Lea Refining Company - Executive Summary |
|
General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Lea Refining 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. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Petroleum refining. We have 2 regulated substances present at our facility. These substances include Butane and Propane. Butane and Propane are distilled from the crude oil feed, stabilized, then transported offsite via pipeline as a combined stream. . The maxi mum inventory of Butane at our facility is 7701 lb. while Propane is present at our facility in a maximum quantity of 2300 lb. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the potentially impacted distances for each reported scenario. To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. This was selected as the basis for the calculations since it generally predicts distances on the high side as compared to more sophisticated models. Scenarios evaluated included both chemical-specific releases and releases of mixtures. The following paragraphs provide details of the chosen scenarios. Light Ends qualifies as a program level 1 process. In the worst case scenario for this process 5001 lb. of Flam. Mix.: Propane, Butane is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.14 miles is obtained corresponding to an endpoint of 1 psi overpressure. This distance is less than the distance to the nearest public receptor. Since this is a program level 1 process, no alternative release scenario is required. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The refinery has an active program in place to maintain compliance with the OSHA Process Safety Management (PSM) program. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Lea Refining Company maintains a detailed record of safet y information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What If or HAZOP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every five years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 5/16/97. Operating Procedures For the purposes of safely conducting activities within our covered processes, Lea Refining Company maintains written operating 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 Lea Refining Company has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity Lea Refining Company carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; 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. Furthermore, these personnel are offered specialized training as needed. 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 Lea Refining Company to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of management of change procedures was performed on 3/6/95. 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 regular practice at Lea Refining Company. The most recent review was performed on 3/3/97. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Lea Refining Company conducts audits on a r egular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 12/8/97. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Lea Refining Company promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. 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 reports are retained for a minimum of 5 years. Employee Participation Lea Refining Company truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our em ployees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors Our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Lea Refining Company has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Lea Refining Company has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Lea Refining Company has a written emergen cy response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Lea County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Lea Refining plans to continue improving and enhancing our already effective safety program. This established successful system is already in place to prevent and respond to accidental releases. Furthermore, no potential offsite consequences have bee n identified. Therefore, it is not surprising that no new courses of action have been identified by the Risk Management Plan. However, the ongoing process whereby Navajo reviews and evaluates new information will continue to result in ever improving refinements to our existing Safety Program. {\rtf1\ansi \deff4\deflang1033{\fonttbl{\f4\froman\fcharset0\fprq2 Times New Roman;}}{\colortbl;\red0\green0\blue0;\red0\green0\blue255;\red0\green255\blue255;\red0\green255\blue0;\red255\green0\blue255;\red255\green0\blue0; \red255\green255\blue0;\red255\green255\blue255;\red0\green0\blue128;\red0\green128\blue128;\red0\green128\blue0;\red128\green0\blue128;\red128\green0\blue0;\red128\green128\blue0;\red128\green128\blue128;\red192\green192\blue192;}{\stylesheet{\f4\fs20 \snext0 Normal;}{\*\cs10 \additive Default Paragraph Font;}}{\info{\author Don Whaley}{\creatim\yr1999\mo6\dy16\hr14\min12}{\version1}{\edmins2}{\nofpages0}{\nofwords0}{\nofchars0}{\vern49197}}\margl1440\margr1440 \widowc trl\ftnbj\aenddoc\hyphcaps0\formshade \fet0\sectd \linex0\endnhere {\*\pnseclvl1\pnucrm\pnstart1\pnindent720\pnhang{\pntxta .}}{\*\pnseclvl2\pnucltr\pnstart1\pnindent720\pnhang{\pntxta .}}{\*\pnseclvl3\pndec\pnstart1\pnindent720\pnhang{\pntxta .}} {\*\pnseclvl4\pnlcltr\pnstart1\pnindent720\pnhang{\pntxta )}}{\*\pnseclvl5\pndec\pnstart1\pnindent720\pnhang{\pntxtb (}{\pntxta )}}{\*\pnseclvl6\pnlcltr\pnstart1\pnindent720\pnhang{\pntxtb (}{\pntxta )}}{\*\pnseclvl7\pnlcrm\pnstart1\pnindent720\pnhang {\pntxtb (}{\pntxta )}}{\*\pnseclvl8\pnlcltr\pnstart1\pnindent720\pnhang{\pntxtb (}{\pntxta )}}{\*\pnseclvl9\pnlcrm\pnstart1\pnindent720\pnhang{\pntxtb (}{\pntxta )}}\pard\plain \qc \f4\fs20 {\b\fs32 General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities}{\fs24 \par }\pard {\fs24 \par \par }\pard \qj\fi-360\li360\sa120 {\b\fs28 1.\tab Accidental Release Prevention and Emergency Response Policies \par }\pard \qj {\fs24 We at Lea Refining Company are strongly commit ted 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 procedure s, 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. \par \par }\pard \qj\fi-360\li360\sa120 {\b\fs28 2.\tab The Stationary Source and the Regulated Substances Handled \par }\pard \qj {\fs24 Our facility's primary activities encompass Petroleum refining. We have 2 regulated substances present at our facility. These substances include Butane and Propane. Butane and Propane are distilled from the crude oil feed, stabilized, then transported offsite via pipeline as a combined stream. \par \par The maximum inventory of Butane at our facility is 7701 lb. while Propane is present at our facility in a maximum quantity of 2300 lb. \par \par }\p ard \qj\fi-360\li360\sa120 {\b\fs28 3.}{\fs28 \tab }{\b\fs28 The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the potentially impacted distances for each reported scenario. \par }\pard \qj {\fs24 To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. This was selected as the basis for the calculations since it generally predicts distances on the high side as compar ed to more sophisticated models. Scenarios evaluated included both chemical-specific releases and releases of mixtures. The following paragraphs provide details of the chosen scenarios. \par \par Light Ends qualifies as a program level 1 process. In the worst case scenario for this process 5001 lb. of Flam. Mix.: Propane, Butane is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.14 miles is obtained corresponding to an endpoint of 1 psi overpressure. This distance is less than the distance to the nearest public receptor. \par \par Since this is a program level 1 process, no alternative release scenario is required. \par \par }\pard \qj\fi-360\li360\sa120 {\b\fs28 4.\tab The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps \par }\pard \qj {\fs24 Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The refinery has an active program in place to maintain compliance with the OSHA Process Safety Manageme nt (PSM) program. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. \par \par }{\fs24\ul Proces s Safety Information}{\fs24 \par Lea Refining Company maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. \par \par }{\fs24\ul Process Hazard Analysis}{\fs24 \par Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled eff iciently. The methodology used to carry out these analyses is What If or HAZOP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every five year s. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 5/16/97. \par \par }{\fs24\ul Operating Procedures}{\fs24 \par For the purposes of safely conducting activities within our covered processes, Lea Refining Company maintains written operating procedures. The se 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. \par \par }{\fs24\ul Training}{\fs24 \par Lea Refining Company has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operat ing procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed. \par \par }{\fs24\ul Mechanical Integrity}{\fs24 \par Lea Refining Company carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent sys tems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. \par \par }{\fs24\ul Management of Change}{\fs24 \par Written procedures are in place at Lea Refining Company to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of management of change procedures was performed on 3/6/95. Process ope rators, 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. \par \par }{\fs24\ul Pre-startup Reviews}{\fs24 \par Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Lea Refi ning Company. The most recent review was performed on 3/3/97. These reviews are conducted to confirm that c onstruction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. \par \par }{\fs24\ul Compliance Audits}{\fs24 \par Lea Refining Company conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 12/8/97. These audits are carried out at least every 3 years a nd any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. \par \par }{\fs24\ul Incident Investigation}{\fs24 \par Lea Refining Company promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to pr event the release from reoccurring. All reports are retained for a minimum of 5 years. \par \par }{\fs24\ul Employee Participation}{\fs24 \par Lea Refining Company truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, inc luding information resulting from process hazard analyses in particular. \par \par }{\fs24\ul Contractors}{\fs24 \par Our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Lea Refining Company has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contr actors are also informed of all the procedures for emergency respon se should an accidental release of a regulated substance occur. \par \par }\pard \qj\fi-360\li360\sa120 {\b\fs28 5.\tab Five-year Accident History \par }\pard \qj {\fs24 Lea Refining Company has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. \par \par }\pard \qj\fi-360\li360\sa120 {\b\fs28 6.\tab Emergency Response Plan \par }\pard \qj {\fs24 Lea Refining Company has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. \par \par To ensure proper functioning, our emergency response equipment is regu l arly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. \par \par Lea County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. \par \par }\pard \qj\fi-360\li360\sa120 {\b\fs28 7.\tab Planned Changes to Improve Safety \par }\pard \qj {\fs24 Lea Refining plans to continue improving and enhancing our already effective safety program. This established successful system is already in place to pr event and respond to accidental releases. Furthermore, no potential offsite consequences have been identified. Therefore, it is not surprising that no new courses of action have been identified by the Risk Management Plan. However, the ongoing process whereby Navajo reviews and evaluates new information will continue to result in ever improving refinements to our existing Safety Program. \par \par }} |