utilized RMP*Comp, the EPA recommended software. Using RMP*Comp, the 1-psi overpressure distance endpoint for a vapor-cloud explosion resulting from the worst-case release of 230,000 pounds of butane is 0.5-miles. The EPA states an alternative release scenario as a release that is more likely to occur than the worst-case scenario and will reach an endpoint off-site. Active and passive mitigation systems may be considered for the alternative release scenario. The alternative release scenario deemed most likely to occur is the failure of a flexible transfer hose while transferring butane between a truck transport and a storage tank. The flexible transfer hose has a nominal diameter of 3-inches a nd a length of 20-feet. Excess flow valves would function to stop the flow of butane between the truck transport and the storage tank, thereby limiting the release to the contents contained within the hose. In this alternative release scenario, 110 pounds of butane would be released. Using RMP*Comp, the 1-psi overpressure distance endpoint for a vapor-cloud explosion resulting from the release of 110 pounds of butane is 0.02-miles. The General Accidental Release Prevention Program and the Specific Prevention Steps Claiborne Energy observes the Occupational Safety and Health Administration (OSHA)'s Process Safety Management (PSM) rule, EPA's Accidental Release Prevention Rule, and with applicable state codes and regulations. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Claiborne Energy maintains a record of safety information that describes the chemical hazards, oper ating parameters, and equipment designs associated with the regulated process. Process Hazard Analysis Our facility conducts studies to ensure the hazards associated with our process are identified and controlled efficiently. The methodology used to carry out these analyses is a "What if" checklist. The studies are conducted by a team of qualified personnel with expertise in engineering and process operations and are revalidated at least once every five years. Any findings related to the hazard review are addressed in a timely manner. Operating Procedures Claiborne Energy maintains written operation procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the process. Training Claiborne Energy has a training program to ensure employees are competent in the operations and procedures associated with the process. Mechanical Integrity Claiborne Energy carries out maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks include; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Claiborne Energy to manage changes in process chemicals, technology, equipment, and procedures. Process operators, maintenance personnel, or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a re gular practice at Claiborne Energy. The reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audit Claiborne Energy conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Claiborne Energy investigates any incident that resulted in, or could reasonably result in a catastrophic release of regulated chemicals. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All investigation reports are retained for a minimum of five years. Employee Participation It is our belief at Claiborne Energy, that pro cess safety management and accident prevention are a team effort. Our company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. Contractors Occasionally, Claiborne Energy hires contractors to conduct specialized maintenance or construction activities. We have a strict policy of informing the contractors of known potential hazards related to the contractor's work and the process. Contractors are also informed of emergency response procedures should an accidental release occur. Five-year Accident History There have been no accidental release of regulated or other chemicals during the last five years that resulted in deaths, injuries, or significant property damage onsite, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency Response Program The Claiborne Energy has a written emergency action plan, in accordance with OSHA standard 29 CFR 1910.38(a). The plan includes all aspects of emergency response including pre-emergency planning, employee training, adequate first aid and medical treatment, evacuations, notifications of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. Planned Changes to Improve Safety Safety improvement is an on-going process at Claiborne Energy. Periodic evaluations are performed to assess the maintenance of safe conditions. We will continue to work to improve our process safety and risk management programs. |