Claiborne Energy, LLC - Executive Summary
EXECUTIVE SUMMARY |
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
At Claiborne Energy, we handle flammable substances considered hazardous by the U.S. Environmental Protection Agency (EPA). It is necessary to observe certain safety precautions in handling flammable substances to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of our community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends on the manner in which we handle flammable substances, the safety devices inherent in the design of the facility, the safe handling procedures that we use, and the training of our personnel.
We at Claiborne Energy are strongly committed to employee, public, and environmental safety. This commitment is demonstrated by our accidental release prevention program that covers areas such as design, installation, operating proce
dures, 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. If an accidental release should occur, the facility is prepared to work with the Mexia Fire Department, and other authorities, to mitigate any release and minimize the impact of the release to people and the environment.
FACILITY DESCRIPTION AND REGULATED SUBSTANCES HANDLED
Claiborne Energy fractionates liquefied petroleum gas into natural gasoline, n-butane, iso-butane, and propane. Transfer pumps are used to transfer feedstocks and product between the storage tanks and truck transports. Access to the facility is restricted to authorized facility employees, authorized management personnel, and authorized contractors. However, a trucking company is co-located on the same property as the facility.
The regulated substances handled at Claiborne Energy are n-butane, iso-butane, and propane
. The maximum quantity of n-butane that can be stored at this facility is 510,000 pounds. The maximum quantity of iso-butane that can be stored at this facility is 390,000 pounds and the maximum quantity of propane that can be stored at the facility is 480,000 pounds.
THE WORST-CASE RELEASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIO, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO
The EPA defines worst-case release scenario as the failure of our largest storage tank when filled to the greatest amount allowed. The entire contents of the tank are assumed to release as a vapor cloud, which finds an ignition source. Ten percent of the released quantity is assumed to participate in the resulting explosion.
The worst-case scenario as defined by the EPA is highly unlikely to occur. During the evaluation, the scenario assumes none of the facility's mechanical controls or safety systems are operational, assumes no emergency
response efforts take place, and assumes it occurs under the worst weather conditions.
Claiborne Energy's worst-case flammable release scenario would result in a release of 230,000 pounds of n-butane. To evaluate the worst-case release scenario, we have utilized RMP*Comp, the EPA recommended software. Based on 230,000 pounds of n-butane released, the distance the affects of a vapor cloud explosion is expected to have no serious harm to the general public is 0.5-mile from the location of the storage tank.
According to RMP regulations, analysis is required on one flammable substance with the greatest distance endpoint. RMP*CompTM results indicate a worst-case release of 130,000 pounds of iso-butane has a hazard endpoint distance of 0.4-mile and 120,000 pounds of propane has a hazard endpoint distance of 0.4-mile. Therefore, analysis is only required on n-butane since the endpoint distance is greater than iso-butane and propane.
The EPA states an alternative release scenario as
a release that is more likely to occur than the worst-case scenario and will reach an endpoint off-site. Active and passive mitigation systems may be considered for the alternative release scenario.
The alternative release scenario deemed most likely to occur is the failure of a flexible transfer hose while transferring n-butane between a truck transport and a storage tank. The flexible transfer hose has a nominal diameter of 3-inches. Excess flow valves would function to stop the flow of n-butane between the truck transport and the storage tank, thereby limiting the release to the contents contained within the hose.
In this alternative release scenario, 110 pounds of n-butane would be released. RMP*Comp, modeled the distance endpoint for the release of 110 pounds of n-butane to no longer pose a hazard to the public as 0.02-mile.
THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PREVENTION STEPS
Claiborne Energy observes the Occupational Safety and Health Ad
ministration (OSHA)'s Process Safety Management (PSM) rule, EPA's Accidental Release Prevention Rule, and with applicable state codes and regulations. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Claiborne Energy maintains a record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the regulated processes.
Process Hazard Analysis
Our facility conducts studies to ensure the hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is a "What if" checklist. The studies are conducted by a team of qualified personnel with expertise in engineering and process operations and are revalidated at least once every five years. Any findings related to the hazard review are addressed in a timely manner.
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.
Claiborne Energy has a training program to ensure employees are competent in the operations and procedures associated with the processes.
Claiborne Energy carries out maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks include; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. 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 Claiborne Energy to manage chang
es in process chemicals, technology, equipment, and procedures. 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-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Claiborne Energy. The reviews are conducted to confirm that construction, equipment, operation, and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Claiborne Energy conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
Claiborne Energy inve
stigates any incident that resulted in, or could reasonably result in a catastrophic release of regulated chemicals. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All investigation reports are retained for a minimum of five years.
It is our belief at Claiborne Energy, that process safety management and accident prevention are a team effort. Our employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.
Claiborne Energy hires contractors to conduct specialized maintenance or construction activities. We have a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of emergency response procedures should an accidental release occur.
FIVE-YEAR ACCIDENT HISTORY
e been no accidental release of regulated or other chemicals during the last five years that resulted in deaths, injuries, or significant property damage onsite, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
EMERGENCY RESPONSE PROGRAM
Claiborne Energy has a written emergency action plan, in accordance with OSHA standard 29 CFR 1910.38(a). The plan includes all aspects of emergency response including pre-emergency planning, employee training, adequate first aid and medical treatment, evacuations, notifications of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.
PLANNED CHANGES TO IMPROVE SAFETY
Safety improvement is an on-going process at Claiborne Energy. Periodic evaluations are performed to assess the maintenance of safe conditions. We will continue to work to improve our process safety and risk management programs.