LYONDELL-CITGO Refining LP - Executive Summary
EXECUTIVE SUMMARY |
LYONDELL-CITGO - Health, Safety, and Environmental Policy
LYONDELL-CITGO Refining LP (LCR) has a vision to be a world class refining company and an industrial pacesetter in health, safety, and environmental performance. Our policy is to manufacture our products in a manner thet protects and preserves the health and well being of our employees, contractors, customers, and neighboring communities. We will operate a clean and safe workplace. We will meet or exceed all applicable laws, rules, and regulations.
The LYONDELL-CITGO Refinery
LCR is a 265,000 Barrel-a-day full conversion fuels refinery with some petrochemical and lubricants production. The refinery has three crude distillation units, two reformers, six hydrodesulfurization units, a fluid calalytic cracking unit, two delayed cokers, two sulfur recovery units, two solvent extraction units, an aromatics recovery complex, a lube oil treating unit and a light-ends fractionation unit. The refinery also has blen
ding facilities for gasoline, caustic treating units and various utilitiy systems. Major products are gasoline, kerosene, diesel, heating oil, coke, aromatics, pale oils, and food grade white oil. LCR produces high-quality, environmentally acceptable products using fractionation, reforming, hydrodesulfurization, and cracking.
Regulated Toxic Chemicals
LCR does not have any of the EPA listed toxic materials above the threshold quantity. However, out of respect for the community's general concern about hydrogen sulfide, LCR did provide an emergency Planning scenario for the material, during a public forum, because it is in some our processes, but below the threshold quantity.
Regulated Flammable Substances
LCR does handle above threshold quantities of methane, ethylene, propane, isobutane, butane, isopentane, pentane and mixed flammables containing the already listed materials and their isomers.
Worst Case Scenario - Flammables
Using EPA's definitions and worst-case weather condition
s with no passive mitigation, LCR's, worst-case scenario for flammables is the instantaneous failure of a pentane spheroid's tank walls. The maximum tank volume is 51,206 barrels, but written procedures and alarms prevent the vessel from containing more than 42,187 barrels. Using EPA's Offsite Consequence Analysis (OCA) Guidance, a 1-psi overpressure ring has a 1.68 mile radius and potentially affects 20,100 people outside the refinery. Although presented here, this is a very unlikely event. The tank is vented to a closed system to prevent over pressuring. Additionally the tank has pressure relief valves in the unlikely event the closed system can not handle all vaporized material. The tank is also equipped with a water spray system in case of a fire in the area. The tank recieves required inspections from professional inspectors to ensure its integrity as well as daily visual inspections from LCR operations personnel.
Alternate Case Scenario - Flammables
An alternate case scenario, us
ing most common weather conditions, is a vapor cloud fire caused by the failure of a pump seal, on a propane pump, which is located near the refinery boundry. Using OCA guidance for a release of 10,000 lbs. per minute for 15 mimutes and no mitgation, a vapor cloud fire would have a radius of 0.1 miles and potentially affect 15 people outside the refinery.
LCR's General Accidental Release Prevention Program
LYONDELL-CITGO processes are covered by OSHA 29 CFR 1910.119, Process Safety Management of highly hazardous chemicals (PSM). LCR complies with all aspects of the PSM regulation, and considers the systems developed for compliance to be the basis for good safety and business practices, including employee safety, training, safe work processes and equipment reliability.
Employee Participation and Training:
LCR has long recognized that employee knowledge, skill and hazard awareness are key elements in operating our facility in a safe, predictable and reliable manner.LCR incorporates em
ployee participation in all elements of PSM and other areas of safety. Effective and timely training programs are used to increase and maintain the skills and knowledge required by LCR employees.
Process Hazard Analysis:
Process Hazard Analysis (PHA) are the heart of the PSM rule and have been conducted on all covered processes in the refinery using teams of engineers and experienced operating personnel who are knowledgeable in the specific process being analyzed. All LCR PHA's are lead by personnel trained in the methodology being used for that PHA. Recommendations from these analyses are shared with employees and used to develop engineering controls to eliminate potential hazards. Currently LCR is revalidating our initial Process Hazard Analyses.
Process Safety Information:
Process Safety Information(PSI) has been updated and made available to all personnel involved in operating the processes. A SAP Plant Maintenance System and a Document Management System are two new electronic syst
ems implemented in the past year to improve access to information and efficiently plan and schedule maintenance work. These systems contain the platforms we plan to use to organize and deliver more information to employees throughout the facility.
LCR's comprehensive system of written Standard Operating Procedures (SOP) and Emergency Operating Procedures (EOP) contain safety notes or reference PSI that is available in the Unit Operating Manual. An electronic document delivery system has been implemented and a computer based training system is being designed for completion in 1999.
Management of Change and Pre-startup Safety Reviews:
LCR's Management of Change (MOC) system is designed to capture all process related changes, and evaluates the change for potential impacts to the process. Major changes require completing a process hazard analysis prior to modification or construction. The system tracts implementation through the close of the project to assure PSI, SOP
's EOP's and P&ID's are updated and all necessary personnel are trained. The pre-startup safety review (PSSR) required for each MOC helps assure all requirements have been met. The MOC process has recently been updated and streamlined to more effectively handle small and complex changes. A computer based training module has been made available electrinically to provide all employees access to forms and to act as a reference.
Mechanical Integrity (MI) fits well into LCR's goal of being a pacesetter in equipment reliability. LCR is committed to maintaining the physical integrity of all equipment to prevent unwanted failures. The MI program is computer based and ties into the SAP Plant Maintenance System to track inspection requirementsand to document equipment history. The MI process is also linked with the MOC process to capture all new equipment ans changes to existing equipment.
LCR investigates all PSM incidents and has trained a mix of e
mployees in investigation methodology to assure all incidents receive prompt attention and that the results of the investigations indentify the root cause. Recommendations from investigations are shared with affected employees and contractors and tracked to closure.
To meet internal goals and compliance with PSM/RMP, LCR has an audit performed every three years to verify all PSM/RMP element requirements are being satisfied.
Hot Work Permits:
Hot work permits have been a part of the refinery's safety program for over 40 years.
LCR has a comprehensive program for selecting and using contractors that includes review of their safety record both prior to selection and during their time of employment.
Five Year Accident History
According to the definition of the rule for off site impact, LYONDELL-CITGO has not had a release of any regulated toxic or flammable material, during the past five years.
Emergency Response Program
The LYONDELL-CITGO Refinery Emerg
ency Response program is detailed in a six (6) volume Emergency Action Plan (EAP). Each volume plays an important role in protecting plant personnel and the surrounding community. An accompanying document is the Spill Response and Prevention Plan (SRPP). In their entirety, these plans provide an effective means of ensuring the safety and health of both company personnel and citizens in the surrounding community in the event of an emergency.
All procedures and response actions employed by the refinery are supported by professional emergency management response standards and recommendations, as being the safest known methods to handle emergencies in refining operations. These standards and regulations include, but are not limited just to standards and regulations developed by the following groups:
* Occupational Safety and Health Administration (OSHA)
* National Fire Protection Association (NFPA)
* Environmental Proction Agency (EPA)
* Federal Emergency Management Ag
* International Fire service Training Association (IFSTA)
* U.S. Department of Transportation (DOT)
* Chemical Manufactures Association (CMA)
* American Petroleum Institute (API)
* American National Standards Institute (ANSI)
Refinery programs deliver a total response system capable of managing emercency events such as fires, spills, gas releases, radiation, and rescue emergencies. The emergency management system is designed to manage all incidents from the smallest to the largest.
Elements of the programs can be outlined in the following described areas:
Emergency Response Procedures - General:
General planning provides strategies and outlines actions for all facility personnel. Items outlined in general facility plans include incident and emergency reporting, notification, response, and evacuation procedures. Evacuation plans include evacuation points ans accounting procedures for site personnel. Site security procedures are in place to ensure
the maintenance of in-plant and outside security. Additionally, general plans include detailed severe weather management plans for expected weather. These severe weather plans include weather monitoring, hurricane preparation, shutdown procedures, and employee communication.
Functional plans provide explicit procedures and actions for emergency management systems and gruops. These plans specify our incident management system, basic strategies, and tactics for handling emergencies. Detailed incident command systems (ICS) and their components are provided, and are consistent with FEMA national incident command standards. Detailed job descriptions are in place for all emergency management and response personnel. Emergency management plans are tiered in order to activate emergency responders and outside assistance dependent on the event. Additionally, comprehensive fire, hazardous materials, medical, rescue, radiation and spill response plans list detailed actions for the
respective type of incident.
The facility Voluntary Emergency Response Team (VERT) provides around-the-clock emergency response services. The team consists of over one hundred and ten (110) highly trained firefighter/hazardous material technicians. Specialily groups, within the team, provide emergency medical, confined-space rescue and waterway spill response.
Outside resource and mutual aid procedures are in place. The refinery is an active member of Channel Industries Mutual Aid (CIMA). Refinery mutual aid plans include procedures and alarm list for the activation of local fire departments and CIMA. The refinery follows all required CIMA organization standard operating procedures. In addition, the facility ERT provides mutual aid emergency assistance to the community.
Staging areas and landing zones sites are provided for outside resource equipment. This information is provided to the local fire departments and CIMA member companies.
The refinery maintains a state-of-the-art communi
cations system for activating emergency response groups and the community. The system includes a refinery-wide trunk radio system programmed for incident management, as well as a telephone system structured to allow for operations during inclement conditions. Systems and procedures are in place for summoning response personnel in or outside the facility. CIMA and State Wide Fire Mutual Aid frequencies are used by the facility ERT for communicating with outside mutual aid resourcesas needed.
A Human Resourse and Communications Crisis Plan provides assistance and information to employees and people in the community who may be affected by an emergency at the site. Through the East Harris County Manufactures Association (EHCMA), of which LCR is a leading member, LCR supports and utilizes the "CAER Line" (Community Awareness & Emergency Response), a 24-hour telephone system, as a means of providing timely information to the community in the event of an emergency at the site.
Administrative plans are in place for managing emergency managements programs. These plans include training, education and exercise plans as well as documentation, investigative, response service inspection and critique requirements.
Training and education plans include all required training and exercises for the plant. They are listed with requirements and a tentative completion schedules. Refinery trianing and exercises encompass all the emergency response efforts described.
Training can be summarized as follows:
Routine training is conducted on site for Voluntary Emergency Response Team (VERT) members at the LCR VERT Training facility. Additionally, VERT members are required to attend various accredited training schools throughout the nation. Members involved in emergency medical are certified through state programs. ERT members also participate in exercise and training sessions with local fire departments, CIMA, Clean Channel Association (CCA), and Local Emergency Planning
For all facility emergency management groups, notification drills are routinely conducted to test emergency notification systems.
Response and evacuation drills are conducted routinely with all personnel. The Emergency Operations Center (EOC) is activiated for many of these exercises. Additionally, the EOC performs tabletop exercises.
Preplan meetings are provided with the local fire department at least annually. emergency action plans and facility emergency equipment are reviewed.
Critique plans are in place to review lessons learned during events and exercises. These lessons learned are used in a continual cycle of improvement for response actions.
Administrative procedures for managing and staffing of the ERT are provided in portion of the plan. These procedures ensure adequate staffing of qualified response personnel at all times.
Emergency Equipment and Procedures:
The refinery maintains a vast array of fire and hazard protection systems. Additionally, a full co
mplement of response equipment and facilities are maintained in a ready state.
Automatic and manual fire and hazard protection systems exist in various types throughout the facility. These systems detect fires and gas releases. Additionally, some systems provide fire suppression or extinguishing such as water sprays and extinguishing compounds.
The facility maintains its own in-house fire water system. The fire water system supports fire monitors, water spray systems, sprinkler systems, hose reels and hydrants.
The VERT operates four (4) industrial foam fire engines, one (1) industrial foam aerial, a heavy rescue truck, an ambulance, a hazmat response unit, decon unit and various specialized support units. Aspill boat is available to deploy boom in case of a spill on the ship channel. The refinery inventories over fifteen thousand (15,000) gallons of firefighting foam for petroleum or chemical fires.
For command and control functions, the refinery has a permanent Emergency Operations C
enter (EOC). The EOC provides facilities for operations of the Emergency Operations Group. this group is composed of managers from various disciplines. These managers promote planning and support functions for the refinery. Field control functions are performed from a mobile field Commamd Post (CP). From the CP field operations of the VERT and process operations are managed.
Building Area Preplans:
Building Area Preplans are provided for permanent facility structures. These plans provide detailed evacuation instructions and routing information in case of forced building evacuation.
Crisis Manage Plan:
Crisis Management Plans contain procedures for stratgic handling of Company crisis situations. The Crisis Management Team is composed of Executive Managers. Their plans describe positions and responsibilities for managing in-plant and community issues during a serious emergency.
Spill Response and Prevention Plan:
The accompanying spill response and prevention plan provides additional in
formation, procedures and resources for handling major spills. These procedures outline job responsibilities for intrenal and external reporting, spill control and cleanup procedures. the procedures also provide general guidelines for spill prevention and waste minimization.
LYONDELL-CITGO IN THE FUTURE
LCR will continue to improve its safety and environmental performance through installation of computer controls for the remaining four process units that do not presently have them. A reorganization of our operations group and a new centralized control room will improve communications and allow quicker response to deviations from normal operations, preventing potential safety concerns or releases. As LCR continues to improve its computer systems, it will have Material Safety Data Sheets and other safety information on line for ease of access by all employees. LCR plans to continue to emphasize equipment reliability and reduce failures through improved preventive maintenance and inspec