San Juan Refinery Company - Executive Summary
This document describes Giant Refining's Risk Management Plan (RMP) for its Bloomfield, NM refinery. It includes all of the RMP elements required by 40 CFR 68. The RMP is not a single document. It is composed of the facility's Process Safety Management (PSM) program, the emergency response plan, an analysis and evaluation of offsite consequences of an accidental release, and other related environmental and health and safety documents and programs. This executive summary presents an overview of the plan and describes briefly the key elements of the RMP.
The Bloomfield refinery consists of a number of interrelated activities and processes, some of which meet the RMP or PSM definition of "process". The individual processes within the facility are roughly grouped into three functional areas, physically separated from one another. The individual processes within the physical areas were considered here as a single process for purposes of determining RMP applicability. This is a ver
y safety-oriented interpretation of the regulation, fully compliant with its spirit, as it results in the largest possible volume of each potential RMP substance being evaluated. It is also physically realistic, as a release occurring at one of the physical areas is unlikely to affect the other areas.
Two of these processes involve more than the threshold quantities of RMP-regulated substances, propane and butane, and are therefore RMP processes. No accidental releases with offsite consequences have occurred within the last five years involving these substances or processes. One of the RMP processes, the FCC and related process equipment within the plant area, will not result in offsite consequences from a worst-case release and meets the other requirements for a program 1 process. The other RMP process, the propane and butane storage bullet tanks, could have offsite consequences and is therefore a program 3 process.
Since the RMP processes involve both propane and butane, each of t
he two processes is considered a single process involving propane and butane, rather than as a propane process and a butane process. This is a safe and reasonable assumption.
Most elements of the PSM and RMP programs at Giant are applied facility-wide rather than in a limited sense to only the PSM and RMP processes. Hazard information and analyses, training, operating and work practices, etc. apply to the entire facility, not just the PSM- and RMP-affected portions. For example, an event triggering a modification to the management of change procedures which occurred at a non-RMP process triggers the modification which in turn affects the procedures as they apply to the RMP processes, even though the event did not occur at the RMP processes.
For this reason, the extensive risk management procedures which ordinarily apply only to program 3 processes are implemented in the program 1 process as well. Giant's RMP clearly goes well beyond the minimum requirements of the law. The following
discussion summarizes each element of the RMP at Giant; no distinction is made here between the program 1 and program 3 processes as regards risk management and accident prevention. The principal area in which the two processes are treated differently is as regards analysis of off-site consequences; since the program 1 process has no potential off-site consequences, no alternative releases were evaluated.
Accidental Release Prevention and Emergency Response Policies
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