El Paso Products Terminal - Executive Summary |
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General Executive Summary for El Paso Products Terminal We at the Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal 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. Our facility's primary activities encompass the storage and sale of motor fuel. We have one regulated substance present at our facility above the threshold quantity: propane. Propane is used for sale. Methyl mercaptan, which is used for odorizing propane before sale, is not held above the threshold quantity. To evaluate the worst case scenarios, we have used the EPA's OCA Guidance Reference Tables or Equations and the EPA's RMP*Comp(TM). For alternative release scenario analyses we have employed the EPA's RMP*Comp(TM). The following paragraphs provide details of the chosen scenarios. The Diamond Shamrock Refining Company, L.P. - El Paso Terminal has invested a great deal of time and effort to reduce the potential of any hazardous material release. These efforts include the stringent design codes that the facility is built to, the routine inspections and monitoring that are performed daily, as well as the periodic internal inspections and repairs. The combination of these four systems ensures that small releases will be addressed quickly and even large releases can be effectively mitigated with no impact on the surrounding community. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from propane storage. In this scenario 391,809 lb. of propane is released from one of the storage tanks without consideration for emergency shutdown valves or oper ator action. The vessel is assumed to be completely full, and that the entire quantity is released as a vapor. The vapor then finds an ignition source, with ten percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance to the 1 psi endpoint will have offsite impacts. The alternative release scenario submitted for Program 3 flammable substances involves a release of propane. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 111,600 pounds of propane in ten minutes from a leak in a pipe. The release is controlled by active mitigation measures that include Emergency Shut Off valves. After comparing the effects of fire and overpressure, the vapor cloud explosion scenario was chosen as worse than fire. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure would not involve offsite effects. The General Acciden tal 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. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with the facility. Process Hazard Analysis Our facility conducted a comprehensive study to ensure that hazards associated with our facility were identified and controlled effectively. The methodology used to carry out this analysis is a Hazard and Operability Study (HAZOP). The study was undertaken by a tea m of qualified personnel with expertise in engineering and process operations and will revalidated at a regular interval of every five years. Findings related to the hazard analysis were addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal 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. Training Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal 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. Refr esher training is provided at least every three years and more frequently as needed. Mechanical Integrity Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified personnel carry out maintenance operations. 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 Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal to manage changes in process chemicals, technology, equipment and procedures. 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-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal 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. Incident Investigation Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal 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 five years. Employee Participation Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal 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. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety perf ormance of the contractor is carried out. Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal 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 Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal has had an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Diamond Shamrock Refining Company, L.P. - El Paso Products Terminal 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 loc al 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. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Monthly safety training, operator training and certification are some of the major steps we are taking to improve safety at our facility. These changes are currently implemented and continuous. |