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TPI Petroleum, Inc.

Parent Companies:
Ultramar Diamond Shamrock Corporation
EPA Facility ID:
100000149387
Other ID:
Facility DUNS:
128447307
Parent Company DUNS:
789875010

Location:

Address:
1925 E. Superior Street
Alma, MI 48802
County:
GRATIOT
Lat / Long:
43.379, -84.625 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
SE Corner of Land Parcel
Horizonal accuracy:
m
Horizontal reference datum:
Source map scale:

Owner/Operator:

Name:
TPI Petroleum Inc.
Phone:
(800) 223-0534
Address:
1925 E.Superior
Alma, MI 48802 -0000
Foreign Address:

Person responsible for RMP implementation:

Name:
Milton "Marty" Neil Martin Jr.
Title:
Safety Manager
Email:

Emergency contact:

Name:
Milton "Marty" Neil Martin Jr.
Title:
Safety Manager
Phone:
(517) 463-9663
24-hour phone:
(517) 463-1164
Ext or PIN:
Email:

Other contacts:

Facility (or company) email:
Facility phone:
(517) 463-1164
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Full-Time Equivalent Employees:
217
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
199700037
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Feb. 8, 1996
Inspecting Agency:
State occupational safety agency
Using Predictive Filing:
No

Processes:

Prefractionator Unit
RMP ID:
23568
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
22,357
No
Flammable Mixture
00-11-11
18,489
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Fcc Unit
RMP ID:
23569
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
72,396
No
Public OCA Chemical
0
No
Sat Gas Recovery Unit
RMP ID:
23570
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
5,596
No
Flammable Mixture
00-11-11
52,630
No
Flammable Mixture
00-11-11
5,865
No
Flammable Mixture
00-11-11
92,862
No
Flammable Mixture
00-11-11
1,000
No
Flammable Mixture
00-11-11
72,697
No
Flammable Mixture
00-11-11
27,540
No
Flammable Mixture
00-11-11
30,345
No
Flammable Mixture
00-11-11
104,060
No
Flammable Mixture
00-11-11
83,402
No
Flammable Mixture
00-11-11
106,112
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
NHT Unit
RMP ID:
23571
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
3,025
No
Flammable Mixture
00-11-11
1,820
No
Flammable Mixture
00-11-11
1,171
No
Flammable Mixture
00-11-11
128,514
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
No 1 Reformer
RMP ID:
23572
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
33
No
Flammable Mixture
00-11-11
24,354
No
Flammable Mixture
00-11-11
27,856
No
Flammable Mixture
00-11-11
4,855
No
Flammable Mixture
00-11-11
54,154
No
Flammable Mixture
00-11-11
2,032
No
Flammable Mixture
00-11-11
38,787
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Naphtha Splitter
RMP ID:
23573
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
98,165
No
Public OCA Chemical
0
No
LCO Hydrotreater
RMP ID:
23574
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
282
No
Flammable Mixture
00-11-11
1,365
No
Flammable Mixture
00-11-11
5,750
No
Flammable Mixture
00-11-11
8,256
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Distillate Hydrotreater
RMP ID:
23575
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
25,375
No
Flammable Mixture
00-11-11
1,805
No
Flammable Mixture
00-11-11
470
No
Flammable Mixture
00-11-11
5,214
No
Flammable Mixture
00-11-11
22,309
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Unsat Gas Plant
RMP ID:
23576
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
12,895
No
Flammable Mixture
00-11-11
33,837
No
Flammable Mixture
00-11-11
19,722
No
Flammable Mixture
00-11-11
3,005
No
Flammable Mixture
00-11-11
3,315
No
Flammable Mixture
00-11-11
2,210
No
Flammable Mixture
00-11-11
19,454
No
Flammable Mixture
00-11-11
543
No
Flammable Mixture
00-11-11
53,600
No
Flammable Mixture
00-11-11
5,319
No
Flammable Mixture
00-11-11
29,204
No
Flammable Mixture
00-11-11
3,170
No
Flammable Mixture
00-11-11
2,519
No
Flammable Mixture
00-11-11
81,354
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
HF Alkylation
RMP ID:
23577
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
27,143
No
Flammable Mixture
00-11-11
201,221
No
Flammable Mixture
00-11-11
50,607
No
Flammable Mixture
00-11-11
121,847
No
Flammable Mixture
00-11-11
266,315
No
Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid]
7664-39-3
202,382
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Dimersol
RMP ID:
23578
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
60,189
No
Public OCA Chemical
0
No
LPG Merox (Extraction)
RMP ID:
23579
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
91,622
No
Flammable Mixture
00-11-11
20,149
No
Flammable Mixture
00-11-11
90,074
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Penex (Isomerization)
RMP ID:
23580
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
24,330
No
Flammable Mixture
00-11-11
9,790
No
Flammable Mixture
00-11-11
4,490
No
Flammable Mixture
00-11-11
4,727
No
Flammable Mixture
00-11-11
9,818
No
Flammable Mixture
00-11-11
4,478
No
Flammable Mixture
00-11-11
1,428
No
Flammable Mixture
00-11-11
8,210
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Tankage
RMP ID:
23581
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propane
74-98-6
1,752
No
Flammable Mixture
00-11-11
931,115
No
Flammable Mixture
00-11-11
227,107
No
Flammable Mixture
00-11-11
951,418
No
Flammable Mixture
00-11-11
1,189,592
No
Isobutane [Propane, 2-methyl]
75-28-5
1,040,241
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Sulfur Recovery Unit
RMP ID:
23582
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen sulfide
7783-06-4
12,199
No
Public OCA Chemical
0
No
Dimersol Stabilizer Unit
RMP ID:
23583
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
579
No
Flammable Mixture
00-11-11
9,921
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 24, 1999
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
16836

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: 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 HF Alkylation)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: 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 HF Alkylation)
CBI claimed:
No
Percent weight:
77.2
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Sulfur Recovery Unit)
CBI claimed:
No
Percent weight:
21.9
Physical state:
Gas
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

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 Tankage)
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 No 1 Reformer)
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
  • Excess flow valve
Public OCA Chemical (in HF Alkylation)
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
  • Excess flow valve
Public OCA Chemical (in LPG Merox (Extraction))
CBI claimed:
No
Model used:
Equations from RMP OCA guidance
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve
Public OCA Chemical (in Tankage)
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
  • Excess flow valve
Public OCA Chemical (in Tankage)
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
  • Excess flow valve
Public OCA Chemical (in Tankage)
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
  • Excess flow valve
Public OCA Chemical (in Tankage)
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
  • Excess flow valve

6. Five-year accident history

April 30, 1998 at 06:50
ID:
2405
NAICS:
Petroleum Refineries (32411)
Duration:
1 minutes
Chemicals involved:
  • Propane
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None meters/second
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised operating procedures
April 19, 1998 at 10:00
ID:
2409
NAICS:
Petroleum Refineries (32411)
Duration:
1 minutes
Chemicals involved:
  • Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None meters/second
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
  • Improper procedure
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Revised training
Oct. 30, 1996 at 13:30
ID:
2406
NAICS:
Petroleum Refineries (32411)
Duration:
1 minutes
Chemicals involved:
  • Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid]
Release events:
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
None meters/second
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Upset condition
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
Aug. 3, 1996 at 06:00
ID:
2408
NAICS:
Petroleum Refineries (32411)
Duration:
1 minutes
Chemicals involved:
  • Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None meters/second
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Human error
  • Improper procedure
  • Unsuitable equipment
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised training
Feb. 8, 1996 at 12:15
ID:
2410
NAICS:
Petroleum Refineries (32411)
Duration:
30 minutes
Chemicals involved:
  • Propane
Release events:
Gas release
Fire
Weather conditions at time of event
Wind speed:
None meters/second SW
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
1
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
5
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$266000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$266000
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Maintenance activity/inactivity
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised training
  • Revised operating procedures
  • New process controls
Nov. 5, 1994 at 11:20
ID:
2407
NAICS:
Petroleum Refineries (32411)
Duration:
1 minutes
Chemicals involved:
  • Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None meters/second
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Human error
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment

7. Prevention: Program level 3

Prefractionator Unit, Petroleum Refineries (32411)
Prevention Program ID:
13004
Safety Review Date
June 1, 1999
PHA Update Date
Aug. 1, 1996
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
June 1, 1999
Training Review Date
Jan. 4, 1999
Maintenance Review Date
Nov. 13, 1995
Maintenance Inspection Date
May 2, 1997
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
Dec. 31, 1999
Incident Investigation Date
None
Incident Invest. Change Completion Date
Sept. 14, 1998
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Fcc Unit, Petroleum Refineries (32411)
Prevention Program ID:
13005
Safety Review Date
June 3, 1999
PHA Update Date
May 28, 1999
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 27, 1999
Training Review Date
June 3, 1999
Maintenance Review Date
Aug. 8, 1996
Maintenance Inspection Date
May 2, 1997
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
Oct. 19, 1998
Incident Invest. Change Completion Date
Oct. 22, 1998
Participation Plan Review Date
April 12, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Sat Gas Recovery Unit, Petroleum Refineries (32411)
Prevention Program ID:
13006
Safety Review Date
June 1, 1999
PHA Update Date
Sept. 30, 1994
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Equipment failure
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
June 1, 1999
Training Review Date
June 1, 1999
Maintenance Review Date
Dec. 11, 1995
Maintenance Inspection Date
March 31, 1991
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
Nov. 7, 1998
Incident Invest. Change Completion Date
Nov. 7, 1998
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
NHT Unit, Petroleum Refineries (32411)
Prevention Program ID:
13007
Safety Review Date
June 1, 1999
PHA Update Date
May 28, 1999
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
Procedure Review Date
June 1, 1999
Training Review Date
June 1, 1999
Maintenance Review Date
Nov. 14, 1995
Maintenance Inspection Date
April 30, 1996
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
Sept. 30, 1998
Incident Invest. Change Completion Date
Sept. 30, 1998
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
No 1 Reformer, Petroleum Refineries (32411)
Prevention Program ID:
13008
Safety Review Date
June 1, 1999
PHA Update Date
May 28, 1999
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Backup Pump
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
Procedure Review Date
June 1, 1999
Training Review Date
June 1, 1999
Maintenance Review Date
Dec. 26, 1996
Maintenance Inspection Date
June 7, 1999
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Naphtha Splitter, Petroleum Refineries (32411)
Prevention Program ID:
13009
Safety Review Date
June 1, 1999
PHA Update Date
April 1, 1997
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
Procedure Review Date
June 1, 1999
Training Review Date
June 1, 1999
Maintenance Review Date
May 3, 1993
Maintenance Inspection Date
May 31, 2063
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
LCO Hydrotreater, Petroleum Refineries (32411)
Prevention Program ID:
13010
Safety Review Date
June 1, 1999
PHA Update Date
May 28, 1999
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
Procedure Review Date
June 1, 1999
Training Review Date
June 1, 1999
Maintenance Review Date
April 1, 1998
Maintenance Inspection Date
April 30, 1998
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
May 1, 1998
Incident Invest. Change Completion Date
May 1, 1998
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Distillate Hydrotreater, Petroleum Refineries (32411)
Prevention Program ID:
13011
Safety Review Date
July 20, 1998
PHA Update Date
Nov. 27, 1998
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
May 28, 1999
Training Review Date
May 28, 1999
Maintenance Review Date
Dec. 30, 1996
Maintenance Inspection Date
April 30, 1998
Equipment Tested
Yes
Management of Change Most Recent Date
March 23, 1999
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
Oct. 28, 1993
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
Dec. 31, 1999
Incident Investigation Date
Dec. 5, 1998
Incident Invest. Change Completion Date
Dec. 14, 1998
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Unsat Gas Plant, Petroleum Refineries (32411)
Prevention Program ID:
13012
Safety Review Date
April 1, 1996
PHA Update Date
April 26, 1996
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
June 3, 1999
Training Review Date
June 3, 1999
Maintenance Review Date
April 16, 1996
Maintenance Inspection Date
March 31, 1993
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
HF Alkylation, Petroleum Refineries (32411)
Prevention Program ID:
13013
Safety Review Date
Sept. 1, 1998
PHA Update Date
Sept. 30, 1998
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Contamination
  • Equipment failure
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
April 28, 1999
Training Review Date
Jan. 4, 1999
Maintenance Review Date
Sept. 29, 1995
Maintenance Inspection Date
Oct. 31, 1996
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
April 27, 1999
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
Nov. 25, 1998
Incident Invest. Change Completion Date
Nov. 25, 1998
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Dimersol, Petroleum Refineries (32411)
Prevention Program ID:
13014
Safety Review Date
June 30, 1995
PHA Update Date
June 1, 1995
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Contamination
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Grounding Equipment
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • Process Detection
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
June 3, 1999
Training Review Date
June 3, 1999
Maintenance Review Date
Dec. 30, 1996
Maintenance Inspection Date
April 30, 1997
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
LPG Merox (Extraction), Petroleum Refineries (32411)
Prevention Program ID:
13015
Safety Review Date
Dec. 16, 1996
PHA Update Date
Jan. 2, 1997
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
June 3, 1999
Training Review Date
June 3, 1999
Maintenance Review Date
Dec. 31, 1996
Maintenance Inspection Date
April 30, 1997
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Penex (Isomerization), Petroleum Refineries (32411)
Prevention Program ID:
13016
Safety Review Date
April 1, 1997
PHA Update Date
April 25, 1997
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
Procedure Review Date
June 1, 1999
Training Review Date
June 1, 1999
Maintenance Review Date
Nov. 14, 1995
Maintenance Inspection Date
Oct. 30, 1998
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
Sept. 19, 1998
Incident Invest. Change Completion Date
Sept. 19, 1998
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Tankage, Petroleum Refineries (32411)
Prevention Program ID:
13017
Safety Review Date
April 15, 1999
PHA Update Date
May 15, 1997
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Fire
  • Explosion
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
Procedure Review Date
July 27, 1998
Training Review Date
July 27, 1998
Maintenance Review Date
Sept. 2, 1998
Maintenance Inspection Date
Sept. 30, 1998
Equipment Tested
Yes
Management of Change Most Recent Date
April 10, 1999
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
April 10, 1999
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
Dec. 31, 1999
Incident Investigation Date
April 28, 1999
Incident Invest. Change Completion Date
May 12, 1999
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Sulfur Recovery Unit, Petroleum Refineries (32411)
Prevention Program ID:
13018
Safety Review Date
Aug. 31, 1998
PHA Update Date
Oct. 30, 1998
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
May 28, 1999
Training Review Date
May 28, 1999
Maintenance Review Date
Dec. 31, 1996
Maintenance Inspection Date
April 30, 1998
Equipment Tested
Yes
Management of Change Most Recent Date
March 26, 1999
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
Oct. 28, 1993
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
Dec. 31, 1999
Incident Investigation Date
Jan. 8, 1998
Incident Invest. Change Completion Date
Jan. 12, 1998
Participation Plan Review Date
April 15, 1996
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999
Dimersol Stabilizer Unit, Petroleum Refineries (32411)
Prevention Program ID:
13019
Safety Review Date
April 28, 1999
PHA Update Date
June 30, 1995
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
April 28, 1999
Training Review Date
April 28, 1999
Maintenance Review Date
Feb. 2, 1998
Maintenance Inspection Date
Feb. 27, 1998
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Feb. 28, 1997
Pre-startup Review Date
None
Compliance Audit Date
March 20, 1998
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
May 5, 1999
Hot Work Review Date
June 17, 1996
Contractor Safety Review Date
Nov. 27, 1998
Contractor Safety Eval. Date
Feb. 26, 1999

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
No
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:
Feb. 24, 1999
Local Response Agency:
Local Response Agency Phone:
(517) 463-8317
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

General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities

1. Accidental Release Prevention and Emergency Response Policies
We at Total Petroleum Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances.


2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass Petroleum refining and marketing. We have 21 regulated substances present at our facility. These substances include Isopentane [Butane, 2-methyl-], Butane, Pentane, Isobutane [Propane, 2-methyl], Propane, 1-Pentene, Butene, Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid], Propylene [1-Propene], Ethane, Hydrogen sulfide, Hydrogen, Methane, 1,3-Butadiene, Ethylene [Ethene], Ammonia (anhydrous), Chlorine, 1-Butene, 1,3-Pentadiene, Carbon oxysulfide [Carbon oxide sulfide (COS)] and Carbon disulfide. Isopentane [Butane, 2-methyl-] is used for gasoline blending. Butane is used for gasoline blending. Pentane is used for gasoline blending. Isobutane [Propane, 2-methyl] is used for gasoline blending. Propane is used for LPG sales. 1-Pentene is used for gasoline blending. Butene is used for gasoline blending. Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] is used as a catalyst for increasing the octane of gasoline. Propylene [1-Propene] is used for LPG sales. Ethane is used for refinery fuel gas. Hydrogen sulfide is a process biproduct which is converted to sulfur. Hydrogen is used for various refinery processes. Methane is used for refinery fuel gas. 1,3-Butadiene is used for gasoline blending. Ethylene [Ethene] is used for refinery fuel gas.
Ammonia (anhydrous) is used for pH control. Chlorine is used for water treatment. 1-Butene is used for gasoline blending. 1,3-Pentadiene is used for gasoline blending. Carbon oxysulfide [Carbon oxide sulfide (COS)] is a process biproduct. Carbon disulfide is a process biproduct.

The maximum inventorys at our facility are: Isopentane [Butane, 2-methyl-] is 11231551.41 lb.; Butane is 10,059,042.43 lb.; Pentane is 6,139,166.01 lb.; Isobutane [Propane, 2-methyl] is 3,347,498.20 lb.; Propane is 1,712,980.67 lb.; 1-Pentene is 1,278,585.76 lb.; Butene is 760,767.01 lb.; Hydrogen fluride/Hydrofluoric acid [Hydrofluoric acid] is 273,656.97 lb.; Propylene [1-Propene] is 204,432.63 lb.; Ethane is 62,820.07 lb.; Hydrogen sulfide is 26,271.86 lb.; Hydrogen is 16,636.57 lb.; Methane is 11,179.22 lb.; 1,3-Butadiene is 6,432.65 lb.; Ethylene [Ethene] is 4,619.28 lb.; Ammonia (anhydrous) is 3,773.07 lb.; Chlorine is 2,000 lb.; 1-Butene is 8.51 lb.; 1,3-Pentadiene is 3.13 lb.; Carbon oxysulfide [Carbon oxide sulfide (COS)] is 2.57 lb.; and Carbon disulfide is 1.06 lb.

3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To evaluate the worst case scenarios, we have used the EPA's OCA Guidance Reference Tables or Equations or the EPA's RMP*Comp{TM} and Equations. For alternative release scenario analyses we have employed the EPA's OCA Guidance Reference Tables or Equations, the EPA's RMP*Comp(TM) and Equations from RMP OCA guidance. The following paragraphs provide details of the chosen scenarios.

The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from HF Alkylation. In this scenario 67917 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation
takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 30% of the maximum capacity of the source by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.016 mg/L.

The alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a release from HF Alkylation. The scenario involves the release of 130800 lb. of Hydrofluoric acid. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 60 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 5.8 miles.

The alternative release scenario for Hydrogen sulfide involves a release from Sulfur Recovery Unit. The scenario involves the release of 5260 lb. of Hydrogen sulfide. Toxic gas is assumed to be released. The release is estimated to cease after 60 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.042 mg/L of Hydrogen sulfide is 0.3 miles.

The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Tankage. In this scenario 681798 lb. of Isobutane [Propane, 2-methyl] is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.71 miles is obtained corresponding to an endpoint of 1 psi overpressure.

One alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Tankage. The release is assumed to r
esult in a Vapor Cloud Explosion. The scenario involves the release of 147600.00 lb. of Flam. Mix.: Isopentane [Butane, 2-methyl-], Butane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.28 miles.

Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from HF Alkylation. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 234832 lb. of Flam. Mix.: Isobutane [Propane, 2-methyl], Butane, Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.26 miles.

Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from LPG Merox (Extraction). The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 20045 lb. of Flam. Mix.: Isobutane [Propane, 2-methyl], Butane, Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.22 miles.

Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Tankage. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 147600.00 lb. of Isobutane [Propane, 2-methyl] in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.22 miles.

Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Tankage. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 110378 lb. of Flam. Mix.: Butane, Propylene [1-Propene], Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.17 miles.

Another alternative release
scenario submitted for Program 2 and 3 flammable substances involves a release from Tankage. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 108241 lb. of Flam. Mix.: Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.17 miles.

Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from No 1 Reformer. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 4706 lb. of Flam. Mix.: Isopentane [Butane, 2-methyl-], Pentane, Isobutane [Propane, 2-methyl], Butane, Propane, Ethane, Methane, Hydrogen in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.09 miles.

4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.

Process Safety Information
Total Petroleum Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.

Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Checklist, What If/Checklist (combined), HAZOP, FMEA and Fault Tree. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years.
Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 05/25/1999.

Operating Procedures
For the purposes of safely conducting activities within our covered processes, Total Petroleum Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.

Training
Total Petroleum Inc. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed.

Mechanical Integrity
Total Petroleum Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.

Management of Change
Written procedures are in place at Total Petroleum Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/28/99. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.

Pre-startup Revie
ws
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Total Petroleum Inc.. The most recent review was performed on 04/27/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.

Compliance Audits
Total Petroleum Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 03/20/1998. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.

Incident Investigation
Total Petroleum Inc. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.

Employee Participation
Total Petroleum Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.

Contractors
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Total Petroleum Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's wor
k and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.


5. Five-year Accident History
Total Petroleum Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, the number of accidental releases has been reduced to a minimum.

There have been 6 accidental releases of regulated substances from our facility within the last 5 years. The first release took place on 11/05/1994 and involved 0.1 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid]. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury.

Another release, of 12000 lb. of Propane, occurred on 02/08/1996. No deaths or injuries occured offsite as a result of this accident. Onsite, there was one death and 3 injuries. There was some onsite property damage.

Another release, of 0.1 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid], occurred on 08/03/1996. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury.

Another release, of 0.1 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid], occurred on 10/30/1996. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury.

Another release, of 0.1 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid], occurred on 04/19/1998. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury.

Another release, of 0.1 lb. of Propane, occurred on 04/30/1998. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths and one injury.

6. Emergency Response Plan
Total Petroleum Inc. carries
a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.

To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.

7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. There are no major steps we want to take to improve safety at our facility as the facility is scheduled to be closed on October 1, 1999.