Excel Paralubes - Executive Summary
30830 LDEQ Facility ID Number |
RISK MANAGEMENT PLAN
The RMP rule requires that this site provide an executive summary in the RMPlan. This summary provides the following items:
7 Accidental release prevention and response policies
7 Description of the stationary source and regulated substances
7 Offsite consequence analysis results
7 General accidental release prevention program and chemical-specific prevention steps
7 Five-year accident history
7 Emergency response program
7 Chemical Specific Prevention Steps
7 Planned changes to improve safety
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Conoco, Inc. and Atlas Processing Company, Inc. (Subsidiary of Pennzoil Products Company Inc.), Excel Paralubes site has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and m
aintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Excel Paralubes site is located In Westlake, Louisiana. It operates a variety of processes that takes raw crude oil and produces high quality lube oils. The Excel Paralubes site has regulated flammables, such as propane, butane, NFPA4 flammable mixtures, and hydrogen. The site also has several of the RMP listed toxic substances, but none at the quantity or concentration specified in the regulation.
HAZARD ASSESSMENT RESULTS
The WCS associated with a release of flammable substances in Program 3 processes at the Excel Paralubes site is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing 108900 pounds, primarily butane. No administrative
controls are in place to limit the storage inventory in the tank; therefore, the full tank inventory of 108900 pounds is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is 0.38 miles impacting a population of 235 people. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this WCS.
The ARS associated with a release of a flammable substances at the site is the radiant heat effects of a fireball formed where a vessel of mainly butane overheats from a fire impinging on the tank (BLEVE) resulting in the release of 108900 pounds of propane over 40 seconds and exploding. The maximum distance to the 1-psi endpoint for this event is 0.20 mile impacting a population of 235 people. This event was selected as being a practical scenario for use in emergency planning and response.
The Excel Pa
ralubes site also has several of the RMP listed toxic substances, but none at the quantity or concentration specified in the regulation therefore we will not be reporting a toxic WCS or ARS.
FIVE-YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at our facility. We investigate every incident very carefully to determine ways to prevent similar incidents from occurring. The following is a brief summary of accidental chemical releases involving material covered under EPA's RMP rule since June, 1994. This incident history considers off-site impact such as shelter-in-place of the public, injuries to the public or equipment damage of $50,000 or more.
There were no accidents that meet the EPA-RMP criteria.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program in place at the Excel Paralubes site. Because processes at the site are regulated by the EPA RMP regulation are
also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.
The Excel Paralubes site encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the refinery accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the site and addresses each accident prevention program element. In addition, the site has a number of initiatives under way that address process safety and employee safety issue. These initiatives include forming teams to
promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management.
Process Safety Information
The Excel Paralubes site keeps a variety of technical documents called Process Technology Packages (PTP's). PTP's are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the refinery are assigned responsibility for maintaining up-to-date process safety information A table summarizing the reference documents and their location is readily available as part of the written employee participation plan to help employees locate any necessary process safety information.
Chemical-specific information, including exposure hazards and emergency response/ exposure treatment c
onsiderations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the refinery has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in a Safe Operating Limit (SOL) section of the PT Package. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).
The site also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and tr
ained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.
Process Hazard Analysis
The Excel Paralubes site has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.
The Excel Paralubes site uses a combination of the hazard and operability (HAZOP) analysis technique along with a What-If checklist to perform these evaluations. In addition the HAZOP/What-If checklist the site uses a systematic Layer of Protection Analysis (LOPA) which takes industry failure rates and applies to a scenario to calculate a threshold value. The combination of HAZOP/What-If checklist/LOPA is recognized as one of the most systemati
c and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.
The PHA team findings are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards do not eventual
ly deviate significantly from the original design safety features, the Excel Paralubes site periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented, tracked, and retained. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained.
The Excel Paralubes site maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and an
nually certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process.
In addition, the Excel Paralubes site maintains key process parameter documents that provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.
To complement the written procedures for process operations, the Excel Paralubes site has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operator
s demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training.
The Excel Paralubes site uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the refinery has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in t
he event of an emergency, (5) understand and follow site safety rules, and (6) inform refinery personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the Excel Paralubes site evaluates contractor safety programs and performance during the selection of a contractor. Site personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Reviews (PSSRs)
The Excel Paralubes site conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into servi
ce. This review provides one additional check to make sure construction is in accordance with the design specifications and that all-supporting systems are operationally ready. The PSSR review uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
The Excel Paralubes site has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mecha
nical integrity of the process equipment.
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.
Another integral part of the mechanical integrity program is quality assurance. The Excel Paralub
es site incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.
Safe Work Practices
The Excel Paralubes site has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance
activities are performed safely.
Management of Change
The Excel Paralubes site has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process-operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.
The Excel Paralubes site promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major prope
rty damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to refinery management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.
To help ensure that the accident prevention program is functioning properly, the Excel Paralubes site periodically conducts an audit to deter
mine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to refinery management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
CHEMICAL SPECIFIC PREVENTION STEPS
The processes at the Excel Paralubes site have hazards that must be managed to ensure continued safe operation. The accident prevention program summarizes previously is applied to all Program 2 and 3 EPA RMP-covered processes at the Excel Paralubes site. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failure and (2) human errors.
dition to the accident prevention program activities, the Excel Paralubes site has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequence of (mitigate) a release. The following types of safety features are used in various processes:
Hydrocarbon detectors with alarms
7 Process relief valves that discharge to a flare to capture and incinerate episodic releases
7 Scrubber to neutralize chemical releases
7 Valves to permit isolation of the process (manually or automated)
7 Automatic shutdown systems for specific process parameters (e.g., high level, high temperature)
7 Vessel to permit partial removal of the process inventory in the event of a release (e.g. dump tank)
7 Curbing or diking to contain liquid releases
7 Redundant equipment and instrumentation (e.g., interruptible power supply for process control system, backup firewater pump)
7 Atmospheric relief device
7 Fire suppression and extinguishing systems
7 Deluge for specific equipment
7 Trained emergency response personnel
7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)
7 Blast-resistant buildings to help protect control systems and personnel
EMERGENCY RESPONSE PROGRAM INFORMATION
The Excel Paralubes site maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and d
econtamination requirements. In addition, the Excel Paralubes site has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to refinery processes or other refinery facilities.
The overall emergency response program for the Excel Paralubes site is coordinated with the Lake Charles, Louisiana Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Excel Paralubes site has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This
provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Excel Paralubes site conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.
PLANNED CHANGES TO IMPROVE SAFETY
The Excel Paralubes site resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned:
7 Removing toxic chemicals such as chlorine and sulfur dioxides as water treating chemicals
7 Written work instructions for calibrating and testing instrumentation safety systems
7 Installing emergency shutdown valves in the liquefied petroleum gas storage area to decrease the inventory that could be released.