Clark Port Arthur Refinery - Executive Summary |
|
EXECUTIVE SUMMARY Clark Refining & Marketing, Inc. Port Arthur, Texas RMP Plan Executive Summary ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Clark Refining & Marketing, Inc.'s Port Arthur Refinery, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) 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: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-ye ar accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * 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 * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES The Port Arthur,Texas, Refinery is a Prime Fuels operation that also includes extensive non-process related equipment. The Plant is situated on 3,840 acres where approximately 1,350 acres are occupied by process units and tankage. We can process approximately 235,000 Barrels Per Day of intermediate and sour crude oils. Our facility produces gasoline, kerosene, diesel fuel, and other petroleum products 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 We have two toxic chemicals in threshold quantities affected by the rule - chlorine and hydrofluoric acid. Chlorine is used to treat raw water that is filtered and then used for cooling, steam, and washup in the processes. It also is injected into the cooling water systems at each cooling tower for control. Chlorine is delivered to the refinery in one-ton cylinders and dispensed directly into the water with metering devices typically from only one cylinder at a time. The only location that has more than one cylinder hooked up for treating also has chlorine monitors in the vicinity to alert for leaks. Hydrofluoric Acid is used in the manufacturing of gasoline. It is brought into the refinery in tank trucks and unloaded directly into the unit. Flammables We have nine flammables that are affected by the rule - the se are propane, propylene, isobutane, butenes, butane, isopentane, isobutylene, isopentane, and pentane. These flammables are mainly manufactured in the operating processes with purchases of isobutane for use at the HF Alkylation Unit. The isobutane and butenes are used as charge for the Alkylation Unit. The other materials are sold as finished products, used for fuel in the refinery, or blended to gasoline. 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 chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenarios and alternative release scenarios 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 Scenarios - Regulated Toxic Chemicals One worse-case for toxics has been chosen. This scenario will only occur when the Hydrofluoric Acid Alkylation Unit is shut down and the acid and hydrocarbons have been pumped into the unit storage tank. Based on the EPA's guidelines for a worse case scenario, a complete failure of the storage tank would occur releasing the mix in the tank of approximately 80% HF Acid and 20% hydrocarbons. When the tank fails releasing its contents, it is assumed that all the HF Acid will vaporize into the air in 10 minutes. Meteorological conditions are also based on EPA guidelines with wind speed of 1.5 meters per second, temperature of 25 deg. C, stability class of F, and relative humidity of 50.0%. The calculated distance to endpoint per the EPA OCA Tables indicates that it has off-site impacts. A list of the potentially impacted receptors include: Public Receptors are schools, residences, hospitals, prisons, public recreation areas or arenas, major commercial, office, or industrial areas; Environmental Receptors are national or state parks, forests, or monuments, officially designated wildlife sanctuaries, preserves, or refuges, and federal wilderness areas. Alternative Release Scenarios - Regulated Toxic Chemicals Two alternative case scenarios have been chosen to represent the two toxics that the refinery has above the threshold values. These toxics are hydrofluoric acid and chlorine. For hydrofluoric acid, a tank truck is unloading 100% hydrofluoric acid when a 3/8" hole develops in the 2" unloading hose. The truck driver has an emergency switch at the truck to stop flow from the truck and the operator has a remote shutdown switch in the control room. The personnel involved are suited up in protective gear and the operation is monitored by remote camera in the control room. Also, water spray mitigation would be started immediately and there would be at least a 90% knock down of vapors. Operators fe el it would only take 20 seconds for the isolation valves to be activated and the hydrofluoric acid contained. Meteorological conditions are based on EPA guidelines with wind speed of 3.0 meters per second, temperature of 25 deg. C, stability class of D, and relative humidity of 50.0%. The calculated distance to endpoint per the EPA OCA Tables indicates that this incident would result in off-site impacts. The only impacted receptor is an industrial area. The next scenario would involve a one ton chlorine cylinders used for water treatment. The connecting hose, from the chlorine cylinder to the chlorinator at the cooling tower at crude still AVU-146, breaks, creating a 0.3175 hole for chlorine to escape. The cylinder contains 1500 pounds of chlorine and it empties into the air. There is no mitigation assumed. Meteorological conditions are based on EPA's guidelines with wind speed of 3.0 meters per second, temperature of 25 deg. C, stability class of D, and relative humidity of 50.0% . The calculated distance to endpoint per the EPA OCA Tables indicates that this incident would have off-site impacts. The only impacted receptor is an industrial area. Worst-case Release Scenarios - Regulated Flammable Chemicals Two worse-cases for flammables have been chosen. One scenario will occur when Sphere 1999 at Neches Station has been filled to capacity and ruptures, releasing isobutane, butane and other C4 related components. The mix is then totally involved in a vapor cloud explosion. There is no mitigation assumed. Meteorological conditions are based on EPA's guidelines with wind speed of 1.5 meters per second, temperature of 25 deg. C, stability class of F, and relative humidity of 50.0%. The calculated distance to endpoint per the EPA OCA Tables indicates that this incident would have off-site impacts. A list of the potentially impacted receptors include: Public Receptors are schools, residences, public recreation areas or arenas, major commercial, office, or offsite i ndustrial areas. The second scenario will occur if one of three spheroids (such as Tank 2155) at 138 Pump House is filled to capacity and ruptures, releasing butane and isobutane mix. The mix is then totally involved in a vapor cloud explosion. There is no mitigation assumed. Meteorological conditions are based on EPA's guidelines with wind speed of 1.5 meters per second, temperature of 25 deg. C, stability class of F, and relative humidity of 50.0%. The calculated distance to endpoint per the EPA OCA Tables indicates that it would have off-site impacts. A list of the potentially impacted receptors include: Public Receptors are schools, residences, public recreation areas or arenas, major commercial, office, or industrial areas; Environmental Receptors are officially designated wildlife sanctuaries, preserves, or refuges. Alternative Release Scenarios - Regulated Flammable Chemicals One alternative case scenario has been chosen to represent flammables for the refinery. Two of the th ree butane pumps at Neches Station are in operation when a 3/4" bleeder is broken off one of the operating pumps. The system pressure is 450 PSIG and temperature is 100 deg. F. A release of 31,200 pounds of butane(mixture of C3's, C4's & C5's) is realized before a vapor cloud explosion(VCE) takes place. There is no mitigation assumed. Meteorological conditions are based on EPA's guidelines with wind speed of 3.0 meters per second, temperature of 25 deg. C, stability class of D, and relative humidity of 50.0%. The calculated distance to endpoint per the EPA OCA Tables indicates that this incident would have off-site impacts. The impacted receptors are residences and an offsite industrial area. 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. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Hydrofluoric Acid Alkylation Unit 443 * Remotely operated "Emergency Block Valves" * Water spray mitigation system * Routine Inspection Program * Pump vibration monitoring program * Volatile Organic Compounds checks for fugitive emissions * Hydrocarbon detectors located in acid area of pump row * Hydrofluoric acid detection paint on flanges * Operator training and routine surveillance of equipment * Continuous remote monitoring via cameras and monitors in control room Chlorine Cylinders * Approved vendor that test each cylinder before filling * Leak check on all fittings by operators after hookup * Periodic operator and instrument tech inspection * Written procedure for chlorine handling * Chlorine detectors at 398 Pump Station that give audible and visual alarms 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. Our goal in the refinery is for prevention rather than mitigation, however, if there is a release, the operations personnel are trained in initial response to contain or minimize any release. The emergency response brigade, made up of highly trained employees, will be on the scene in a ma tter of minutes to help or take over the mitigation depending on the circumstances. FIVE-YEAR ACCIDENT HISTORY Clark keeps records for all significant accidental chemical releases that occur at our facility. At the Port Arthur Refinery we have not had any accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: If any future incidents occur, Clark will conduct formal incident investigations to identify and correct the root causes of the events. EMERGENCY RESPONSE PROGRAM Clark maintains emergency response and spill response contingency plans, which comply with all federal, state, and local regulatory requirements. 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. We have developed procedures that outline the emergency actions to be taken as require d. This is the Emergency Procedures Manual (Red Book). Copies of our Red Book are located throughout the refinery for quick access. Each covered location has emergency procedures that are peculiar to that location, as well as, the overall refinery plan. Our overall plan is coordinated with the community and joint training takes place on an annual basis which includes our Emergency Response Team and the local emergency responders. The notification system for the refinery is also outlined in the Red Book. Outside notification is made as required under the regulations and outside help is called upon as deemed necessary. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: * Certain sections of fire water piping in the refinery are being replaced where needed and upgraded to supply a greater volume of flow in needed locations. * Remote operated va lves are being installed on LPG tanks to allow emergency shutdown. * The water deluge system for the spheres in 441 Tank Field is being fitted with remote operators. * The fire proofing for all LPG Spheres is being improved as the spheres are taken out of service and all glass level gauges will be replaced with Saab Gauges and a differential pressure type backup gauge when the tanks are worked. * A spheroid at 138 Pump House will be taken out of service in the future to reduce inventory. Other planned items include: * Several unit control rooms are planned to be pressurized and have toxic detector monitors installed in the AC intake stacks where operators are expected to stay in an emergency. * CRU 1344 (Cat Reformer) is being reviewed for installation of Emergency Block Valves in strategic locations. |