Occidental of Elk Hills, Inc. - Executive Summary
1. Accidental Release Prevention and Emergency Response Policies |
We at Occidental of Elk Hills, 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
We have 5 regulated substances present at our facility. These substances include Butane, Propane, Ethane, Methane and Ammonia (anhydrous). Butane, Propane, Ethane and Methane are by-products of the gas production process. Ammonia (anhydrous) is used in the Cogeneration Facility.
The maximum inventory of each of our products is: Butane 835680 lbs., Propane 668127 lbs., Ethane 196098 lbs., Methane 104583 lbs.
and Ammonia (anhydrous) 12000 lbs.
3. The Worst Case Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario
To perform the required offsite consequence analysis for our facility, we have used the RMP Submit program supplied by the EPA. Based on the criteria of 40 CFR 68.10, the distance to the specified endpoint for the worst-case scenario for all of our processes is less than the distance to the nearest public receptor. However, our facility does meet the requirements of 29 CFR 1910.119 as outlined in Section 4 below. These provide us with both the necessary administrative controls and mitigation measures necessary to limit the distances of our worst case scenarios.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.
The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Occidental of Elk Hills, 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 HAZOP. 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 35R LOAP in Jan. 97.
For the purposes of safely conducting activities within our covered processes, Occidental
of Elk Hills, 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.
Occidental of Elk Hills, 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.
Occidental of Elk Hills, Inc. carries out highly documented maintenance checks on process 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, contro
ls and pumps. Qualified personnel carry out maintenance operations 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 Occidental of Elk Hills, Inc. to manage changes 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 of established processes are conducted as a regular practice at Occidental of Elk Hills, Inc. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startu
p prior to placing equipment into operation.
Occidental of Elk Hills, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted in Feb. 98. 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.
Occidental of Elk Hills, 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 identify 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.
Occidental of Elk Hills, 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.
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. Occidental of Elk Hills, Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's work 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
Occidental of Elk Hills, Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our
stringent release prevention policies, there has been no accidental release during this period.
6. Emergency Response Plan
Occidental of Elk Hills, 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.