MOTIVA Enterprises LLC - Norco Refining - Executive Summary |
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MOTIVA ENTERPRISES LLC - NORCO REFINING RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1406 - LDEQ Facility ID Number INTRODUCTION The MOTIVA ENTERPRISES LLC - Norco Refining Company has a long standing commitment to worker and public safety. We are committed to operating and maintaining all of our processes in a safe and responsible manner. This commitment is demonstrated by the resources invested in accident prevention, such as the safety in the design of our processes, development of safe operating procedures, preventative maintenance practices, accidental release prevention, emergency response planning and training programs to ensure the safety of our employees, the public and protection of the environment. The Norco Refining Company Health, Safety and Environmental policies speak to these commitments and provide the framework by which all activities originate. This document provides a brief overview of the comprehensive risk management activities that we have designed and im plemented, including: A description of our facility and use of substances regulated by EPA's RMP regulation A summary of results from our assessment of the potential off site consequences from accidental chemical releases An overview of our accidental release prevention programs A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule An overview of our emergency response program An overview of existing and planned improvements at the facility to help prevent accidental chemical releases The certifications that EPA's RMP rule requires us to provide The detailed information (called data elements) about our risk management program RMP MANAGEMENT SYSTEM POSITION DEPARTMENT PROGRAM RESPONSIBILITY PSM / RMP MANAGEMENT Safety Engineer Health, Safety and Environmental 1. Oversee implementation of RMPProgram 2. Review of all RMP related procedures 3. PSM / RMP Program Audits / Assurance COMMUNITY A FFAIRS Manager - Community Affairs 1. Coordinate public relations process 2. Media interface 3. Employee communications 4. Community issue resolution 5. Local agency liaison POSITION DEPARTMENT PROGRAM RESPONSIBILITY OPERATIONS Dept. Mgrs. Refining Operations Department 1. Operations Procedure Update Operation Specialists 2. Operator Training Compliance Coordinators 3. Operator Competency Testing Safety and Health Assurance 4. Process Safety Information Coordinator 5. Employee Participation 6. RMP/PSM Communication Focal Point 7. PSSR Performance & Tracking 8. Compliance Audit Mitigation EMERGENCY RESPONSE Senior Management Health, Safety and Environmental 1. Develop & Implement ER Program Emergency Response Coordinator 2. Training of Response Team Members Site Supervisor 3. Establishment of ER Teams - HAZMAT - ERT - RAT - MER - MARS 4. Test and maintain ER equipment 5. Coordinate with outside Mutual Aid Organizations, LEPC, DEP 6. Organize and conduct on-site and off-site Mutual Aid drills 7. Address Community Issues and Concerns MANAGEMENT OF CHANGE Technical Engineering Mgr. Technical Engineering Services 1. Coordinate MOC process Projects Mgr. Major Projects 2. Track MOC process 3. Maintain MOC database and change record keeping 4. Training of Technical, Operations, Projects and Engineering employees 5. PSR & PSSR coordination and record keeping TRAINING Training Coordinator Central Maintenance Dept. 1. Coordinate NRC Employee Training Process 2. Track employee training compliance POSITION DEPARTMENT PROGRAM RESPONSIBILITY PROCESS HAZARDS ANALYSIS PHA Coordinator Health, Safety and Enviro nmental 1. Coordinate and facilitate PHA process 2. Training of PHA team members in PHA process 3. Identify process hazards and mitigation items 4. Tracking of PHA mitigation items 5. Communication with Management on findings CONTRACTOR MANAGEMENT Contractor Coordinator Central Maintenance 1. Coordinate Contractor Management Process 2. Contractor training 3. Conduct contractor communication 4. Conduct contractor compliance audits 5. Track contractor injury / illness statistics MECHANICAL INTEGRITY Manager Central Maintenance 1. Maintain maintenance procedures 2. Coordinate maintenance training 3. Coordinate maintenance scheduling Manager - Total Productive Central Maintenance 1. Reliability program coordination Equipment Management / 2. Systems integrity coordination Root Cause Analysis 3. Positive materia l identification (PMI) Manager - Control Systems Technical Engineering Services 1. Process information update Engineering (CSE) 2. Protective Instrument Systems Assurance 3. Update control system instrumentation procedures and documentation Manager - Inspection and Technical Engineering Services 1. Equipment integrity / reliability Pressure Equipment 2. Materials inspection 3. Inspection / auditing 4. Update inspection documentation and procedures Manager - Mechanical Technical Engineering Services 1. Equipment integrity / reliability Integrity 2. Equipment testing 3. Inspection / auditing 4. Update inspection documentation and procedures POSITION DEPARTMENT PROGRAM RESPONSIBILITY INCIDENT INVESTIGATION Incident Investigation Team Technical Engineering Services 1. Incident investigation Coordinator 2. Root Cause Analysis 3. Identify & track mitigation items ASSURANCE PROGRAM Manager - Assurance Systems Health, Safety and Environmental 1. Tracking PSM, PHA, audit mitigation Development items 2. PSM program development COMPLIANCE AUDITS PSM Coordinator Health, Safety and Environmental 1. Develop PSM audit (Safety Engineer) / 2. Perform PSM audit Safety Inspectors 3. Track mitigation of findings 4. Internal Company audit mitigation tracking 5. Underwriter audit mitigation tracking PERMITTING PROCESS Manager - Operating Depts. Refining Operations Department 1. Coordinate permit process Manager - Health and Safety Health, Safety and Environmental 2. Coordinate hot work permit process 3. Resolve field permit issues STATIONARY SOURCE AND REGULATED SUBSTANCES The MOTIVA Enterprises LLC - Norco Refining Company operates a variety of processes to produce petroleum based products (e.g., natural gas, pr opane, butane, condensate, oil products, gasoline, etc.) from raw crude oil. The refinery stores and uses a variety of flammable substances most of which are in the form of mixtures that are termed "feed stocks". Storage of the pure flammables (i.e., propane, butane, 1,3 - butadiene) takes place in the tank farm areas. In addition, the refinery uses chlorine, ammonia, methyl mercaptan, and hydrogen chloride in a variety of processes. The following is a list of chemicals or mixtures of chemicals that the EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release. Our accidental release prevention programs, designed control systems and our emergency contingency planning efforts help us effectively manage those hazards that are posed to our employees, the public, and the environment by our use or processing of these chemicals. RMP Listed Flammable Hydrocarbon Inventory Unit / Process Process Equipment Chemical(s) Amount Usage Alkylation DIB fractionator Depropanizer Treater DIB Treater Dimersol Reactor Reactors / Settlers Butane, Isobutane, Propane, Propylene 1,050,000 Unit Feed Stock Coker Coke Drum Overhead Coke Drums Ethane, 2-penten, propane, propylene 60,000 Unit Feed Stock Cat Reformer (CR-1) Stabilizer Accumulator Product Separator Feed Surge Drum Reactors / Furnaces Ethane, Hydrogen, Methane, Propane, 1-pentene 911,000 Unit Feed Stock Cat Reformer (CR-2) Stabilizer Accumulator Product Separator Feed Surge Drum Reactors / Furnaces Absorber Butane, Ethane, Hydrogen, Isobutane, Isopentane, Methane, 1-pentene, Propane 2,110,000 Unit Feed Stock Distilling (DU-5) / SATS GAS Vacuum Flasher, Debutanizer, Depropanizer Rectified Absorber Accumulator Butane, Ethane, Hydrogen, Isobutane, Isopentane, Methane, Pentane, Propane, 1-pentene 7,486,000 Unit Feed Stock Hydroprocessing / Hydrogen Plant 1st Stage Reactors 2nd Stage Reactors Furnaces Compressors Exchangers, Reboiler s Butane, Ethane, Hydrogen, Isobutane, Isopentane, Methane, Propane 1,345,000 Unit Feed Stock Product Assurance Product Storage Product Blending Spheres Storage Tanks Blend Drums Accumulators Butane, 1,3-Butadiene, 1-butyne, 1-butene, 3-methyl-1-butene, 2-cis-butene, 2-methyylpropene, 2-trans-butene, Isobutane, Propadiene, Vinyl acetate, Pentane, Isopentane, Isoprene, 1-pentene, 2-pentene, 2-methyl-butene, Propane, Propylene 74,500,000 Unit Feed Stocks Product Storage Cat Cracker Rectified Absorber, Depropanizer, Debutanizer, Fractionator, Exchangers, Furnaces, Regenerator 2-butene, Butane, Isobutane, Propane, Propylene 1,450,000 Unit Feed Stock Sec-butyl Alcohol (SBA) BB Splitter, Exchangers 2-butene, Butane, Pentane, Isobutane 680,000 Unit Feed Stock Sulfur Plant S-3 Scot Reactor, Claus Unit Hydrogen 52,500 Unit Feed RMP Listed Toxic Substances Inventory Unit / Process Process Equipment Chemical(s) Amount Usage Alkylation Storage Tank and piping Hydrochloric Acid 88,130 pH control Storage Tank and piping Ammonia 17,000 pH Control Product Assurance Storage tank and piping Methyl Mercaptan 30,000 Odorant added to odorless gases Storage tank and piping Ammonia 41,000 pH Control OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. Worst-case Toxic Release Scenario - Methyl Mercaptan 1. Scenario Information and Basis for Selection: The methyl mercaptan storage tank (PV-504) is located at the Product Assurance Tank Car Loading Rack and is used as an odorant in L PG and other odorless gases. The release calculations assume urban topography conditions due to the surrounding congestion at the tank car loading area. The vessel contains 30,000 lbs. of methyl mercaptan. This scenario was selected due to the amount stored in the vessel and it's proximity to public receptors. 2. Release Description: The release of methyl mercaptan occurs as a result of complete vessel rupture and loss of integrity. The entire 30,000 lbs. of material is released over a 10 minute period. 3. Assumptions and Mitigation Measures: The vessel is maintained at an 80% inventory level (i.e., Passive mitigation) as dictated by operating procedures. The assumption here is that the vessel is kept at not more than 80%. 4. End Point Distance: Based on calculations performed via the EPA Look-up Tables (RMP Off site Consequence Analysis Guidance Booklet) the toxic endpoint (based on the AIHA Emergency Response Planning Guidelines ERPG-2 level endpoint of 0.049 mg / L ) was calculated at 6.3 miles (33,200 feet). 5. Public and Environmental Receptors: There are approximately 30,000 individuals that could potentially be affected by this release. The closest environmental receptor is Bayou Trepagnier which is considered a Designated Scenic Stream by the Louisiana Department of Wildlife and Fisheries. This is located adjacent to the fenceline at the North Property storage and treatment area. The population and environmental receptor assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. Alternative Toxic Release Scenario - Methyl Mercaptan 1. Scenario Information and Basis for Selection: The methyl mercaptan storage tank (PV-504) is located at the Product Assurance Tank Car Loading Rack and is used as an odorant in LPG and other odorless gases. The release calculations assumes urban topogra phy conditions due to the surrounding congestion at the tank car loading area. This scenario was selected due to (1) a history of 3 similar releases that occurred over the last 8 years on this vessel during transfer operations and (2) the location of the vessel with respect to offsite receptors. 2. Release Description: The release of methyl mercaptan occurs as a result of a 2" transfer hose line leak during vessel charging. A calculated amount of 1,160 lbs. of methyl mercaptan will be released in approximately 2-3 minutes before mitigation of the leak can occur. 3. Assumptions and Mitigation Measures: It is assumed that the vessel is operating at normal temperature, flow and pressure when the release occurs. Passive mitigation: The vessel is maintained at an 80% inventory level as dictated by operating procedures. Active mitigation: Operator surveillance of the actual loading process allows quick action to mitigate the leak. Operator intervention includes the closing of is olation valves, applying water to the leak area from fixed deluge system and area fire water monitors. The truck driver will also close the loading valves on the truck to minimize the amount of methyl mercaptan leakage. 4. End Point Distance Non-Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the toxic endpoint (based on the AIHA Emergency Response Planning Guidelines ERPG-2 level endpoint of 0.049 mg / L ) was calculated at 0.85 miles (4480 feet). Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the toxic endpoint (based on the AIHA Emergency Response Planning Guidelines ERPG-2 level endpoint of 0.049 mg / L ) was calculated (after passive and active mitigation steps were considered) at 0.36 miles (1890 feet). 5. Public and Environmental Receptors Non-Mitigation Measures : There are approximately 2,675 ind ividuals that could potentially be affected by this release. The population receptor assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. There was no impact to environmental receptors. Mitigation Measures : There are approximately 526 individuals that could potentially be affected by this release. The population assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. Alternative Toxic Release Scenario - Anhydrous Ammonia 1. Scenario Information and Basis for Selection: The anhydrous ammonia storage tank (PV-82) is located adjacent to the Product Assurance W Tank storage area and is used in liquid and gas scrubbing systems and for pH control at the Alkylation plant. T he release calculations assumes rural topography conditions due to lack of congestion near the W tank area. This scenario was selected due to the volume stored and the proximity to off site receptors. 2. Release Description: The release of ammonia occurs as a result of a 2" transfer hose line leak during vessel charging. A calculated amount of 835 lbs. of ammonia will be released in approximately 5 minutes before mitigation of the leak can occur. 3. Assumptions and Mitigation Measures: It is assumed that the vessel is blocked in and isolated during vessel charging. Passive mitigation: The vessel is maintained at an 80% inventory level as dictated by operating procedures. Active mitigation: Operator and truck driver surveillance of the actual loading process allows quick action to mitigate the leak. Operator intervention includes the closing of isolation valves, applying water to the leak area from fixed deluge system and area fire water monitors. The truck driver will a lso close the loading valves on the truck to minimize the amount of ammonia leakage. Hazmat and fire brigade teams will be called to respond to the spill incident. 4. End Point Distance Non-Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the toxic endpoint (based on the AIHA Emergency Response Planning Guidelines ERPG-2 level endpoint of 0.14 mg / L ) was calculated at 0.31miles (1640 feet). Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the toxic endpoint (based on the AIHA Emergency Response Planning Guidelines ERPG-2 level endpoint of 0.14 mg / L ) was calculated (after passive and active mitigation steps were considered) at 0.19 miles (1000 feet). 5. Public and Environmental Receptors Non-Mitigation Measures : There are approximately 235 individuals that could potentially be affected by this release. The population receptor assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. There was no impact to environmental receptors. Mitigation Measures : There are no (0) individuals that could potentially be affected by this release. The population assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. There was no impact to environmental receptors. Alternative Toxic Release Scenario - Hydrochloric Acid 1. Scenario Information and Basis for Selection: The hydrochloric acid storage tank (L-432) is located in the Kerosene Treater portion of the Alkylation Unit. It is used for pH control in the feedwater to the Biotreater System. The release calculations assumes urban topo graphy conditions due to the surrounding congestion in the Kerosene Treater area. This scenario was selected due to (1) a history of similar releases that occurred over the last 8 years on this tank during transfer operations and (2) the location of the vessel with respect to offsite receptors. 2. Release Description: The release of hydrochloric acid occurs as a result of a 3" transfer hose line leak during vessel charging. A calculated amount of 28,900 lbs. of methyl mercaptan will be released in approximately 10 minutes before mitigation of the leak can occur. 3. Assumptions and Mitigation Measures: It is assumed that the tank is isolated from active processes during transfer operation. Passive mitigation: The vessel is maintained at an 80% inventory level as dictated by operating procedures. The tank is located within a diked area. Active mitigation: Operator and truck driver surveillance of the actual loading process allows quick action to mitigate the leak. Operator a nd truck driver intervention includes the closing of isolation valves, applying water to the leak area area fire water monitors. The truck driver will also close the loading valves on the truck to minimize the amount of hydrochloric acid leakage. The Hazmat Team and fire brigade will be responding. 4. End Point Distance Non-Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the toxic endpoint (based on the AIHA Emergency Response Planning Guidelines ERPG-2 level endpoint of 0.030 mg / L ) was calculated at 0.19 miles (1000 feet). Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the toxic endpoint (based on the AIHA Emergency Response Planning Guidelines ERPG-2 level endpoint of 0.030 mg / L ) was calculated (after passive and active mitigation steps were considered) at 0.04 miles (211 feet). 5. Public and Env ironmental Receptors Non-Mitigation Measures : There are approximately 100 individuals that could potentially be affected by this release. The population receptor assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. There was no impact to environmental receptors. Mitigation Measures : There are approximately 34 individuals that could potentially be affected by this release. The population assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. There was no impact to environmental receptors. Worst-case Flammable Release Scenario - Amylene Sphere 1. Scenario Information and Basis for Selection: The Amylene Sphere (S-408) is located in mid-property tank farm. Amylene is mixture of isopentane isomers and is used as a blending agent in gasoline. The release calculations assumes rural topography conditions due to the lack of congestion in the surrounding tank farm. The sphere contains 5,970,000 lbs. of amylene. This scenario was selected due to the amount stored in the sphere and it's proximity to public receptors. 2. Release Description: The release of amylene occurs as a result of complete sphere rupture and loss of integrity. The entire 5,970,000 lbs. of material is released instantaneously. 3. Assumptions and Mitigation Measures: The sphere is kept at a 90% capacity (i.e., Passive mitigation) as dictated by operating procedures. 4. End Point Distance: Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the 1-psi endpoint (based on the TNT-equivalency method) was calculated at 1.6 miles (8,350 feet). 5. Public and Environmental Receptors: There are approximately 4,400 in dividuals that could potentially be affected by this release. The closest environmental receptor is Bayou Trepagnier which is considered a Designated Scenic Stream by the Louisiana Department of Wildlife and Fisheries. This is located adjacent to the fenceline at the North Property storage and treatment area. The population and environmental receptor assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. Worst-case Flammable Release Scenario - 1,3 - Butadiene Sphere 1. Scenario Information and Basis for Selection: The 1,3 - Butadiene Sphere (S-411) is located in north -property tank farm. 1,3-Butadiene is used as a blending agent in making plastics and other polymers. The release calculations assumes rural topography conditions due to the lack of congestion in the surrounding tank farm. The sphere contains 9,770,000 l bs. of 1,3-Butadiene. This scenario was selected due to the amount stored in the sphere and it's proximity to public receptors. 2. Release Description: The release of 1,3-Butadiene occurs as a result of complete sphere rupture and loss of integrity. The entire 9,770,000 lbs. of material is released instantaneously. 3. Assumptions and Mitigation Measures: The sphere is kept at a 80% capacity (i.e., Passive mitigation) as dictated by operating procedures. 4. End Point Distance: Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the 1-psi endpoint (based on the TNT-equivalency method) was calculated at 1.7 miles (9,000 feet). 5. Public and Environmental Receptors: There are approximately 3,400 individuals that could potentially be affected by this release. The closest environmental receptor is Bayou Trepagnier which is considered a Designated Scenic Stream by the Louisiana Department of Wildlife and Fisheries. This is located adjacent to the fenceline at the North Property storage and treatment area. The population and environmental receptor assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. Alternative Release Flammable Scenario - Propane Vessel 1. Scenario Information and Basis for Selection: The propane storage vessel (PV-497) is located at the Product Assurance Tank Truck Loading Rack and is sold as a fuel product. The release calculations assumes urban topography conditions due to the surrounding congestion at the tank truck loading area and neighboring rail car storage location. This scenario was selected due to the volume of propane stored and the location of the vessel with respect to offsite receptors. 2. Release Description: The release of propane occurs as a result of a 1" leak on a 3" flange and pipe connect ion. The flange is elevated above the vessel on a top feed line downstream of the propane metering skid. A calculated amount of approximately 56,000 lbs. of propane will be released in 25 minutes before mitigation of the leak can occur. 3. Assumptions and Mitigation Measures: It is assumed that the vessel is operating at normal temperature, flow and pressure when the release occurs. This leak will be detected visually by the unit operator, security guard or contractor truck driver. Passive mitigation: The vessel is maintained at a 70% inventory level as dictated by operating procedures. Active mitigation: Operator intervention includes the closing of isolation valves at the propane skid to stop feed to the vessel, applying water to the leak area from fixed deluge system and area fire water monitors. To prevent backflow of propane from the vessel to the leak area, the Emergency Response Teams will hook up a water stream to the upstream side of the 3" flange and force water to the flange to stop the propane from leaking. The ER Team will then tighten the flange to eliminate the leak. 4. End Point Distance: Non-Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the 1-psi endpoint (based on the TNT-equivalency method) was calculated at 0.072 miles (383 feet). Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the 1-psi endpoint (based on the TNT-equivalency method) was calculated (after passive and active mitigation steps were considered) at 0.057 miles (303 feet). 5. Public and Environmental Receptors: Non-Mitigation Measures : There are approximately 61 individuals that could potentially be affected by this release. The population receptor assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. There was no impact to environmental receptors. Mitigation Measures : There are approximately 34 individuals that could potentially be affected by this release. The population receptor assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. There was no impact to environmental receptors. Alternative Release Flammable Scenario - Propylene Vessel 1. Scenario Information and Basis for Selection: The propylene storage vessel (PV-503) is located in the BPS Unit (Product Assurance). Propylene is sold as a fuel product. The release calculations assumes rural topography conditions due to the lack of surrounding congestion in the BPS area. This scenario was selected due to the volume of propylene stored, storage pressure and the location of the vessel wi th respect to offsite receptors. 2. Release Description: The release of propylene is from an 8" feedline flange (2" leak opening in the flange). The flange is located at grade. A calculated amount of approximately 229,000 lbs. of propylene will be released in 25 minutes before mitigation of the leak can occur. 3. Assumptions and Mitigation Measures: It is assumed that the vessel is operating at normal temperature, flow and pressure when the release occurs. This leak will be detected visually by the unit operator or contractor. Passive mitigation: The vessel is maintained at a 80% inventory level as dictated by operating procedures. Active mitigation: Operator intervention includes the closing of an ESD valve from the control building to stop feed out of and into the vessel, applying water to the leak area from fixed deluge system and area fire water monitors. The operator will notify the Site Supervisor who will inturn notify the fire brigade to respond. The fire brigad e will hook up water to the upstream side of the ESD valve and flow water through the flange to rduce the amount of leakage. The fire brigade will then tighten up the flange to stop the leak completely. 4. End Point Distance: Non-Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the 1-psi endpoint (based on the TNT-equivalency method) was calculated at 0.15 miles (801 feet). Mitigation Measures : Based on calculations performed via the EPA Look-up Tables (RMP Offsite Consequence Analysis Guidance Booklet) the 1-psi endpoint (based on the TNT-equivalency method) was calculated (after passive and active mitigation steps were considered) at 0.11 miles (568 feet). 5. Public and Environmental Receptors: Non-Mitigation Measures : There are approximately 100 individuals that could potentially be affected by this release. The population receptor assessment was calculated using the 1995 US Depart ment of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. There was no impact to environmental receptors. Mitigation Measures : There are approximately 34 individuals that could potentially be affected by this release. The population receptor assessment was calculated using the 1995 US Department of Commerce, Economics and Statistics Administration, Bureau of the Census Landview III Environmental Mapping Software for the Texas and Louisiana Region. There was no impact to environmental receptors. ACCIDENT PREVENTION PROGRAM AND PROCESS SAFETY The following is a summary of the general accident prevention program in place at the MOTIVA - Norco Refining Company. Due to the fact that all of the processes at the refinery are regulated by the EPA RMP and the OSHA PSM regulations, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. Employee participation The MOTIVA ENTERPRISES LLC - Norco Refining Company encourages employees to participate in all facets of the Process Safety Management Programs. Examples of employee participation range from updating and compiling technical documents and process information to participating on a number of safety and departmental committees. Employees currently participate on the Process Hazards Analysis (PHA) Teams. The various teams and committees are composed of operations, m aintenance, engineering and management. Specific examples of the various teams, committees and forums that employees participate in is documented in our site employee participation procedure. This procedure is maintained and updated by the NRC Health and Safety Department. Employees have access to all process safety information, MSDS, process technical information, maintenance practices, accident and incident information and all process improvement information. Process safety information The MOTIVA ENTERPRISES LLC - Norco Refining Company keeps a variety of technical documents that 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 Process Safety Management Program to help employees locate any necessary process safety information. Chemical-specific information, including exposure hazards and emergency response / exposure treatment considerations, is provided in material safety data sheets (MSDS). 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 developed critical operating variable lists for specific process parameters (e.g., temperature, level, composition). 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., shutdown systems). Our refinery also maintains numerous technical documents that provide information about the desi gn 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 trained 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 MOTIVA ENTERPRISES LLC - Norco Refining Company has a comprehensive program to help ensure that hazards associated with 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 MOTIVA ENTERPRISES LLC - Norco Refining Company primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized a s one of the most systematic 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/or mitigation measures when the team believes such measures are necessary. The PHA Team findings are forwarded to local and corporate 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 eventually deviate significantly fro m the original design safety features, the MOTIVA ENTERPRISES LLC - Norco Refining Company 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 and retained. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained. Operating procedures The MOTIVA ENTERPRISES LLC - Norco Refining Company 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 annually 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 MOTIVA ENTERPRISES LLC - Norco Refining Company maintains a Key Parameter Document 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. Training To complement the written procedures for process operations, the MOTIVA ENTERPRISES LLC - Norco Refining Company has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery operations if they are not already familiar with such operations. After successfully completi ng this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through skills, 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. Operator re-qualification and re-certification takes place every six months and three years respectively. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The MOTIVA ENTERPRISES LLC - Norco Refining Company 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 t o 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 the 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 MOTIVA ENTERPRISES LLC - Norco Refining Company evaluates contractor safety programs and performance during the selection of a contractor. Refinery personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup review (PSSR) The MOTIVA ENTERPRISES LLC - Norco Refining Company conducts 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 service. 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 PSR review team 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. Mechanical integrity The MOTIVA ENTERPRISES LLC - Norco Refining Company 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 asp ects of this program include: (1) conducting training, (2) develop written procedures, (3) performing inspections and test, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical 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 an MOC 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 MOTIVA ENTERPRISES LLC - Norco Refining Company 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 Procedures / Permitting The MOTIVA ENTERPRISES LLC - Norco Refining Company 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 p rocess piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work, welding, etc.), 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 MOTIVA ENTERPRISES LLC - Norco Refining Company 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 change. Incident investigation The MOTIVA ENTERPRISES LLC - Norco Refining Company 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 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 recommend ation 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 5 years so that the reports can be reviewed during future PHA's and PHA revalidations. Compliance audits To help ensure that the accident prevention program is functioning properly, the MOTIVA ENTERPRISES LLC - Norco Refining Company periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three 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 repor ts are retained. FIVE - YEAR ACCIDENT HISTORY The MOTIVA ENTERPRISES LLC - Norco Refining Company has an excellent record of accident prevention over the last 6 years; the frequency of accidental releases has decreased. Records and documentation are kept for all significant accidental releases. For each of these incidents, we have conducted formal incident investigations to identify, correct the root cause(s) and determine ways to prevent similar incidents from occurring. The following is a brief summary of the accidents that have occurred over the last five years that fit the RMP reporting criteria. Date of Incident Unit Substance / Amount Release Event RMP Category 6/8/93 Product Assurance H2SO4 - 44,000 lbs. Pipeline Leak Off-site Impact / Public Evac. 9/3/94 Fractionation Plant Propane, Isobutane, Pressure vessel relief Off-site Impact / Butane - 253,000 lbs. Public Road Closure 12/16/94 Coker Hydrocarbons - 475 lbs. Coke drum rel ease On-site Impact 7/19/95 Distilling Hydrocarbons - 2080 lbs. Piping failure On-site Impact 8/20/95 Alkylation Propane, Isobutane - 855 lbs. Pressure vessel relief On-site Impact 10/14/96 Distilling Hydrocarbons - 20,000 lbs. Bleeder valve failure On-site Impact 1993 1994 1995 1996 1997 1998 1999 No. of RMP events w/ 0 1 2 1 0 0 0 On-site Impact No. of RMP events w/ 1 1 0 0 0 0 0 Off-site Impact EMERGENCY RESPONSE PROGRAM The MOTIVA ENTERPRISES LLC - Norco Refining Company 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 decontamination requirements. In addition, the MOTIVA ENTERPRISES LLC - Norco Refining Company 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 emergency response program changes are administered through the MOC process, which includes informing and / or training affected personnel in the changes. The overall emergency response program for the MOTIVA ENTERPRISES LLC - Norco Refining Company is coordinated with the St. Charles Parish, Louisiana Local Emergency Planning Committee (LEPC) and the St. Charles Parish Department of Emergency Preparedness. This coordination includes periodic meetings of the committees, which includes local emergency response officials, local government officials, community members and industry representatives. The MOTIVA ENTERPRISES LLC - Norco Refining Company has around - the - clock communications capability with appropriate LEPC and DEP officials and emergency response organizations (e.g., fire departments). 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 and DEP meetings, the MOTIVA ENTERPRISES LLC - Norco Refining Company conducted periodic emergency drills that involve the LEPC, DEP, and emergency response organizations (e.g., Mutual Aid Organization), and the refinery provides annual refresher training to local emergency responders regarding the hazards of re gulated substances in the refinery. PLANNED CHANGES TO IMPROVE PROCESS SAFETY, RELIABILITY AND LOSS CONTROL The MOTIVA ENTERPRISES LLC - Norco Refining Company has made considerable progress in the areas of process safety, operations and equipment reliability, maintenance effectiveness and control systems improvement. Norco Refining Company has developed and implemented a number of programs and processes designed to enhance the safe operation and maintainability of our facility. The following is a list of current activities underway at the Norco Refining Company representative of the commitment to creating a safe workplace for our employees and also to assure our neighbors that effort to promote our employees a safe place to work and our neighboring community members continued confidence in our efforts to create a safe Chemical Reduction 1. Inventory Control - Identify opportunities to provide process units with as-needed inventory levels to reduce excess volume of materia ls on-site. Program / Process Assurance 1. Internal Auditing Programs - Process Safety Management auditing of programs, procedures and activities to assure compliance with state regulations, federal regulations and best industrial practices. 2. External Auditing Programs - Insurance Underwriter Audits are conducted to determine compliance with best industrial practices with regard to safety and loss protection. 3. The tracking of department efforts to mitigate audit findings, PHA findings and Incident investigation - Root Cause Analysis findings. 4. Process Hazards Analysis - revalidation every 5 years according to OSHA PSM regulation. Equipment / Process Reliability 1. Control System Engineering - Improved control systems in control buildings. 2. Inspection and Pressure Equipment - Equipment inspection initiatives (i.e., piping, pressure vessels, compressors, etc.) - Equipment Requiring Inspection (ERI) - tracking of equipment requiring inspection. - Corrosion Control Do cuments - identification of all active corrosion mechanisms (selecting most appropriate inspection tools, appropriate material selections and reviews for plant changes, identify critical variables for corrosion control). * Dead Leg and Injection Point Corrosion Identification Process. * Corrosion Under Insulation (CUI) - maintenance of coating and insulation on equipment. * Pipe rack and piping corrosion inspection. * Risk Based Inspection (RBI) - a quantitative risk assessment (likelihood and consequence of failure) based inspection program. 3. Mechanical Equipment - equipment inspection initiatives (i.e., pumps, turbines, rotating equipment, etc.) 4. Maintenance - Positive Material Identification (PMI) - identification and tracking of equipment quality and suitability prior to installment in operating units. - Total Productive Equipment Management (TPEM) - improve reliability, lifetime and maintenance of equipment. Safeguarding 1. Protective Instrument Systems (PIS) - protecti ve instrumentation designed to prevent a catastrophic incident. (shutdown system, alarms, high temperature, high pressure indication, etc.) 2. Design practices for further construction of process units (installation of shutdown systems, relief systems. 3. Development of safeguarding memorandums for every operating unit. 4. Inspection and Pressure Equipment - alternate relief systems to prevent loss of integrity in process equipment. Training 1. Continual training and job qualification of operations employees. 2. Mandatory safety training courses for all employees at Norco. Emergency Response 1. Continual training of Emergency Response and HAZMAT Teams. 2. Purchase of two 6,000 gallon per minute tank fire fighting nozzels. 3. Addition of mobile fire attack pick-up trucks with 1,000 gallon per minute nozzels. 4. Upgraded fire water supply system to increase water flow and pressure to unit boundaries. 5. Upgraded community communication system in cooperation with St. Charles Paris h Department of Emergency Preparedness (DEP) CERTIFICATION STATEMENT FOR PROGRAM LEVEL 2 & 3 PROCESSES: Based on the criteria in 40 CFR 68.185, The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete. Name: William K. Marquis CIH CSP Signature : Title : Senior Safety Engineer Date : |