Motiva Enterprises LLC-Sorrento Off Site Storage F - Executive Summary
25891 LDEQ Facility ID Number |
1.0 ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Motiva Enterprises LLC - Sorrento Offsite Storage Facility (Sorrento) is under the management of the Motiva Enterprises LLC - Convent Refinery; and, as such, maintains the same long standing commitment to the safety of workers and the public and protection of the environment, as Convent Refinery. This commitment is expressed in the Company's policy statement:
Motiva is committed to protecting the health and safety of employees and others in our workplaces and protecting the environment and public wherever we conduct business activities. We are committed to the belief that all occupational injuries and illnesses are preventable and that serious or fatal injuries resulting from our activities are unacceptable. Each employee has a personal and vital responsibility to contribute to safe work performance. Our objective is to continuously improve our Safety, Health and Environmental performance, and
in so doing, to be recognized as a leader in our industry. We will comply with all safety, health, and environmental laws and regulations and will manage performance in these areas in the same manner as other aspects of our business.
In accordance with this policy Motiva will:
7 Assure compliance and continuous improvement using management systems that set targets and report performance.
7 Devote sufficient resources to ensure outstanding Safety, Health and Environmental performance.
7 Design, maintain, and operate facilities to minimize environmental impact, and to protect employees, contractors, and the public from injury and illness.
7 Foster awareness and provide training with the objective of protecting employees, the community, and the environment.
7 Integrate Safety, Health and Environmental processes into line operations, hold all employees accountable for performance and make this performance a key factor in evaluating and rewarding personnel.
7 Emphasize Safety,
Health and Environmental performance as a key factor in selecting contractors and require contractors to manage SHE matters in accordance with this policy.
7 Routinely audit Safety, Health and Environmental performance in all our operations to ensure compliance with laws and company policies.
7 Respond quickly and effectively to Safety, Health and Environmental incidents involving our facilities, equipment, and products under our control.
7 Foster constructive dialogue with federal, state, and local governments and communities in analyzing emerging Safety, Health and Environmental issues, finding solutions to problems and developing cost effective, scientifically-based standards and regulations.
7 Require subsidiaries and joint ventures under our control to manage Safety, Health and Environmental performance in line with this policy, and use our influence to promote it in other ventures.
This commitment is demonstrated by the resources invested in accident prevention
, such as training of personnel and considering safety in the design, installation, operation, and maintenance of Sorrento. Furthermore, the Company's commitment is validated through Convent Refinery's participation in OSHA's Voluntary Protection Program (VPP), of which Convent Refinery has maintained VPP Star status since December, 1995.
However, in the unlikely event of a release, Convent Refinery's trained personnel will respond to control and contain the release.
2.0 DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
Sorrento is located near the intersection of Louisiana Highway 61 and Interstate 10, east of the town of Sorrento, Ascension Parish, Louisiana. Sorrento, which is under the control and management of Convent Refinery, is a Liquefied Petroleum Gas (LPG) storage and pipeline transfer facility, utilizing underground salt dome caverns for storage. LPGs are transported via pipeline to/from the Convent Refinery site to Sorrento, a distance of approximately 7 mi
les, where the products are stored or transported to customers via pipeline. The Sorrento facility consists of one program level 3 process that contains two regulated flammables, butane and iso-butane, as well as flammable mixtures. Sorrento does not currently have any RMP-listed toxic materials.
Since Sorrento is an operating entity of Convent Refinery, all programs in effect at Convent Refinery are also applicable to Sorrento.
3.0 HAZARD ASSESSMENT RESULTS
Since Sorrento does not currently contain any RMP-listed toxic materials, no offsite consequences relating to toxics are reported.
The worst-case scenario (WCS) associated with a release of flammable substances at Sorrento is a vapor cloud explosion (VCE) involving a release of 54,900 pounds of butane, as a result of complete butane line separation, between the entrance to Sorrento and the S-1 cavern. The release quantity included the entire contents of the butane line within the Sorrento facility and a portion of the content
s of the S-1 cavern. The specified quantity of butane is assumed to instantaneously release, completely vaporize, and ignite, resulting in a VCE. No administrative controls are in place to limit the inventory in the system. This scenario is expected to have offsite impact. Although numerous controls exist to prevent such releases and to manage their consequences, no credit for mitigation measures was taken into account in evaluating this WCS.
The alternative release scenario (ARS) for flammable substances at Sorrento is a VCE resulting from the release of 50,360 pounds of iso-butane, through a 1 inch diameter hole in the piping within the facility. The release is expected to be isolated by the operators within 20 minutes by employing active mitigation. This scenario is expected to have offsite consequences.
4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program, administered by Convent Refinery, in effect for So
rrento. Because Sorrento is regulated by the EPA Risk Management Program (RMP) regulation as well as the OSHA Process Safety Management (PSM) standard, this summary addresses the elements which are common to both regulations and describes the management system in place to implement the accident prevention program.
4.1 Employee Participation
Convent Refinery encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team or incident investigation team. Employees have access to all information created as part of the refinery accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in the employee participation plan, entitled Standing Instruction 5.19 - Employee Participation, that is maintained by Con
In addition, Convent Refinery has a number of initiatives under way that address process safety and employee safety issues. These initiatives are implemented by teams and include VPP participation, the Quality Process, and the Employees' Safety Process. Teams are typically made up of members from various areas of the plant, including operations, maintenance, engineering, supervision, and management.
4.2 Process Safety Information
Convent Refinery maintains a variety of technical documents that are used to help maintain safe operation of Sorrento. These documents address the hazards of the chemicals in the process, the technology of the process, and the equipment used in the process. Specific departments within Convent Refinery are assigned responsibility for maintaining up-to-date process safety information.
Employees and contractors are informed of the location of process safety information that is relevant to their work.
Chemical-specific information, including
exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). MSDSs are readily available through Convent Refinery's computer system.
Convent Refinery 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 area classifications, piping and instrument diagrams (P&IDs), 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.
4.3 Process Hazard Analysis
Convent Refinery has a comprehensive program in place for performing process hazard analyses (PHAs), documenting PHA results, tracking of recommendations, and resolutio
n of recommendations.
Convent Refinery uses the hazard and operability (HAZOP) analysis technique to perform PHAs. The HAZOP analysis is recognized as one of the most systematic and thorough qualitative hazard assessment techniques. This technique utilizes the services of a multi-disciplined team, usually composed of five members, representing various areas of expertise. The objectives of the team are to identify reasonably foreseeable hazardous conditions which could occur as the result of a deviation from design intent, to identify engineering and administrative controls and safeguards in place to prevent or reduce the consequences of the potentially hazardous condition, and make recommendations for additional prevention and/or mitigation measures, when the team believes such measures are necessary. Recommendations may be simple solutions to identified problems or they may be requests for further investigation to develop an appropriate solution.
Each PHA study is documented by a
written report, which is maintained on file for the life of the process. All approved recommendations are entered into a computer data base and assigned to appropriate departments for resolution. The status of each recommendation is tracked until fully resolved, and the final resolution is documented and retained.
To verify that the PHA is consistent with the current process, Convent Refinery updates and revalidates the PHA for this facility at least every 5 years, until the facility is no longer operating. The results of these updates are documented and retained, recommendations are entered into a computer data base and assigned to appropriate departments for resolution, and final resolution of the recommendations is also documented in the data base.
4.4 Operating Procedures
Operating procedures have been developed to provide instructions for safely conducting activities involved at Sorrento. Operating phases of the process are addressed in these procedures. These procedures can be
used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. Operating procedures are readily available to operators and for other personnel to use as necessary to safely perform their job tasks.
In addition to operating procedures, Convent Refinery 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 spark-producing activities (i.e., hot wor
k), 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 maintenance activities are performed safely.
To complement the written procedures for process operations, Convent Refinery has implemented a comprehensive training program for all Motiva and contract employees involved in operating the Sorrento facility.
New operators must provide evidence of having received basic training in refinery operations, if they are not already familiar with such operations, before being employed on site. Once on site, a new operator receives on the job training to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently.
e maintained through refresher training. The operating procedures are grouped into modules, and each operator is expected to review the assigned modules and pass the prescribed tests over a period of three years. Thus, refresher training is a continuing effort.
All process-specific training is administered and documented by Motiva, for each operator, including the means used to verify that the operator understood the training.
Basic health and safety training for contract operators is identical to Motiva employees, except that this training is conduced and documented by the contract employer.
Convent Refinery uses contractors for certain operating functions, routine maintenance activities, maintenance during shutdown periods, and for construction activities. Convent Refinery also uses contractors for less safety sensitive work, such as, security, janitorial, grounds maintenance, engineering, clerical, etc.
Contractors performing the more safety sensitive work deal
ing with operations, maintenance, and construction activities are subjected to more stringent safety requirements to assure that they:
(1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards of the workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform refinery personnel of any hazards that they find during their work. This is accomplished by: (1) evaluating the safety programs and performance of prospective contractors, (2) basic safety training of contract employees by approved outside agencies, (3) site specific orientation training of contract employees, (4) pre-work conference with contractor supervision, (5) providing contractors with process overview information, (6) administration of process-specific training for contract operators, and (7) monitoring contractor performance to ensure that contractors are fulfilling their safety obligation
4.7 Pre-startup Safety Reviews (PSSRs)
Convent Refinery conducts a PSSR for any new facility or facility modification that requires a significant change in the process safety information. The purpose of the PSSR is to ensure that safety 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 PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
4.8 Mechanical Integrity
Convent Refinery has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps a
nd 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 that 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. Applicable 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 p
ressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), unless special approval is given to use of the equipment, after it is determined what actions are necessary to ensure the safe operation of the equipment.
Another integral part of the mechanical integrity program is quality assurance. Convent Refinery 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.
4.9 Hot Work Permit
Convent Refinery utilizes a comprehensive work permit system to safely manage all work performed at the facility. In addition to hot work, the work permit system also includes requirements for entry into confined spaces, as well as requirements for other than hot work. The existing work permit system serves as a framework for all other safe work pract
4.10 Management of Change
Convent Refinery has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology, (including process operation 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 operating limits, and equipment information, as well as procedures, are updated to incorporate these changes, in addition, operating and maintenance personnel are provided any necessary training on the change.
4.11 Incident Investigation
Convent Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental 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 documents its findings, develops recommendations to prevent a recurrence, and enters the information into a computer data base for tracking. Each recommendation is promptly assigned to an appropriate department for resolution. The final resolution of each finding or recommendation is documented in the data base, available for review by all employees and 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.
4.12 Compliance Audits
To help ensure that the accident prevention program is functioning properly, audits are periodically conducted to determine whether the procedures and practices required by the accident prevention program are being implemented. C
ompliance audits are conducted at least every 3 years. The audit team develops findings that are forwarded to Convent Refinery's 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 in a computer data base, and the two most recent audit reports are retained.
5.0 CHEMICAL SPECIFIC PREVENTION STEPS
Because the Sorrento facility handles flammable materials, potential hazards associated with these materials must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA RMP-covered processes at Convent Refinery as well as the Sorrento facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors.
In addition to the accident prevention program activities, Sorrento has safety feature
s to help (1) contain/control the release of flammable materials, (2) quickly detect such a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used:
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases.
2. Manual and automatic operated emergency shutdown valves to permit isolation of the process.
3. Hardwire alarms for specific process parameters.
4. Automated emergency shutdown systems for specific process parameters.
1. Hydrocarbon detectors with alarms.
2. Process is manned around the clock.
1. Firewater system with hydrants and monitors throughout the facility.
2. Fire extinguishers located throughout the facility.
3. Portable fire fighting equipment (e.g. pumper trucks, foam trailers, water cannons, etc.) available from the refinery site.
4. Trained emergency response personnel.
5. Personal protect
ive equipment (e.g., protective clothing, self-contained breathing apparatus, etc.).
6. Direct communications with the refinery site.
6.0 FIVE-YEAR ACCIDENT HISTORY
Sorrento has an excellent record of accident prevention over the past 5 years. Of the identified incidents, none have resulted in on-site or offsite effects. Every incident, regardless of the severity, is very carefully investigated to determine ways to prevent similar incidents from occurring.
7.0 EMERGENCY RESPONSE PROGRAM INFORMATION
Convent Refinery maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of 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 at the Sorrento facility. The procedures address all aspects of emergency response, including, reporting of an emergency, emergency response, first-aid and
medical treatment for exposures, evacuation plans, accounting for personnel, notification of local emergency response organizations, and post-incident cleanup and decontamination requirements. In addition, Convent Refinery 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 emergency response program is updated when necessary, based on modifications made to the process or facility.
Emergency response activities for the Sorrento facility are coordinated with the Office of Emergency Prepardness of Ascension Parish. Convent Refinery has around-the-clock communications capability with appropriate local agencies, who have direct communications with local police and fire departments. This provides a means of notifying the public of an incident, if neces
sary, as well as facilitating quick response to an incident. Convent Refinery also participates in the Sorrento Dome Alert network, which provides notification of an incident to other participating facilities in the area network.
8.0 PLANNED CHANGES TO IMPROVE SAFETY
All findings from past PHA studies have been resolved, and there are no planned changes at this time.