Placid Refining Co. L.L.C. -Port Allen Refinery - Executive Summary |
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LDEQ Facility ID # PLACID REFINING COMPANY LLC PORT ALLEN REFINERY Risk Management Plan Executive Summary The Placid Refining Company LLC - Port Allen Refinery (Placid) is committed to operating in a manner that is safe for Placid workers, the public, and the environment. It is Placid's policy that in the conduct of its activities it will strive to protect and promote the health and safety of its employees, customers, and others who may be affected by these activities, and to limit adverse effects on the physical environment in which its activities are carried out. As part of this policy, Placid has established systems to help ensure safe operation of the processes at this facility. One part of these systems is a risk management program (RMP) that helps manage the risks at Placid and that complies with the requirements of the Environmental Protection Agency's (EPA's) rule 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule), and the Louisiana Department of Environmental Quality regulation (LAC 33:III.Chapter.59). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at Placid. This document is intended to satisfy the RMP Plan executive summary requirement of the RMP rule and to provide the public with a description of the risk management program at Placid. Accidental Release Prevention and Emergency Response Policies Placid has a long-standing commitment to the safety of the general public, of Placid employees and to the preservation of the environment. One primary portion of this commitment is the prevention of accidental releases of hazardous substances in and around the refinery. Placid utilizes engineering controls, inspection programs, and detailed procedures as a means to prevent accidental releases. In the event of a release, the refinery has well trained emergency response teams to contain, mitigate, monitor, and stop the relea se. In addition to handling the release, the refinery has also established a wide variety of communication systems to alert the community in the event of a significant release. In conjunction with our local emergency planning committee (LEPC), the refinery has ability to notify the local community through cable override systems, radio broadcasts, and/or through an automated telephone notification system. The Placid Refinery Manager has overall responsibility for the development and implementation of the risk management program for EPA-regulated processes at facilities. However, the specific responsibilities for certain aspects of that program have been delegated to other personnel who report either directly, or through other management personnel, to the Refinery Manager. Specific responsibility for the implementation of the process safety management (PSM), emergency response, and accident prevention programs has been delegated to the Manager of Safety. Similarly, responsibility for the RMP hazard assessment and risk management plan has been delegated to the Environmental Manager. In keeping with Placid's policy that safe operation is part of everyone's job, many other personnel are also involved in RMP activities on an ongoing basis. Description and Regulated Substances Placid is a full range refinery and petroleum products facility located in Port Allen, Louisiana. Placid uses crude petroleum as their feed material and makes a variety of petroleum-based products, including gasoline, diesel fuel, and liquefied petroleum gases such as propane and butane. Many of these products are flammable substances that EPA has specifically listed in the RMP rule and are present in some process units above the EPA threshold quantity of 10,000 pounds. In total, Placid has 6 process units that are covered by the RMP rule because of their flammable process materials. These units are listed in the RMP data included with this summary (Section 1.17 of the RMP Data Elements). P lacid also handles one toxic substance regulated by the RMP rule in a sufficient quantity to be covered by the RMP rule: 7 Hydrofluoric acid is used as a catalyst in the HF Alkylation unit which produces alkylate. The HF Alkylation Unit is covered because the unit contains more than the threshold quantity for hydrofluoric acid of 1,000 pounds. Hazard Assessment Results Placid performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance that could affect the public or the environment. The offsite consequence analysis consisted of evaluating both worst-case scenarios and alternative release scenarios. Placid does not expect a worst-case release scenario to ever occur. An alternative release scenario represents a release that might occur during the lifetime of a facility like Placid. Alternative release scenarios can be used to help the LEPC improve the community emergency response plan. Placid has shared that information wit h the LEPC, local hospitals, and other organizations involved in emergency response activities. It is also available to local residents and businesses. If you are interested in this information, please contact Placid's receptionist at (225) 387-0278 and request the Environmental Manager. The main objective of performing the offsite consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance: 7 When considering explosion of a flammable substance, people at the endpoint distance are likely to be knocked down by the blast. Windows could shatter, and the potential for structural damage to buildings exists, although a building collapse is unlikely. People could be seriously injured by being knocked down by the force of the blast, by flying glass, or by falling objects. 7 When considering the release of a toxic substance, most people at the endpoint distance would be able to walk away from the exposure without any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely. Some people who are particularly susceptible to the substance released could be incapacitated. At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effects would be less. Worst-case Release Scenarios The worst-case scenario associated with the toxic substance in RMP-covered processes at the refinery is a failure from the acid settler/acid storage in the HF Alkylation Unit, resulting in a release of 1,500 gallons (approximately 12,500 lbs) of hydrogen fluoride (HF) gas over a 10-minute period. Although Placid has numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating thi s scenario. The maximum distance to the toxic endpoint of 20-ppm (0.016 milligrams per liter) for this worst-case release scenario is approximately 11 miles. The worst-case scenario associated with a release of flammable substances in RMP-covered processes at the refinery is assumed to result in a vapor cloud containing the total quantity of the substance that could be released from Tank 11, which stores naphtha. The entire quantity in the cloud is assumed to be between the upper and lower flammability limits of the substance. For the worst-case consequence analysis, the vapor cloud is assumed to detonate. The endpoint of the consequence analysis of a vapor cloud explosion of a regulated flammable substance is an overpressure of 1 pound per square inch (psi). The endpoint was chosen as the threshold for potential serious injuries to people as a result of property damage caused by the explosion. The maximum distance to the 1-psi endpoint for this scenario is 2.32 miles. Althoug h Placid has numerous controls to prevent such releases and to manage their consequences, no credit for mitigation measures was taken into account in evaluating this worst-case scenario. There are no Program 1 processes at the refinery, therefore, no additional worst-case analyses are reported for such processes. Also, Placid did not identify any worst-case scenarios that would affect public receptors other than the receptors affected by the scenarios reported above. Alternative Release Scenarios The alternative case scenario for hydrogen fluoride (HF) is release from a > inch nozzle failure on the HF Alykalation Unit Acid Settler, resulting in a release of 875 gallons (approximately 7,250 lbs.) of HF gas over a 5-minute period. The 5-minute release duration is the approximate time necessary to isolate the acid settler, activate the water mitigation system, and thus effectively stopping the release. The release of HF would be accompanied by hydrocarbons; therefore, the unit's e xisting hydrocarbon detectors were considered in estimating the discovery time of the release. The maximum distance to the toxic endpoint of 20 ppm (0.016 milligrams per liter) for this scenario is 2.8 miles. The alternative case scenario for flammable substances at the refinery is a release from an Isobutane Tank (Tank 114) resulting from overfilling and overpressuring the tank (7675 lbs released over a 5-minute period). The release is expected to be isolated by the operators within 5 minutes (active mitigation). The maximum distance to the 1-psi endpoint for this event is 0.11 miles. This event was selected as being a practical scenario for use in emergency planning and response. Accidental Release Prevention Program The following is a summary of the general accident prevention program in place at Placid. Because processes at the refinery that are regulated by the EPA RMP regulation are also subject to the Occupational Safety and Health Administration (OSHA) process safety mana gement (PSM) standard, and because the OSHA PSM requirements are very similar to the EPA RMP requirements for refineries, this summary addresses each of the OSHA PSM elements. The PSM program at this facility has been extended by Placid, where necessary, to satisfy EPA's Program Level 3 accident prevention program requirements. Employee Participation Employee Participation has always been a goal at Placid. Keeping employees informed and involved creates a team unity atmosphere. Employees have participated on Process Hazards Analysis Teams and have access to all Hazop information and recommendations. This information along with updated Operation Manuals are kept in the Control Room, Safety Department and Process Engineering. Operation manuals are developed, updated and reviewed by Operations Personnel and the Training Department. These Operation Manuals assist employees in refresher training and Operator Recertification Programs. Safety meetings are held on a regular basis for Operations, Maintenance, Laboratory, Terminal, Administration and Contract personnel. Regulations updates and safety procedures are the main topics during these safety meetings. All meetings are documented and kept on file. Administration safety meetings are held on a quarterly basis. Each department has representatives on the Employee Safety Committee which meets monthly. Safety concerns, programs, audits, employee participation and other safety ideas are discussed during the meetings. Process Safety Information Placid keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within Placid are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents and thei r location is readily available as part of the written employee participation plan to help employees locate any necessary process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, Placid has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the operation manuals for each process unit. Placid ensures that the process is maintained within these limits by using process controls and monitoring instruments, operating procedures, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). Placid also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis Placid has a comprehensive PHA program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each existing covered process and future processes are systematically examined to identify hazards and ensure that adequate controls are in place to manage those hazards. Placid primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and t horough hazard evaluation techniques available. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as recommends accident prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team recommendations are forwarded to management for resolution. Implementation of safety improvements in response to PHA findings is completed within six months if feasible. Any item that cannot be taken care of within six months is documented and justified. All approved safety improvements being implemented in response to PHA team recommendations are tracked until they are complete. The final resolution of each recommendation is documented and retained by the Safety Department. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety feature s, Placid periodically updates and revalidates its process hazard analyses of affected units. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. Offsite consequences have been incorporated into all PHA updates completed after August 1996. The results and recommendations from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the recommendations is documented and retained. Operating Procedures Placid maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and annually certified by the Manager of Safety as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made to the process. In addition, the Placid operating procedures provide guidance on how to respond to events that result in exceeding safe operating limits for specific process or equipment parameters. The written operating procedures are readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, Placid has implemented a training program for all employees involved in operating a process. New employees receive basic training in Placid operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through te sts, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted yearly on a three year cycle. Operators are given the opportunity to take part in more frequent refresher training if desired. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors Placid uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, Placid has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Placid personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, (4) safe work practices, and (5) a work permit process (i.e., for hot work, confined space, etc.) prior to their beginning work. In addition, Placid evaluates contractor safety programs and performance during the selection of a contractor. Placid personnel periodically monitor contractor performance to insure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews Placid conducts a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information (not required for replacement in kind). The purpose of the review is to ensure that sa fety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The review team uses checklists to verify all aspects of readiness. A review involves field verification of the construction and serves a quality assurance function. Mechanical Integrity Placid has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system th at maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. Placid incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices Placid has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control welding and other spark-producing activities, and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenan ce activities are performed safely. Management of Change Placid has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process technology information, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change. Incident Investigation Placid promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmen tal loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team, which often includes contractors, documents its findings, develops recommendations to prevent a recurrence, and forwards these results to Placid management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, Placid periodically conducts audits to confirm the pr ocedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. These audits are led by a third party contractor with assistance by Placid employees as required. The findings are forwarded to Placid management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. Chemical-specific Prevention Steps The processes at Placid have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at Placid. Collectively, these prevention program activities help prevent potential accident scenarios of both hydrofluoric acid and flammable substances caused by equipment failures or human errors. In addition to the accident prevention program ac tivities, Placid has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safety features are used in various processes: Release Detection Diesel Hydrotreater Unit 7 Hydrogen sulfide detectors in the sulfur plants; 7 Hydrocarbon detectors with alarms in the FCC, Treaters, Reformer, Diesel Hydrotreater Unit (DHTU) and Tank Farm ; and 7 Hydrogen sulfide detectors are worn by DHTU and Treaters employees. Release Containment/Control 7 Process relief valves that discharge to a flare to capture and incinerate process materials to prevent overpressure damage to equipment; 7 Scrubbers to neutralize chemical releases; 7 Manual and automatic valves to permit isolation of the process; 7 Automated shutdown systems for specific process parameters (e.g., high level, high temperature); 7 Acid storage tank used for the removal of HF from the process unit in the event of a release; 7 Curbing or diking to contain liquid releases; 7 Redundant equipment and instrumentation where needed (e.g., uninterruptible power supply for some critical process control system, redundant firewater pumps, electrical and diesel); 7 Release mitigation systems (water spray systems); 7 Fire suppression and extinguishing systems (dry and liquid); 7 Deluge system for the HF Alkylation process; 7 Trained emergency response personnel; 7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus); and 7 Blast-resistant control buildings to help protect control systems and personnel. Five-year Accident History No releases of regulated substances from regulated processes have occurred from Placid in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site. Emergency Response Program Information Placid Refining Company LLC Port Allen Refinery (Placid) maintains a written Emergency Procedures Manual, which is in place to protect worker and public safety as well as the environment. The manual includes procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first aid and medical treatment, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, Placid has procedures that address maintenance, inspection and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The Emerg ency Procedures Manual is updated when necessary based on modifications made to refinery processes or other refinery facilities. Any changes approved are updated in the manual and affected personnel are trained in regards to the changes during periodic safety meetings and/or through the Management of Change process, on shift training meetings. The overall emergency response program for Placid is coordinated with the West Baton Rouge Parish Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. Placid has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, Placid conducts p eriodic emergency drills that involve the LEPC and emergency response organizations. Additionally, Placid provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the refinery. Planned Changes to Improve Safety Placid constantly strives to improve the safety of its operations through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers. Placid resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned during the next 5 years: 7 Placid addresses all findings from PHA's, developing action item lists to enhance process safety; 7 Placid has programs in place to recognize, evaluate, and control hazards administratively and using engineering controls; 7 Placid is in the process of enhancing its personnel training programs; and 7 Placid will evaluate supplementing hydrocarbon (HC) detector s with HF monitoring equipment and implement as appropriate. |