ERGON-West Virginia, Inc. - Executive Summary |
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Facility Overview: ERGON-West Virginia, Inc. (Ergon) owns and operates an oil refinery in Newell, WV. The Newell facility has one chemical (propane) above the defined thresholds for which Risk Management Planning (RMP) is required. Because the facility is also subject to the Process Safety Management (PSM) standard for propane, has the potential to cause an offsite consequence, and due to the facility's standard industrial classification (SIC) code (2911), the Newell facility is subject to Program 3 requirements of the RMP standards. Chemical Safety Overview: The facility's overall approach and commitment to chemical safety is demonstrated primarily by the existing PSM program for the PSM covered processes. Several of the prevention program elements have been implemented facility-side such as management of change and training. Additionally, Ergon's management structure for RMP implementation involves many key facility personnel including the plant manager, engineering staff, and environmental and safety personnel. Release Scenarios: Worst-case and alternative release scenario assessments were conducted for the Newell facility per the RMP regulations. The United States Environmental Protection Agency's (EPA's) Offsite Consequence Analysis Guidance document was used to assess consequence distances for both the worst-case and alternative scenarios. The worst-case release scenario was determined to be a failure of the largest propane storage vessel at the facility, resulting in a release of 190,000 pounds of propane. This release scenario results in a 0.5-mile distance and has offsite impacts. The alternative scenario assessed for propane involved an economizer small connector failure at the MEK Dewaxer. While the 0.1-mile scenario distance does not leave plant boundaries, there are other potential pulic receptors within plant boundaries in the form of other companies' employees. Five-year Accident History: The facility has had no RMP-reportable accident/ releases within the five years proceeding RMP submittal. Prevention Program: The facility has implemented a Program 3 level Prevention Program, as required by the RMP rules. These prevention program provisions are specifically intended to minimize the probability and consequences of accidental releases from the facility and include such measures as a process hazard analysis, operating and maintenance procedures, training, compliance auditing, management system, and management of change. The facility prevention program is an ongoing system based on periodic training, process hazard analysis, incident investigations, audits, procedure revisions, and RMP updates as required to reflect facility change and RMP requirements. Emergency Response Program: The facility maintains an Emergency Action Plan which addresses the required elements for emergency planning and response. Ergon has coordinated with the local fire department for response to accidental releases of propane. Summary: The RMP for the facility has been completed in accordance with all 40 CFR 68 requirements and the facility has certified RMP compliance. |