Coastal Eagle Point Oil Company - Executive Summary |
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Coastal Eagle Point Oil Company (CEPOC) Risk Management Plan: Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Coastal Eagle Point Oil Company has a longstanding commitment to worker and public safety. This commitment is demonstrated by refinery programs that have been developed to support accident prevention, such as detailed operator training, qualification and refresher training program, annual safety training for all field personnel and consideration for safety in the design, installation, operation, and maintenance of our refinery processes. CEPOC's practice is to determine appropriate administrative and mechanical controls to prevent foreseeable releases of regulated substances. However, if a release were to occur, our response team members are well trained to respond and control the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES Coastal Eagle Point Oil Company, located in Westville, New Jersey, operates a number of different pr ocess functions to produce petroleum products such as gasoline, fuel oil, propane and butane from raw crude oil. The refinery has several regulated flammables, such as propane, butane and intermediate flammables. In addition, the refinery uses chlorine, which is also a regulated substance, for disinfection and treatment of process water at the refinery cooling towers. The entire refinery has been classified as a single process, with multiple production units. This classification ensures that all regulated chemicals that meet the criteria defined by the EPA are included in this program. HAZARD ASSESSMENT RESULTS 40 CFR 68.155(c) The worst case scenario (WCS) associated with toxic substances in the refinery is a catastrophic failure of a one ton cylinder of chlorine. Based on the criteria defined by the EPA, this scenario would result in a release of 2,000 pounds of chlorine gas over a 10-minute period. Although we have numerous controls to prevent such releases and to manage t heir consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating this scenario. The maximum distance to the toxic endpoint for this WCS is 1.3 miles. No Program 1 or 2 processes containing regulated toxic substances were identified at the refinery. The alternative release scenario (ARS) for chlorine is a 3/8 inch valve sheared off due to torque while opening or closing the valve, resulting in a release of 345 lbs. of Chlorine gas over a 10-minute period. The release is expected to be isolated by the operators within 10 minutes (active mitigation). The basis for the 10 minute mitigation is actual response time demonstrated in emergency response drills performed at the site. No other mitigation measures were taken into account in evaluating this scenario. The maximum distance to the toxic endpoint for this scenario is 0.33 miles which does not reach any offsite public receptors. The WCS associated with a release of flamma ble substances in Program 3 processes at the refinery is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing normal Butane. No administrative controls are in place to limit the storage inventory in the tank; therefore, the full tank inventory of 2,520,400 lbs. is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1 psi endpoint for this WCS is 1.09 miles. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for mitigation measures was taken into account when evaluating this WCS. Some of these controls include leak detection, alarms, interlocks, shutdowns, over pressure safeguards and scheduled equipment inspections. The ARS for flammable substances at the refinery is a VCE resulting from the failure of a 4 inch truck loading hose failure. This would result in a release of 1,817 lbs./minute released over a 15-minute period. The release is expected to be isolated by the operators within 15 minutes (active mitigation). The maximum distance to the 1 psi endpoint for this event is less that 0.1 of a mile. This event was selected as a practical scenario for use in emergency planning and response. This ARS also has no off site impact. No Program 1 or 2 processes containing regulated flammable substances were identified at the refinery. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at Coastal Eagle Point Oil Company. The covered process at the refinery that is regulated by the EPA RMP regulation is also subject to the OSHA Process Safety Management standard 29CFR 1910.119 and the NJDEP Toxic Catastrophe Prevention Act program N.J.A.C. 7:31 (1-6). This summary addresses each of these elements and describes the management system in place to implement this program. Employee Participation Coastal Eagle Point Oil Company involves employ ees in the programs developed to support process safety management and accident prevention. Employees are included in every element of the program, from development, to active participation, to program updates. They are members of the process hazard analysis (PHA) team, the compliance audit team and make up the safety and emergency response teams. They implement the mechanical integrity, operator training and contractor safety programs. Employees have access to information created as part of this accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in the employee participation plan that is maintained at the refinery. In addition, the refinery has a number of initiatives under way that address process safety and employee safety issues. These initiatives include development and implementation of systems to promote additional process and personal safety. Process Safety Information Coastal Eagle Point Oil Compan y keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents include information on each production unit and their associated hazards, key process parameters, normal operating procedures, and equipment design basis information. Different departments within the refinery are assigned responsibility for maintaining up-to-date process safety information. A table summarizing these documents, their latest revision dates and their location is readily available to help employees locate information related to the process safety information developed at the refinery. Chemical specific information, including exposure hazards and emergency response exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For each production unit, the refinery has documented operating limits for specific process parameters (e.g., temperature, level and pressure) in the Normal Operating Conditions (NOC) section of the Standard Operating Procedures Manuals. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems such as alarms, interlocks and automatic shutdown systems. Coastal has also developed a document that contains information on the criteria for design and operation used at the site. This document includes a list of industry standards that are referenced in the design and construction of process equipment. This information includes reference to acceptable materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written inspection procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as designing proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) Coastal Eagle Point Oil Company has a comprehensive program to help ensure that hazards associated with the various production units are identified and controlled. Within this program, each production unit is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. Coastal Eagle Point Oil Company primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted by a team of people with operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes sugges tions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team has the support of the refinery management to determine appropriate resolutions and resolve any questions or findings identified during the review. When appropriate, implementation of mitigation options developed 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. 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 from the original design safety features, Coastal Eagle Point Oil Company periodically updates and revalidates the hazard analysis results. These reviews are conducted a t least every 5 years and will be conducted at this frequency until the process is no longer operating. Also, when there are significant changes to a production unit that may require major construction, a HAZOP team will be assembled to review the recommended changes to determine the effect on the existing process before construction design considerations are complete. The results and findings from these review and revalidation activities are documented and retained. Once again, the team findings are reviewed with management for consideration, and the final resolutions are documented and retained. Operating Procedures Coastal Eagle Point Oil Company maintains written procedures that address various operating scenarios, such as (1) unit startup and shutdown, (2) normal operating conditions, abnormal conditions and corrective actions (3) temporary operations, (4) emergency procedures, such as pump or instrumentation failure (5) emergency unit shutdown and (6) initial startup of a ne w process. These procedures are 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. These procedures are maintained by reviewing them as often as necessary to reflect changes made through the management of change process. In addition, Coastal Eagle Point Oil Company maintains a Standard Operating Procedure Document that provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with the additional written operating procedures, is readily available to operators in the control room of each production unit and for other personnel to retrieve and review from the computer network as desired. Operator Training To complement the written procedures for process operations, Coastal Eagle Point Oil Company has a comprehensive training program for employees involved in operating a process. New employees and unit transfers receive basic operator training in refinery operations related to the process to which they are being assigned. After successfully completing this training, a newly assigned operator receives on the job training from a qualified operator to learn unit specific duties and tasks. Operators demonstrate required qualification requirements through written tests, demonstrative skills and oral testing. Once the Unit Supervisor has reviewed the qualification of the Operator, their progress is documented and they are assigned to work the job for which they have just qualified. There are additional qualified operators working at the process unit for operator support. In addition, operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. Operating procedure review and job rotation is performed every year as appropriate. Refresher testi ng is conducted at least every 3 years on all jobs for which an operator is qualified. Training is documented for each operator, including the means used to verify that the operator understood the training. Contractors Coastal Eagle Point Oil Company uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the refinery has procedures in place to 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) sa fe work practices prior to their beginning work. In addition, Coastal Eagle Point Oil 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 Safety Review (PSSR) Coastal Eagle Point Oil Company conducts a 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. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that prev ention program requirements are identified and implemented as appropriate. Mechanical Integrity Coastal Eagle Point Oil Company has 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 aspects of this program include: (1) training, (2) developing written procedures, (3) performing inspections and tests, (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 operating limits. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or qualified personnel will meet to discuss 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. Coastal Eagle Point Oil 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 Practices Coastal Eagle Point Oil 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 process piping or equipment is opened, (4) confined space permit and procedure to ensure that adequate precautions are in place before entry and (5) a hot and safe work permit procedure to control spark-producing activities. These and other safety procedures, along with the training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change Coastal Eagle Point Oil Company has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology and procedures are properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to mana ge any new hazards and to verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, equipment information, procedures and other affected process safety information are updated as required. In addition, training is provided as required for those employees whose job responsibilities may be affected by the change. Incident Investigation Coastal Eagle Point Oil 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, made up of hourly and management personnel, documents its findings, develops recommendations to prevent a recurrence, and forwards these results to refinery management for review. Corrective actions developed in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, Coastal Eagle Point Oil Company conducts a compliance audit every year to determine whether the procedures and practices are being implemented and to evaluate the effectiveness of these programs. This audit is performed on the requirements of all three regulatory programs, (TCPA, PSM and EPA RMP). The audit team develops a report of findings and recommendations. Corrective actions taken in response to the audit team's findings are tracked until t hey are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. CHEMICAL SPECIFIC PREVENTION STEPS As a major facility, Coastal Eagle Point Oil Company submitted a Title V operating permit application to the NJDEP Bureau of Operating Permits on August 19th, 1996. The application is currently under review by the Department. Refinery operation at Coastal Eagle Point Oil Company has hazards just by the nature of the process and the chemicals that are used in refining. Through the implementation of the elements of the prevention program and additional efforts for safety and risk management, these hazards are managed to ensure continued safe operation. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failure or (2) human error. In addition to the accident prevention program activities, Coastal Eagle Point Oil Company has safety features on many un its to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following are examples of some of these safety features used in various processes: Release Detection -Hydrocarbon detectors with alarms Release Containment Control -Process relief valves that discharge to a flare to capture and incinerate spontaneous releases -Valves to permit isolation of the process (manual or automated) -Automatic shutdown systems for critical process -Curbing or diking to contain liquid releases -Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) -Atmospheric relief devices Release Mitigation -Fire suppression and extinguishing systems -Deluge system for specific equipment -Trained emergency response personnel -Personal protective equipment, bunker gear and Nomex clothing FIVE-YEAR ACCIDE NT HISTORY Coastal Eagle Point Oil Company has an excellent record of accident prevention over the past 5 years. None of the incidents that have occurred have resulted in significant property damage onsite or have resulted in offsite consequences. Each incident is investigated very carefully to determine ways to prevent similar incidents from occurring in the future. EMERGENCY RESPONSE PROGRAM INFORMATION Coastal Eagle Point Oil 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 agenc ies and the public if a release occurs, and post-incident cleanup and decontamination requirements. Coastal Eagle Point Oil Company also 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 the refinery or recommendations made by State and/or Federal agencies. The overall emergency response program for Coastal Eagle Point Oil Company is coordinated with the West Deptford Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which has included local emergency response officials, local government officials, and industry representatives. Coastal Eagle Point Oil Company has around-the-clock communications capabil ity with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of quickly alerting outside agencies and determining whether there is a need to notify the public, as well as facilitating quick response to an incident. In addition involvement with local LEPC personnel, the Coastal Eagle Point Oil Company conducts annual emergency drills to which the LEPC is invited to participate. The refinery provides refresher training to local emergency responders regarding the hazards of regulated substances in the refinery. PLANNED CHANGES TO IMPROVE SAFETY Coastal Eagle Point Oil Company resolves findings from PHAs, some of which result in modifications to the process. Annual audits provide recommendations for continual improvement of routine operations and procedures. Coastal Eagle Point Oil Company plans to continue annual auditing of all three regulatory programs which is in excess of the three year auditing requirement identifi ed by the EPA OSHA risk management programs. These audits often result in detailed systems analysis and recommendations for improved implementation and safety practices. Coastal Eagle Point Oil Company plans to continue annual refresher training of operating personnel which is also in excess of the three year refresher training required by all three regulatory programs. Project development is an ongoing activity that contributes to improved safety and operations. These projects are in various stages of planning, development and approval. Examples of these kind of projects include: Pressure control loop modification at the FCCU E9 depropanizer tower. Relocation of H2S monitors at the Isomerization unit. Extension of the plant nitrogen system Installation of a fuel gas shut off valve on HH1 heater |