El Dorado Refining Company - Executive Summary |
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This document outlines a Risk Management Program (RMP), prepared in accordance with 40 CFR Part 68. This document has been prepared to consider all covered process units as RMP Program Level 3 processes. The following is a brief outline of the plan and additional details are included in the attached file containing the complete Executive Summary. ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The El Dorado, Kansas refinery has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, refinery personnel have been trained on the proper response to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The El Dorado refinery is located at 1401 South Douglas Road in El Dorado, Kansas. The plant is owned and operated by El Dorado Refining Company, a Division of Equilon Enterprises LLC. Equilon Enterprises LLC was formed January 1, 1999 as an alliance between Texaco and Shell. Texaco acquired the El Dorado facility from Getty Oil Company in January 1985. The refinery processes about 110,000 barrels of feedstock per day to refine crude oils into various petroleum and chemical products by the use of typical refining and specific petrochemical processes. The El Dorado facility receives and transports petroleum products via rail, tank trucks and pipelines. The El Dorado Plant has a storage capacity of petroleum and refined products exceeding two million barrels through a network consisting of over 150 above ground tanks. The list of regulated flammable substances includes hydrogen, methane, ethane, propane, butane and pentane. In addition, the refinery uses and/or processes chlorine an d hydrogen fluoride, which are regulated toxic substances. HAZARD ASSESSMENT RESULTS For toxic substances, a worst case scenario was prepared for hydrogen fluoride and alternative release scenarios were prepared for hydrogen fluoride and chlorine. For flammable substances, worst case scenarios and an alternative release scenario was prepared for butane. Although we have controls to prevent releases of this nature and to manage their consequences, no credit for administrative controls or passive mitigation measures were taken into account in evaluating the scenarios. GENERAL ACCIDENTAL RELEASE/CHEMICAL SPECIFIC PREVENTION PROGRAM STEPS The refinery is subject to the EPA Risk Management Program (RMP) regulation and the OSHA Process Safety Management (PSM) standard. Therefore, there is a management system in place to address each element and to implement the accident prevention program. The elements are Employee Participation, Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractors, Pre-Startup Safety Review, Mechanical Integrity, Safe Work Practices, Management of Change, Incident Investigations and Compliance Audits. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the El Dorado refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the El Dorado refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. In addition to the accident prevention program activities, the El Dorado refinery has safety features on many units to help contain/control a release, quickly detect a release and reduce the consequences or mitigate the consequences of a release. FIVE YEAR ACCIDENT HISTORY A review of accident/incident data for the previous five years shows two incidents that met the reporting crite ria of 40 CFR Part 68. One of the incidents involved hydrogen fluoride and one of the incidents involved butane. There were no offsite consequences from either of these incidents. An additional incident involving hydrogen fluoride was reported because it was similar in size of the release to the alternative release scenario selected for hydrogen fluoride. There were no onsite or offsite consequences from this incident. The El Dorado refinery has not had an accident over the last five years involving chlorine that qualifies under RMP as a significant event with onsite or offsite effects. The El Dorado refinery has not had an accident over the last five years involving any of the remaining flammable substances that qualifies under RMP as a significant event with onsite or offsite effects. The flammable substances include hydrogen, methane, ethane, propane and pentane. EMERGENCY RESPONSE PROGRAM INFORMATION The emergency response plan for El Dorado Plant is documented in the El Dorado Emergency Management System - Emergency Plans and Procedures. The El Dorado Emergency Management System (EEMS) is an organizational plan designed to manage an emergency situation by setting up effective communications, establishing a management plan, providing necessary resources and allowing coordination with any municipal/state/federal emergency response agency that may respond to an emergency at the facility. The El Dorado Refinery emergency response organization consists of the Safety Department and the Emergency Response Team (ERT). Emergency response drills and training are conducted periodically to evaluate the El Dorado Refinery's overall emergency response program. The training and drills have often been coordinated with the El Dorado Fire Department, Butler County Emergency Management, Butler County LEPC, Butler County Rescue Squad and Butler County Sheriff's Department. The emergency response programs for the processes with toxic substances have been upgraded in recent years. PLANNED CHANGES TO IMPROVE SAFETY The refinery has implemented a number of items to improve safety throughout the facility as part of an overall continuous improvement process. Four specific areas that are undergoing change and are particularly important to achieving improvements in safety are Process Hazard Analysis, Management of Change, Incident Investigation and Mechanical Integrity. Two additional areas where changes are in progress to improve safety are the TEAMS Safety Process and the Corporate Process Safety Initiative. The TEAMS Safety Process is a behavior-based system that consists of a coordinator and 21 teams to analyze safety issues of importance to the El Dorado refinery employees. The teams are involved in various safety-related areas with the goal of new approaches to procedures, practices and methods. The Corporate Process Safety Initiative is a corporate wide review of various process safety elements by teams with members from the various loc ations. The emphasis is on sharing ideas and successful practices and focusing on implementing improvements at the individual facilities. Note: The previous is a brief outline and additional details are included in the attached file containing the complete Executive Summary. RISK MANAGEMENT PLAN EXECUTIVE SUMMARY (Revised 7-20-99) for EL DORADO REFINING COMPANY (EDRC) A Division of EQUILON ENTERPRISES LLC SUMMARY This document outlines a Risk Management Program (RMP), prepared in accordance with 40 CFR Part 68. This document has been prepared to consider all covered process units as RMP Program Level 3 processes. ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The El Dorado, Kansas refinery has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, refinery personnel have been trained on the proper response to control and contain the release. This commitment to employee and public safety is demonstrated by the Equilon Enterprises Code of Conduct which stresses the need for being responsible corporate citizens and good neighbors in the communities in which they operate. The President and CEO of Equilon further defined this in his "Vision and Commitment to Safety, Health and Environment Performance" letter of February 25, 1998. He indicated model safety, health and environmental performance is part of the company vision. He also encouraged each employee to adhere to the following principles: * The belief that all accidents, occupational illnesses, process safety incidents and environmental incidents are preventable.. * Compliance with all safety, health and environmental regulations is mandatory. * Atte ntion to safety, health and environment matters is our first consideration in all activities. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The El Dorado refinery is located at 1401 South Douglas Road in El Dorado, Kansas. The plant is owned and operated by El Dorado Refining Company, a Division of Equilon Enterprises LLC. Equilon Enterprises LLC was formed January 1, 1999 as an alliance between Texaco and Shell. Texaco acquired the El Dorado facility from Getty Oil Company in January 1985. The refinery processes about 110,000 barrels of feedstock per day to refine crude oils into various petroleum and chemical products by the use of typical refining and specific petrochemical processes. The El Dorado facility receives and transports petroleum products via rail, tank trucks and pipelines. The El Dorado Plant has a storage capacity of petroleum and refined products exceeding two million barrels through a network consisting of over 150 above ground tanks. The l ist of regulated flammable substances includes hydrogen, methane, ethane, propane, butane and pentane. In addition, the refinery uses and/or processes chlorine and hydrogen fluoride, which are regulated toxic substances. HAZARD ASSESSMENT RESULTS The worst-case scenario (WCS) for toxic substances is a failure at the Hydrogen Fluoride (HF) Alkylation Unit resulting in a ten minute release of 255,000 lbs. of HF from the HF Alkylation Unit de-inventory vessel. For this WCS, the distance to the toxic endpoint (or ERPG-2 value) of 20 PPM is 51,900 feet or 9.8 miles. Although we have controls to prevent releases of this nature and to manage their consequences, no credit for administrative controls or passive mitigation measures were taken into account in evaluating this scenario. This quantity of HF is present in the de-inventory drum at a frequency of about 4 weeks every four years. Under actual storage conditions, the HF which is stored as a liquid, would not instantly vaporize. Amb ient conditions would determine the rate at which a vapor cloud would be generated. However, under EPA RMP modeling requirements, all of the release is assumed to be discharged into the air and no pool is formed. Therefore, the distance reported for this release may be overstated. The alternative release scenario (ARS) for HF at the refinery is a ten-minute release of 13,020 pounds of HF from a one-inch hole in the reactor settler area. The distance to the toxic endpoint (or ERPG-2 value) of 20 PPM is 3,990 feet or 0.8 miles. Neither active or passive mitigation systems were used to evaluate this scenario. Under actual release circumstances, the duration of the release would be limited by transferring the reactor settler contents to the emergency de-inventory vessel. Also, the water mitigation system installed at this unit would be activated during an HF release and reduce the amount of HF that would become airborne. The alternative release scenario for Chlorine is a twenty-min ute release of 600 pounds of Chlorine from a hole in a storage cylinder. The distance to the toxic endpoint (or ERPG-2 value) of 3 PPM is 0.3 miles. Although we have controls to prevent releases of this nature and to manage their consequences, no credit for administrative controls or passive mitigation measures were taken into account in evaluating this scenario. Two worst-case scenarios (WCS) were identified for Butane at the facility. Each scenario impacts a circular area with the Vapor Cloud Explosion (VCE) at the center of the release. Because the locations of each release are different, the affected areas overlap. A separate population estimate has been made for each scenario. For purposes of discussion, the worst cases have been defined as a primary worst-case scenario and a secondary worst-case scenario. The primary worst case scenario involves the release and subsequent VCE of the full inventory of Tank 435. The capacity of this tank is 7,200,000 pounds of isobutane/bu tane mixture. The maximum distance to the 1-psi endpoint is 1.6 miles. Although we have controls to prevent releases of this nature and to manage their consequences, no credit for administrative controls or passive mitigation measures were taken into account in evaluating this scenario. The secondary worst case scenario involves the release and subsequent VCE of the full inventory of Tank 458. The capacity of this tank is 9,000,000 pounds of isomerate. The maximum distance to the 1-psi endpoint for this other WCS is 1.7 miles. Although we have controls to prevent releases of this nature and to manage their consequences, no credit for administrative controls or passive mitigation measures were taken into account in evaluating this scenario EPA recommends that the VCE be modeled using a "TNT equivalent model". A TNT equivalent model assumes that the release is in an area where the equipment is highly congested (e.g. within a few feet of each other). For both of the WCS's, the re leases are in an open tank farm area which is not congested. This would substantially reduce the overpressure of the blast, which the TNT equivalent model does not account for. In addition, the EPA RMP rule requires that all of the material instantly vaporize upon release when in reality the secondary worst-case scenario would form a liquid pool upon release and then be contained in a diked area, thus substantially reducing the amount that would vaporize. Therefore, each of the WCS's result in distances that may be over-stated. The alternative release scenario for Butane at the refinery is the failure and subsequent ignition of 227,000 lbs of butane from a 350 psig, 4 inch pipeline at the plants' North property line adjacent to the Southwest Trafficway. No active or passive mitigation systems were used for this scenario. The rupture is assumed to ignite and result in a flame jet (i.e. a torch fire) pointed horizontally away from the release. The distance to reach the endpoint o f concern of 5 kw/m2 is 0.15 miles (818 feet). GENERAL ACCIDENTAL RELEASE/CHEMICAL SPECIFIC PREVENTION PROGRAM STEPS The following is a summary of the accident prevention program in place at the refinery. The refinery is subject to the EPA Risk Management Program (RMP) regulation and the OSHA Process Safety Management (PSM) standard. Therefore, this summary addresses each OSHA PSM element and the management system in place to implement the accident prevention program. Employee Participation The El Dorado refinery provides for and encourages employees to participate in all facets of process safety management and accident prevention. Employees are involved in the development, review, updating and application of both procedures and information for the various PSM and RMP elements. Information regarding the status of the various elements is made available to all employees. More specific information regarding employee involvement has been documented in an employee participation pl an that is maintained at the refinery and is accessible to all employees. In addition, the refinery is currently undertaking new approaches to improve process safety and employee safety. The most significant of these is our TEAMS process that is a behavior-based system utilizing members from all departments in the plant. To date, 21 different teams have been organized to analyze issues selected from a survey of employees. The teams work to improve safety by implementing new approaches to procedures, practices and methods. These teams will also remain involved to monitor the progress and the effectiveness of the individual issues. Process Safety Information The El Dorado refinery maintains a variety of technical documents that are used to help sustain safe operation of the processes. These documents address chemical properties and associated hazards, limits on key process conditions, specific chemical inventories and equipment design parameters. Each process unit has safe upper & lower limits identified in associated operating manuals. The plant maintains a process safety information document that lists the type of information, where it is located and the department responsible for updating the information. The process safety information is updated on an on-going basis and is verified in conjunction with process hazard analysis studies. Chemical-specific information includes exposure hazards, as well as emergency response and exposure treatment considerations. For specific process areas, the refinery has established safety-related limits for specific process parameters (e.g., temperature, level, composition). The refinery verifies that the process is maintained within these limits using process controls, monitoring instruments, trained personnel, and safety systems such as alarms on critical variables and automated shutdown systems. The refinery also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes such things as materials of construction, design pressure ratings, design temperature ratings and the electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as evaluating proposed process and facility changes to determine that safety features in the process are not compromised. Process Hazard Analysis The El Dorado refinery has a comprehensive program to identify for the various processes the potential hazards that may be created as a result of deviations from the design intent. Within this program, each process is systematically examined to identify potential hazards and verify that adequate safeguards are in place to mitigate and/or control the circumstances. The El Dorado refinery primarily uses the industry recognized Hazard and Operability (HAZOP) method as the basis for process hazard analysis studies. The HAZOP study is considered one of the most comprehensive of all available qualitative hazard assessment techniques. This technique utilizes the services of a multi-disciplined team, usually composed of four to seven members, typically representing operations, engineering, maintenance and safety. The objectives of the study are to identify the causes and consequences of potentially hazardous or inefficient operating conditions and to identify safeguards in place, which would mitigate and/or control the circumstances. A systematic process is used to identify a variety of possible scenarios, which may lead to hazardous situations, recommend improvements in the areas of safety and operability and document the findings. Recommendations may be made to improve the efficiency of the equipment or unit and/or to render less likely the probability and extent of damage or injury in the event the equipment does not operate as designed or human error were to occur. In some cases, f urther studies are recommended for scenarios outside the defined scope of the HAZOP study or when the team does not have the resources to make a definite recommendation to address an issue. The HAZOP team findings are forwarded to refinery management for further consideration. After review, management may elect to implement the recommendation as stated, recommend further study or not implement the recommendation. The review and follow-up process can be facilitated through an action plan, which documents the status of the recommendations made in the study. The action plan should include a listing of the recommendations, a time frame for addressing each recommendation, an individual designated to address each recommendation and the action being taken. The progress of this action plan is monitored until all recommendations for an individual HAZOP study are completed and resolution documentation is on file. To assure the hazard analysis is consistent with the current process, the ref inery updates and revalidates the hazard analysis for each process unit at least every 5 years. These will be conducted on a 5-year cycle until the process is no longer operating. The 5 year hazard analysis reviews are conducted, considered, documented and closed in the same manner as outlined in the paragraphs above for the original hazard analyses. To date, over 35,000 man-hours have been expended in conducting process hazard analysis studies at El Dorado. For changes to the refinery processes, different process hazard analysis methods may be used depending on the complexity of the change. If the change is large in scope the HAZOP method is used. For smaller and less complex changes, a checklist method may be used. Checklists that have been developed at EDRC for use are the What-If Checklist, Tie-In Checklist and Design Capacity Review Checklist. Operating Procedures Operating procedures have been developed to provide instructions for safely conducting activities involved f or each process at the refinery. The written procedures address various modes of process operations, such as unit startup, normal operations, temporary operations, emergency shutdown and normal shutdown. These procedures serve as a consistent basis for training new operators and for reference by more experienced operators. The procedures are periodically reviewed and annually certified as current and accurate. The procedures are also reviewed as necessary to reflect changes made through the management of change process. All operating employees have the opportunity to be involved in reviewing operating procedures for accuracy and completeness. Proposed changes are reviewed and revised procedures issued as necessary. Operations employees from process areas may be assigned on a full time basis to coordinate the revisions to existing procedures and for writing new procedures. The training department has overall responsibility for the operating procedures and holds routine meetings to review the status of the procedures and coordinate the progress of the ongoing effort. Training The El Dorado refinery has an operator training program that is coordinated by the training department in conjunction with the operating procedures. Operations employees from the process areas that are responsible for the operating procedures are also involved in the operator training. All operators receive refresher training on operation of the units to ensure operating skills and knowledge are maintained and enhanced. New employees receive foundational training on refinery operations as well as unit specific training. Operations trainers and other unit operators work with the new employees as they progress through various skill levels. At each level the new operator must demonstrate their understanding and proficiency before proceeding to the next level. Training is also conducted for management of change items that affect an operator's duties. All operator refresher training, new employee training and management of change training that is conducted is documented and the records are maintained by the training department. Contractors The refinery 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 determine whether 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 do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform refinery personnel of any hazards 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 refinery evaluates c ontractor safety programs, performance and training during the contractor selection process. These same factors are monitored during contractor activities at the refinery to ensure they are fulfilling their safety obligations. Pre-Startup Safety Review The El Dorado refinery has a formalized process, which requires that a pre-startup safety review (PSSR) be conducted whenever a facility modification requires management of change or a change in process safety information. Personnel with expertise in process operations and engineering participate in the pre-start up safety reviews that are completed in conjunction with the management of change system. They are verifying that construction is in accordance with specifications, all necessary procedures are in place and are adequate, any process hazard analysis recommendations have been addressed and training of operating personnel has been conducted. This review is included in the management of change process to facilitate the review and document the activities. Mechanical Integrity A site-specific mechanical integrity program has been developed and implemented at the El Dorado refinery that provides for the on-going integrity of pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems. A primary objective at the refinery is to maintain equipment in a safe and operable condition to allow the refinery to plan for equipment outage, predict necessary repairs, and minimize unscheduled equipment downtime. The basic aspects of this program include conducting training, maintaining written procedures, performing inspection and tests, correcting identified deficiencies and applying quality assurance measures. Maintenance personnel receive training on both an overview of the process including safety and health hazards and applicable maintenance procedures to allow them to perform their work in a safe manner. The safety department maintains information r egarding an overview of the process units and the engineering, training and maintenance departments maintain procedures necessary to maintain the refinery equipment. Inspection and tests are performed in accordance with plant and industry standards to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits. Documentation of inspection and tests is maintained and equipment deficiencies that are identified are corrected. Quality assurance is another integral part of the mechanical integrity program. The El Dorado refinery incorporates quality assurance in new construction, new equipment installation and maintenance activities. This is necessary to assure new equipment, maintenance material and spare parts and equipment are suitable for the process application. Quality assurance is also accomplished through checks and inspections to assure it is properly installed and consistent with design specifications and industry standards. S afe Work Practices The refinery 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 that is being worked on, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit or procedure to control spark-producing activities (i.e., hot work), and (5) a confined space procedure. 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 El Dorado refinery has a comprehensive system to manage facility changes. This system requires that changes to items such as process equipment, chemicals, or procedures be properly authorized and reviewed before being implemented. To assure proposed changes are pr operly reviewed and documented, the management of change procedure at the El Dorado refinery requires certain activities to be performed by various departments. These activities begin once scope definition is completed and include reviews of engineering design, process hazard analysis, safety, environmental, operator training, maintenance training, construction, inspection, testing and pre-startup. Affected equipment and chemical information, as well as procedures are updated as necessary to incorporate changes. Incident Investigations The refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire, explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations, and forwards the results to management for resolution. Each corrective action is tracked until it is completed. Incident investigation reports are retained for at least 5 years so that reports can be reviewed during future PHA studies. Compliance Audits In accordance with corporate policies, the El Dorado refinery has conducted audits of the safety and process safety programs at the facility. In the past these have consisted of implementing Texaco's Environmental, Health and Safety Compliance Program that was intended to help verify that El Dorado's actions were directed by the utmost concern for the environment, health and safety of all employees and the surrounding community. To verify that the regulatory requirements were properly applied, the El Dorado facility has undergone periodic Environmental, Health and Safety Audits by the corporation. In addition, Texaco conducted Corporate Risk Management Program audits on a frequency of three years or less. These audits were conducted by a team headed by personnel from the Texaco Corporate Safety and Industrial Hygiene Department, and were assisted by personnel from other corporate refineries. Equilon Enterprises LLC will continue to audit the El Dorado facility to assure compliance with regulatory, corporate and facility programs in regards to environment, health and safety concerns for all employees and the community. These audits will consist of corporate teams conducting Compliance Assurance Reviews, Focused Audits and Process Safety & Risk Management Audits. Compliance Assurance Reviews are designed to focus on safety, health and environmental standards and this review was conducted at El Dorado in May of 1999. Focused Audits are intended to assess pressure equipment integrity, safeguarding, and protective instrument systems and one was completed at the El Dorado facility in May of 1999. A Process Safety & Risk Management Audit is scheduled to take place at El Dorado in September of 1999 and will focus on compliance with th e OSHA Process Safety standard and the EPA Risk Management Program. Audit team findings are forwarded to refinery management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete and the final resolution of each finding is documented. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the El Dorado refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the El Dorado refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. In addition to the accident prevention program activities, the El Dorado refinery has safety features on many units to help contain/control a release, quickly detect a release and reduce the consequences or mitigate the consequences of a release. The following types of safety features are used in various processes: Release Detection * Hydrocarbon detectors * HF detectors * Video camera monitors to detect leaks Release Containment/Control * Process relief valves that discharge to a flare to capture and incinerate episodic releases * Scrubbers to neutralize chemical releases * Valves to permit isolation of the process (manual or automated) * Automated shutdown systems for specific process parameters (e.g., high level, high temperature) * Vessel to permit partial removal of the process inventory in the event of a release (e.g., de-inventory vessel) * Curbing or diking to contain liquid releases * Redundant equipment (backup firewater pump, backup process pump) * Emergency battery-powered backup electrical supply for process control systems * Atmospheric relief devices * Water spray systems at pump seals * Water spray systems at selected equipment * Perimeter water spray curtain * Remotely activated shutoff valves for pumps Release Mitigation * Refinery dedicated fire water system * Backup firewater pumps and sources * Refinery dedicated fire department equipment (including, engines, aerials, tankers, mini-pumpers, foam equipment, rescue\medical vehicle, portable monitors, portable hydrants and portable pumps) * Deluge system for specific equipment * Trained emergency response personnel * Personal protective equipment (e.g. protective clothing, self-contained breathing apparatus) * Blast-resistant buildings to help protect control systems and personnel * Emergency alarm system with siren and public address capability FIVE YEAR ACCIDENT HISTORY A review of accident/incident data for the previous five years shows two incidents that met the reporting criteria of 40 CFR Part 68. On January 10, 1997 an operator received minor burns from exposure to a few drops hydrogen fluoride while withdrawing a small amount from a test port. There were no offsite consequences from this incident. On October 24, 1998 an operator received a burn injury from a butane release and fire that was the result of the failure of a pump bearing and seal. The second-degree burn was to the employee's hand and he returned to normal duty without any lost time. There were no offsite consequences as a result of this incident. An additional incident was reported because it was similar in size of the release to the alternative release scenario selected for hydrogen fluoride. On September 18, 1998 the failure of a pipefitting resulted in the release of 12,000 pounds of hydrogen fluoride, but with no onsite or offsite consequences. All of these incidents were investigated and the recommendations are being addressed. The El Dorado refinery has not had an accident over the last five years involving chlorine that qualifies under RMP as a significant event with onsite or offsite effects. The El Dorado refinery has not had an accident over the last five years involving any of the remaining flammable substances that qualifies under RMP as a significant event with onsite or offsite effects. The flammable substances include hydrogen, methane, ethane, propane and pentane. The following table is a summary of the number of incidents that have occurred during the past five years that meet the reporting criteria of 40 CFR Part 68: 1995 1996 1997 1998 1999 Number of RMP Events with Onsite Effects 0 0 1 1 0 Number of RMP Events with Offsite Effects 0 0 0 0 0 EMERGENCY RESPONSE PROGRAM INFORMATION The emergency response plan for El Dorado Plant is documented in the El Dorado Emergency Management System - Emergency Plans and Procedures. The El Dorado Emergency Management System (EEMS) is an organizational plan designed to manage a major incident (e.g., fire, vapor release, tornado, spills, etc.). EEMS is based on the Incident Command System (ICS). This type of system allows the El Dorado refinery to mitigate an emergency situation by setting up effective communications, establishing a management plan, providing necessa ry resources and allowing coordination with any municipal/state/federal emergency response agency that may respond to an emergency at the facility. EEMS is a structured organization put together to establish an incident command system to be used in the event of an emergency. This organization involves every department within the refinery and sets up specific duties for each position/person to complete. This system was put into place at the refinery such that during an emergency, the following will occur: * Activate emergency siren to notify plant personnel and the surrounding community * Manage the incident * Protect human health and the environment * Maintain continuity of chain of command * Provide effective communication * Deal effectively and promptly with the media * Deal effectively and promptly with government agencies * Implement medical emergency response system * Procure needed materials, supplies and personnel. If an incident within the plant can present a hazard to the community, the refinery Incident Commander will contact the County Emergency Preparedness Coordinator. The County Emergency Preparedness Coordinator will assess the nature of the emergency incident and determine if he/she will delegate the County Incident Commander responsibility to the El Dorado Fire Department Fire Chief. Additional coordination procedures are described in the Butler County LEPC Emergency Operating Plan. The El Dorado Refinery emergency response organization consists of the Safety Department and the Emergency Response Team (ERT). The Safety Department has 5 Fire/Safety Specialists and 2 Safety Inspectors with various qualifications such as Hazardous Material (HAZMAT) Technician/Specialist, State Certified Emergency Medical Technician, Fire Service Instructor, Firefighter II Certified, Industrial Firefighter, Driver/Operator and Rescue Specialist. The Emergency Response Team is composed of about 50 volunteer plant employees that are trained in fire suppression, first aid, CPR, rescue and hazardous materials response. The ERT is divided into 4 teams to cover the operating shifts and a fifth team of employees who primarily work daylight hours. ERT training is conducted in quarterly sessions and in monthly drill exercises that are held the other 8 months of the year. Emergency response drills and training are conducted periodically to evaluate the El Dorado Refinery's overall emergency response program. The topics covered in the drills and training cover a wide range of emergencies such as spills, leaks, releases, fires, rescues and first aid. The training and drills have often been coordinated with the El Dorado Fire Department, Butler County Emergency Management, Butler County LEPC, Butler County Rescue Squad and Butler County Sheriff's Department. Some of the drills or training that involved RMP regulated chemicals and/or involved local emergency response personnel are discussed below: * October 28, 1998 - Hazard Identification and HA ZMAT training with the El Dorado Fire Department. * June 4, 1998 - Chlorine release from a cylinder at the Water Treater. The response was to secure the area and apply a chlorine B kit to contain the leak. * June 24, 1997 - HAZMAT training held in conjunction with the El Dorado Fire Department and the Butler County LEPC. Included in the training were tank truck fundamentals and specific portions on acid tank trucks and cryogenic tank trucks. * March 11, 1997 - Test of the Plant Alarm System, including the Severe Weather Alert capabilities with the City of El Dorado and the El Dorado Fire Department. * March 13, 1997 - Mutual aid drill with the El Dorado Fire Department that simulated a gasoline tank on fire. * May 28, 1996 - Butane leak from a pipeline. In addition to the ERT, this drill involved the El Dorado Fire Department, Butler County Emergency Management and the Butler County Sheriff's Department. This drill very closely simulates the Alternative Release Scenario for Bu tane. * June 6, 1995 - Emergency response drill involving an HF truck unloading at the HF Alkylation unit. During unloading, the truck's pressure relief valve began leaking. The truck driver was unable to apply the leak kit and a vapor cloud traveled north to the cooling towers. The operator initiates the water curtain mitigation system and the ERT responds. The emergency response program for the HF Unit has been upgraded in recent years by the installation of the following equipment: * Perimeter water spray curtain, * Remotely activated shutoff valves for pumps, * Video cameras installed to help detect leaks, * HF and hydrocarbon leak detectors and, * De-inventory vessel. The Water Treater Unit was upgraded in 1999 to include the following Chlorine related improvements: * Improved metering and piping and * Automatic flow shut-off in the event of a leak or line break. PLANNED CHANGES TO IMPROVE SAFETY The refinery has implemented a number of items to improve safety througho ut the facility as part of an overall continuous improvement process. The following areas are undergoing changes and are particularly important to achieving improvements in safety. * Process Hazard Analysis - As we continue on a program of revalidation, the process hazard analysis is important in evaluating process unit safety to stay updated on Management of Change items, incidents, operating procedures and human factors. * Management of Change - This process was reviewed and revised and will continue to improve safety by virtue of the corresponding review and updating of process safety information, procedures, training and mechanical integrity. * Incident Investigation - A new incident tracking system is in the process of being put into place and will make the information more readily available to all plant personnel. * Mechanical Integrity - New methods of involving maintenance employees are being put in place by the Machine Shop and written mechanical integrity processes are bein g revised and improved. Two additional areas where changes are in progress to improve safety are the TEAMS Safety Process and the Corporate Process Safety Initiative. The TEAMS Safety Process is a behavior-based system that consists of a coordinator and 21 teams to analyze safety issues of importance to the El Dorado refinery employees. The teams are involved in various safety-related areas with the goal of new approaches to procedures, practices and methods. Some of those teams with the most significance to process safety are: * Safety procedure review * Incident investigation * Peer work analysis * Management of change review and communication * Safety awareness and attitudes The Corporate Process Safety Initiative is a corporate wide review of various process safety elements by teams with members from the various locations. The emphasis is on sharing ideas and successful practices and focusing on implementing improvements at the individual facilities. Subjects being revie wed that are relevant to RMP\PSM elements are: * Management of Change * Operating procedures and training * Incident investigation * Mechanical Integrity - Preventative Maintenance - Protective instrumentation - Pressure equipment integrity * Incident investigation and solution identification * Audit Programs El Dorado Refining Company Risk Management Plan 16 El Dorado Refining Company June, 1999 El Dorado Refining Company Risk Management Plan El Dorado Refining Company June, 1999 |