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Excel Paralubes

Parent Companies:
Phillips 66 Company
FHR Lubricants, LLC
EPA Facility ID:
100000040387
Other ID:
70669CNCLKOLDSP
Facility DUNS:
10971518
Parent Company #1 DUNS:
0
Parent Company #2 DUNS:
0

Location:

Address:
2800 Old Spanish Trail
Westlake, La, LA 70669
County:
CALCASIEU
Lat / Long:
30.242, -93.282 (Get map)
Method:
Classical Surveying Techniques
Description:
Storage Tank
Horizonal accuracy:
1 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Phillips 66 Company
Phone:
(337) 491-5211
Address:
2800 Old Spanish Trail
Westlake, LA 70669 -5124
Foreign Address:

Person responsible for RMP implementation:

Name:
Julie Richard
Title:
PSM/RMP Director

Emergency contact:

Name:
Ron Tower
Title:
Safety Director
Phone:
(337) 491-5224
24-hour phone:
(337) 491-5301
Ext or PIN:
5224

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
88
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2627
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
June 14, 2010
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

76-W Flare
RMP ID:
1000048374
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
185,800
No
Public OCA Chemical
0
No
13-Saturated Gas Recovery
RMP ID:
1000048375
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
132,000
No
Public OCA Chemical
0
No
11-Hydrocracker
RMP ID:
1000048376
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
58,000
No
Public OCA Chemical
0
No
12-Hydrodewaxer
RMP ID:
1000048377
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
8,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
May 30, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000039405

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in 76-W Flare)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in 76-W Flare)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

76-W Flare, Petroleum Refineries (32411)
Prevention Program ID:
1000041982
Safety Review Date
Feb. 20, 2014, since latest RMP submission
PHA Update Date
June 22, 2010, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Dikes
  • Fire Walls
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 23, 2014, since latest RMP submission
Training Review Date
Dec. 21, 2011, since latest RMP submission
Maintenance Review Date
May 1, 2014, since latest RMP submission
Maintenance Inspection Date
March 10, 2012, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 28, 2014
Management of Change Review Date
Aug. 30, 2013
Pre-startup Review Date
March 24, 2014
Compliance Audit Date
May 6, 2013
Compliance Audit Change Completion Date
July 1, 2014
Incident Investigation Date
May 12, 2011
Incident Invest. Change Completion Date
May 30, 2012
Participation Plan Review Date
May 2, 2011
Hot Work Review Date
Dec. 18, 2013
Contractor Safety Review Date
Aug. 23, 2013, since latest RMP submission
Contractor Safety Eval. Date
May 5, 2014, since latest RMP submission
13-Saturated Gas Recovery, Petroleum Refineries (32411)
Prevention Program ID:
1000041981
Safety Review Date
April 22, 2014, since latest RMP submission
PHA Update Date
Jan. 8, 2013, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Dikes
  • Fire Walls
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 23, 2014, since latest RMP submission
Training Review Date
Dec. 21, 2011, since latest RMP submission
Maintenance Review Date
May 1, 2014, since latest RMP submission
Maintenance Inspection Date
April 4, 2012, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 9, 2014
Management of Change Review Date
Aug. 30, 2013
Pre-startup Review Date
Jan. 10, 2014
Compliance Audit Date
May 6, 2013
Compliance Audit Change Completion Date
July 1, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
May 2, 2011
Hot Work Review Date
Dec. 18, 2013
Contractor Safety Review Date
Aug. 23, 2013, since latest RMP submission
Contractor Safety Eval. Date
May 5, 2014, since latest RMP submission
11-Hydrocracker, Petroleum Refineries (32411)
Prevention Program ID:
1000041983
Safety Review Date
May 16, 2014, since latest RMP submission
PHA Update Date
Jan. 6, 2014, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Dikes
  • Fire Walls
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 23, 2014, since latest RMP submission
Training Review Date
Dec. 21, 2011, since latest RMP submission
Maintenance Review Date
May 1, 2014, since latest RMP submission
Maintenance Inspection Date
April 15, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 9, 2014
Management of Change Review Date
Aug. 30, 2013
Pre-startup Review Date
March 4, 2014
Compliance Audit Date
May 6, 2013
Compliance Audit Change Completion Date
July 1, 2014
Incident Investigation Date
Aug. 1, 2010
Incident Invest. Change Completion Date
Sept. 10, 2010
Participation Plan Review Date
May 2, 2011
Hot Work Review Date
Dec. 18, 2013
Contractor Safety Review Date
Aug. 23, 2013, since latest RMP submission
Contractor Safety Eval. Date
May 5, 2014, since latest RMP submission
12-Hydrodewaxer, Petroleum Refineries (32411)
Prevention Program ID:
1000041984
Safety Review Date
April 9, 2014, since latest RMP submission
PHA Update Date
March 23, 2010, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Dikes
  • Fire Walls
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 23, 2014, since latest RMP submission
Training Review Date
Dec. 21, 2011, since latest RMP submission
Maintenance Review Date
May 1, 2014, since latest RMP submission
Maintenance Inspection Date
April 4, 2012, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 2, 2014
Management of Change Review Date
Aug. 30, 2013
Pre-startup Review Date
Jan. 10, 2014
Compliance Audit Date
May 6, 2013
Compliance Audit Change Completion Date
July 1, 2014
Incident Investigation Date
Feb. 27, 2013
Incident Invest. Change Completion Date
Oct. 18, 2013
Participation Plan Review Date
May 2, 2011
Hot Work Review Date
Dec. 18, 2013
Contractor Safety Review Date
Aug. 23, 2013, since latest RMP submission
Contractor Safety Eval. Date
May 5, 2014, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
April 29, 2014
Local Response Agency:
Local Response Agency Phone:
(337) 433-3512
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

EXECUTIVE SUMMARY



Louisiana Department of Environmental Quality Facility ID Number - 30830

EPA Facility ID Number 1000 0004 0387



EXCEL PARALUBES

RISK MANAGEMENT PLAN

EXECUTIVE SUMMARY



The RMP rule requires that this site provide an executive summary in the RMPlan. This summary provides the following items:

Accidental release prevention and response policies

Description of the stationary source and regulated substances

General accidental release prevention program and chemical-specific prevention steps

Five-year accident history

Emergency response program

Planned changes to improve safety



ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES



The Phillips 66 Company and FHR Lubricants, LLC partnership - Excel Paralubes site has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement effective controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES



The Excel Paralubes site is located in Westlake, Louisiana. It operates a variety of processes that takes vacuum gas oil (an intermediate product from the refining of raw crude oil) and produces petroleum products such as naptha, kerosene, diesel and lubricant base oils. The Excel Paralubes site has regulated flammables, such as propane, butane, NFPA4 flammable mixtures, and hydrogen. The site also has several of the RMP listed toxic substances, but none at the quantity or concentration specified in the regulation.



GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS



The following is a summary of the general accident prevention program in place at the Excel Paralubes site. Because p
rocesses at the site are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.



Employee Participation



The Excel Paralubes site 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. 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 an employee participation plan that is maintained at the site and addresses each accident prevention program element. In addition, the site has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management.



Process Safety Information



The Excel Paralubes site keeps a variety of technical documents called Process Technology Packages (PTP's). PTP's 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 the refinery are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the written employee participation plan to help employees locate any necessary process safety information.



Chemical-specific infor
mation, 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, the refinery has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in a Safe Operating Limits (SOL) section of the PT Packages. The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g. automated shutdown systems).



The site 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



The Excel Paralubes site has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.

The Excel Paralubes site uses a combination of the hazard and operability (HAZOP) analysis technique along with a What-If checklist to perform these evaluations. In addition the HAZOP/What-If checklist the site uses a systematic Layer of Protection Analysis (LOPA) which takes industry failure rates and applies to a scenario to calculate a threshold value. The
combination of HAZOP/What-If checklist/LOPA is recognized as one of the most systematic and thorough hazard evaluation techniques. 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 accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.



The PHA team findings are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained.

To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Excel Paralubes site periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented, tracked, and retained. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained.



Operating Procedures



The Excel Paralubes site maintains written procedures that address various modes of process operations, such as (1) process 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 b
asis 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.

In addition, the Excel Paralubes site maintains key process parameter documents that provide guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process and for other personnel to use as necessary to safely perform their job tasks.



Training



To complement the written procedures for process operations, the Excel Paralubes site has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery 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 tests, 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 at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training.



Contractors



The Excel Paralubes site uses contractors to supplement its workforce for maintenance or construction activities. Because some contractors work on or near process equipment, the refinery 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 refinery 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, and (4) safe work practices prior to their beginning work. In addition, the Excel Paralubes site evaluates contractor safety programs and performance during the selection of a contractor. Site personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.



Pre-startup Safety Reviews (PSSRs)



The Excel Paralubes site conducts a PSSR for any new facility or facility modification that requires a 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 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.



Mechanical Integrity



The Excel Paralubes site 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 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. 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 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. The Excel Paralubes site 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



The Excel Paralubes site 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 work), 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 tr
aining of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.



Management of Change



The Excel Paralubes site 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 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.



Incident Investigation



The Excel Paralubes site 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 forwards these results to refinery 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 preve
ntion program is functioning properly, the Excel Paralubes site periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to refinery 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 the Excel Paralubes site have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 2 and 3 EPA RMP-covered processes at the Excel Paralubes site. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failure and (2) human errors.



In addition to the accident prevention program activities, the Excel Paralubes site has safety features on many processes to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequence of (mitigate) a release. The following types of safety features are used in various processes:



Release detection:

Hydrocarbon detectors with alarms

Hydrogen Sulfide detectors with alarms



Release Containment/Control:

Process relief valves that discharge to a flare to capture and incinerate episodic releases

Scrubber to neutralize chemical releases

Valves to permit isolation of the process (manually or automated)

Automatic shutdown systems for specific process parameters (e.g., high level, high temperature)

Curbing or diking to contain liquid releases

Redundant equipment and instrumentation (e.g., interruptible power supply for process control system,
backup firewater pump)

Atmospheric relief devices



Release Mitigation:

Fire suppression and extinguishing systems

Deluge for specific equipment

Trained emergency response personnel

Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)

Blast-resistant buildings to help protect control systems and personnel



FIVE-YEAR ACCIDENT HISTORY



We keep records for all significant accidental chemical releases that occur at our facility. We investigate every incident very carefully to determine ways to prevent similar incidents from occurring. The following is a brief summary of accidental chemical releases involving material covered under EPA's RMP rule since June, 2009. This incident history considers on-site/off-site impacts such as injuries and fatalities, on-site/off-site property damage of $100,000 or more, off-site impact such as shelter-in-place or evacuation of the public and off-site environmental damage.



Summary: From June 2009 through May 2014 we have had no significant accidental releases.



EMERGENCY RESPONSE PROGRAM INFORMATION



The Excel Paralubes site 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. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, 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, the Excel Paralubes site has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equi
pment. 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 refinery processes or other refinery facilities.



The overall emergency response program for the Excel Paralubes site is coordinated with the Lake Charles, Louisiana 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. The Excel Paralubes site 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, the Excel Paralubes site conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the refinery provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the refinery.



PLANNED CHANGES TO IMPROVE SAFETY



The Excel Paralubes site resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned:



Risk Based Inspection (RBI) and Criticality Studies

Retro Positive Material Identification (PMI) program

Corrosion Under Insulation (CUI) program

Short Term Fix Guidelines to facilitate shortened response time to unit upsets

Continued upgrade of tandem seals in high risk pumps

Instrumented Safety Systems (ISS) program

Improvements to firewater system reliability and integrity

Improvements to site security