TPI Petroleum, Inc. - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Total Petroleum Inc. 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 and marketing. We have 21 regulated substances present at our facility. These substances include Isopentane [Butane, 2-methyl-], Butane, Pentane, Isobutane [Propane, 2-methyl], Propane, 1-Pentene, Butene, Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid], Propylene [1 -Propene], Ethane, Hydrogen sulfide, Hydrogen, Methane, 1,3-Butadiene, Ethylene [Ethene], Ammonia (anhydrous), Chlorine, 1-Butene, 1,3-Pentadiene, Carbon oxysulfide [Carbon oxide sulfide (COS)] and Carbon disulfide. Isopentane [Butane, 2-methyl-] is used for gasoline blending. Butane is used for gasoline blending. Pentane is used for gasoline blending. Isobutane [Propane, 2-methyl] is used for gasoline blending. Propane is used for LPG sales. 1-Pentene is used for gasoline blending. Butene is used for gasoline blending. Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] is used as a catalyst for increasing the octane of gasoline. Propylene [1-Propene] is used for LPG sales. Ethane is used for refinery fuel gas. Hydrogen sulfide is a process biproduct which is converted to sulfur. Hydrogen is used for various refinery processes. Methane is used for refinery fuel gas. 1,3-Butadiene is used for gasoline blending. Ethylene [Ethene] is used for refinery fuel gas. Ammonia (anhydrous) is used for pH control. Chlorine is used for water treatment. 1-Butene is used for gasoline blending. 1,3-Pentadiene is used for gasoline blending. Carbon oxysulfide [Carbon oxide sulfide (COS)] is a process biproduct. Carbon disulfide is a process biproduct. The maximum inventorys at our facility are: Isopentane [Butane, 2-methyl-] is 11231551.41 lb.; Butane is 10,059,042.43 lb.; Pentane is 6,139,166.01 lb.; Isobutane [Propane, 2-methyl] is 3,347,498.20 lb.; Propane is 1,712,980.67 lb.; 1-Pentene is 1,278,585.76 lb.; Butene is 760,767.01 lb.; Hydrogen fluride/Hydrofluoric acid [Hydrofluoric acid] is 273,656.97 lb.; Propylene [1-Propene] is 204,432.63 lb.; Ethane is 62,820.07 lb.; Hydrogen sulfide is 26,271.86 lb.; Hydrogen is 16,636.57 lb.; Methane is 11,179.22 lb.; 1,3-Butadiene is 6,432.65 lb.; Ethylene [Ethene] is 4,619.28 lb.; Ammonia (anhydrous) is 3,773.07 lb.; Chlorine is 2,000 lb.; 1-Butene is 8.51 lb.; 1,3-Pentadiene is 3.13 lb.; Carbon oxysulfide [Carbon oxide sulfide (COS)] is 2.57 lb.; and Carbon disulfide is 1.06 lb. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To evaluate the worst case scenarios, we have used the EPA's OCA Guidance Reference Tables or Equations or the EPA's RMP*Comp{TM} and Equations. For alternative release scenario analyses we have employed the EPA's OCA Guidance Reference Tables or Equations, the EPA's RMP*Comp(TM) and Equations from RMP OCA guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from HF Alkylation. In this scenario 67917 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 30% of the maximum capacity of the source by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.016 mg/L. The alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a release from HF Alkylation. The scenario involves the release of 130800 lb. of Hydrofluoric acid. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 60 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 5.8 miles. The alternative release scenario for Hydrogen sulfide involves a re lease from Sulfur Recovery Unit. The scenario involves the release of 5260 lb. of Hydrogen sulfide. Toxic gas is assumed to be released. The release is estimated to cease after 60 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.042 mg/L of Hydrogen sulfide is 0.3 miles. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Tankage. In this scenario 681798 lb. of Isobutane [Propane, 2-methyl] 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 0.71 miles is obtained corresponding to an endpoint of 1 psi overpressure. One alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Tankage. The release is assumed to r esult in a Vapor Cloud Explosion. The scenario involves the release of 147600.00 lb. of Flam. Mix.: Isopentane [Butane, 2-methyl-], Butane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.28 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from HF Alkylation. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 234832 lb. of Flam. Mix.: Isobutane [Propane, 2-methyl], Butane, Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.26 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from LPG Merox (Extraction). The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 20045 lb. of Flam. Mix.: Isobutane [Propane, 2-methyl], Butane, Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.22 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Tankage. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 147600.00 lb. of Isobutane [Propane, 2-methyl] in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.22 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Tankage. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 110378 lb. of Flam. Mix.: Butane, Propylene [1-Propene], Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.17 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Tankage. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 108241 lb. of Flam. Mix.: Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.17 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from No 1 Reformer. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 4706 lb. of Flam. Mix.: Isopentane [Butane, 2-methyl-], Pentane, Isobutane [Propane, 2-methyl], Butane, Propane, Ethane, Methane, Hydrogen in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.09 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary st eps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Total Petroleum Inc. maintains a detailed record of safety 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 Checklist, What If/Checklist (combined), HAZOP, FMEA and Fault Tree. 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 5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 05/25/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, Total Petroleum Inc. 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 Total Petroleum Inc. 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 3 years and more frequently as needed. Mechanical Integrity Total Petroleum Inc. carries out highly documented maintenance checks on pr ocess 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 Total Petroleum Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/28/99. 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 Revie ws Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Total Petroleum Inc.. The most recent review was performed on 04/27/1999. 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 Total Petroleum Inc. 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 03/20/1998. 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 Total Petroleum Inc. 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 i dentify 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 Total Petroleum Inc. 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, including information resulting from process hazard analyses in particular. Contractors On occasion, 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. Total Petroleum Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's wor k 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 Total Petroleum Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, the number of accidental releases has been reduced to a minimum. There have been 6 accidental releases of regulated substances from our facility within the last 5 years. The first release took place on 11/05/1994 and involved 0.1 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid]. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury. Another release, of 12000 lb. of Propane, occurred on 02/08/1996. No deaths or injuries occured offsite as a result of this accident. Onsite, there was one death and 3 injuries. There was some onsite property damag e. Another release, of 0.1 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid], occurred on 08/03/1996. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury. Another release, of 0.1 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid], occurred on 10/30/1996. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury. Another release, of 0.1 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid], occurred on 04/19/1998. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury. Another release, of 0.1 lb. of Propane, occurred on 04/30/1998. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury. 6. Emergency Response Plan Total Petroleum Inc. carries 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. 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. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. There are no major steps we want to take to improve safety at our facility as the facility is scheduled to be closed on October 1, 1999. |