Valero Refining Company - Texas - Executive Summary |
|
1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Valero Refining Comany - Texas, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 7 A description of our facility and use of substances regulated by EPA's RMP regulation 7 A summary of results from our assessment of the potential offsite consequences from accidental chemical releases 7 An overview of our accidental release prevention programs 7 A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 7 An overview of our emergency response program 7 An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment 7 The certifications that EPA's RMP rule requires us to provide 7 The detailed information (called data elements) about our risk management program 2 STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility is a petroleum refinery which produces gasoline, heating fuels, and streams for use as chemical feedstocks, using a variety of processing operations. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics - Hydrogen Fluoride stored in pressure vessels and contained within process unit equipment, and chlorine in one ton containers Flammables - Miscellaneous flammable mixtures and pure component streams, stored in storage tanks and contained within process unit equipment The regulated substances a re contained within the utlities areas of the plant (chlorine) and within the tank farm and specified process units. Several other process units may contain regulated substances, but are either in mixtures that do not meet the definition of a flammable mixture, or are below the threshold quantity. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these substances. 3 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals Valero has chosen to adopt the worst cas e scenario for a release of hydrogen fluoride as put forth in the EPA's Guidance for Offsite Cosequence Analyses. That scenario results in an endpoint distance of approximately 22 miles, although more rigorous dispersion models could be expected to reflect a fraction of that distance. Administrative controls (e.g., inspections, testing, procedures, training) are in place to prevent such a scenario, as well as proven equipment designs. Mitigation measures include water sprays to knock down and disperse a vapor cloud should one occur, TV monitors and other detectors for early recognition of any potential problems, redundant process controls including motor operated valves for rapid isolation, and trained responders for isolation and containment. Alternative Release Scenarios - Regulated Toxics The alternative release scenario reported for hydrogen fluoride involves a failure or inadvertent opening of a small bore valve. The release scenario chosen was based upon unit and industry histories, and might result in an endpoint distance of 0.43 miles. Mitigation measures are the same as stated above. The alternative release scenario for chlorine was put forth in the EPA's Guidance for Wastewater Treatment Plants. The scenario involves a release of 500 pounds per minute from a container, for which the impact radius is 0.37 miles. Mitigation measures include fire water sprays to "knock down" a chlorine cloud should one occur, as well as trained responders for isolation and containment. Worst-case Release Scenario - Regulated Flammable Chemicals The worst case flammable scenario chosen is a large tank in the tank farm area that contains a flammable mixture of hydrocarbons, primarily isobutane. In this case, the endpoint distance (using EPA's OCA lookup tables) is 1.6 miles and the potentially affected residential population is 360. Alternative Release Scenario - Regulated Flammable Chemicals The alternative release scenario for flammables was calculated following the EPA's proposed OCA Guidance Reference Tables or Equations. The release chosen for modeling is a spill during loading, resulting in a vapor cloud explosion having an impact zone of 0.13 miles. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We maintain a number of programs to help prevent accidental releases and ensure safe operation. The accident prevention programs in place include: OSHA PSM elements, including employee participation programs, process safety information, process hazard analyses, operating procedures and training, mechanical integrity programs with training, contractor programs, incident investigation, management of change, pre-startup safety reviews, compliance audits, and hot work and safe work programs. Additionally, Valero has implemented various safety programs addressing safe personnel protective clothing and equipment, hearing protection, safe entry and exit controls, impact protection and secondary containment controls, and a detailed analysis and adherence to generally accepted industry codes and standards. We have additionally adopted the Texas City area contractors training program to assure that only qualified contractor personnel may enter the facility. Valero (and the prior refinery owner) has made every effort to assure compliance with OSHA PSM, dating back to 1992. Program improvements have been implemented following PSM audits in 1995 and 1998. Accordingly, the dates provided in Section 7. Prevention Program Level 3 represent the latest updates to the program elements. As part of our prevention efforts, we have implemented the following chemical-specific pre vention steps: For our toxic chemicals, hydrogen fluoride and chlorine, we have reviewed and adopted industry guidelines and manufacturer's recommendations regarding safe storage and handling. This includes personnel training as well as robust equipment designs. For flammables, we have adopted several API, NFPA, insurance company, ASME, ANSI, and other codes and standards. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5 FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary o f accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: There have been four releases of hydrogen fluoride at the Valero Texas City Refinery in the past five years, but they have not had any adverse impact on the community. Each of the releases involved small releases and minor personnel exposure. One incident involving flammables occurred in the last five years. An explosion was experienced, resulting in injuries to two employees. Equipment modifications were introduced to the affected unit as well as other refinery units as a result of the incident investigation. The community experienced no adverse impact. For the above incidents, and for others that do not meet EPA's definition, we have conducted formal incident investigations to identify and correct the identified causes of the events. 6 EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan through Industries Mutual Aid Society and the Texas City Fire Department. 7 PLANNED CHANGES TO IMPROVE SAFETY We are continuously investigating and reviewing technology and / or applications that could possibly enhance our safety efforts. 8 CERTIFICATIONS Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario all processes at our facility is less than the distance to the nearest public receptor: Within the past five years, the process(es) has (have) had no accidental release that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from acc idental releases. In the event of fire, explosion, or a release of a regulated substance from the process(es), entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMPlan. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true accurate, and complete. Signature Eugene W. Cotten Title Vice President and General Manager Date June 15, 1999 |