Berry Petroleum Company - Executive Summary |
|
EXECUTIVE SUMMARY Berry Petroleum Company Stephens, Arkansas Accidental release prevention and emergency response policies At the Berry Petroleum Company, we handle 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. We at Berry Petroleum Company are strongly committed to employee, public, and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such 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 Stephens 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 Berry Petroleum Company uses atmospheric distillation to separate crude oil into asphalt, diesel fuel, jet fuel, and two grades of naphtha - LSR heavy and LSR light. The asphalt, diesel fuel, and jet fuel are not regulated under 40 CFR 68. The LSR heavy and LSR light are regulated under 40 CFR 68 as a result of being mixtures containing regulated chemicals and the flash points and boiling points are less than 730F a nd 1000F, respectively. Transfer pumps are used in the product transferring process between the storage tanks and truck transports. Access to the site is restricted to authorized facility employees, authorized management personnel, and authorized contractors. The regulated substance handled at the Berry Petroleum Company is pentane and propane. The maximum quantity of pentane that can be stored at this facility is 1,000,000 pounds in three 41,000-gallon storage tanks and one 78,000-gallon storage tank. The maximum quantity of propane that can be stored at the facility is 37,000 pounds in one 10,500-gallon aboveground storage tank. 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. Berry Petroleum Company worst-case release scenario would result in a release of 400,000 pounds of pentane. To evaluate the worst-case release scenario, we have utilized RMP*Comp, the EPA recommended software. Based on 400,000 pounds of pentane released, the distance the affects of a vapor cloud explosion is expected to have no serious harm to the general public is 0.6-mile from the location of the storage tank. According to RMP regulations, an analysis is required on one flammable substance with the greatest endpoint distance . RMP*Comp results indicate a worst-case release of 37,000 pounds of propane has a hazard endpoint distance of 0.3-mile. Therefore, analysis is only required on pentane since the endpoint distance is greater. 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 pentane between a truck transport and a storage tank. The flexible transfer hose has a nominal diameter of 3-inches. Excess flow valves at the truck transport function to stop the flow of pentane out of the truck transport. In this alternative release scenario, 20,600 pounds of pentane would be released before facility personnel could implement actions to stop the release. RMP*Comp modeled the distance e ndpoint for the release of 20,600 pounds of pentane to no longer pose a hazard to the public as 0.1-mile. The general accidental release prevention program and the specific prevention steps Our Berry Petroleum Company complies with the Occupational Safety and Health Administration (OSHA)'s Process Safety Management (PSM) rule, EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Berry Petroleum Company maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the refinery processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensu re that the hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is a "What if" checklist. The studies are undertaken 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 For the purposes of safely conducting activities within our processes, Berry Petroleum Company 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 processes Training Berry Petroleum Company has a comprehensive training program to ensure employees are competent in the ope rations and procedures associated with the processes. Mechanical Integrity The refinery carries out highly documented 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. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. 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 Berry Petroleum Company 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 safet y reviews related to new processes and to modifications in established processes are conducted as a regular practice at Berry Petroleum Company. 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 The refinery 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 Berry Petroleum Company promptly investigates any incident that resulted in, or could reasonably result in a catastrophic release of pentane or propane. 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 r eports are retained for a minimum of five years. Employee Participation It is our belief at Berry Petroleum Company, that process 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, Berry Petroleum Company hire 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 processes. Contractors are also informed of emergency response procedures should an accidental release occur. Five-year accident history The Berry Petroleum Company has an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no accidental release of pentane or propane during this period that resulted in deaths, injurie s, or significant property damage onsite, or known deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency response program The Berry Petroleum Company has a written emergency response program, in accordance with OSHA standard 29 CFR 1910.119. The program 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 affect areas. Planned changes to improve safety Safety improvement is an on-going process at the Berry Petroleum Company. Periodic evaluations are preformed to assess the maintenance of safe conditions. There are no additional specific safety recommendations for implementation at this time. |