Exxon Chemical Company Baytown Olefins Plant - Executive Summary

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EXECUTIVE SUMMARY FOR 
EXXON CHEMICAL BAYTOWN OLEFINS PLANT 
 
 
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES  
 
The Exxon Baytown Olefins Plant (BOP) has a long-standing commitment to worker and public safety and protecting the environment. This commitment is demonstrated by its' continuing participation in the Occupational Safety and Health Administration's Voluntary Protection Program, as well as through the resources invested in accident prevention, such as personnel training and considering safety in the design, installation, operation, and maintenance of our processes.  In 1993, BOP was awarded the coveted "STAR" recognition by OSHA for excellence in occupational safety and health.  Continued membership as a STAR site requires continuous improvement in each of 19 rigorous elements, with periodic recertifications by OSHA.  In 1996, BOP was recertified as a STAR site and we are currently preparing for our second recertification in 2000.  Key elements of the VPP program  
include Hazard Assessment, Employee Participation, Management Commitment and Involvement, Process Safety Management, Incident Analysis and recommendation follow-up to completion.  Our objective is to implement effective controls to prevent releases of regulated substances.  However, if a release does occur, our trained personnel will respond to control, contain and mitigate the release. 
 
Exxon Corporation enhanced its safety programs in 1991 by implementing structured safety management systems entitled Operations Integrity Management System (OIMS).  In 1997, Lloyd's Register Quality Assurance reviewed OIMS and evaluated it against the international standard for Environmental Management Systems (ISO 14001) to determine if OIMS is equivalent to ISO 14001.  After an extensive review which included a number of facility audits, they concluded that the "environmental components of OIMS are consistent with the intent and meet the requirements of the ISO 14001 Environmental Management Systems  
Standard."  They went on to say, "We further believe Exxon to be among the industry leaders in the extent to which environmental management considerations have been integrated into its ongoing business processes." 
 
This Executive Summary describes the following: Stationary Source, Hazard Assessment Results, Accident Release Prevention Program Elements, Chemical Specific Prevention Steps, Five-Year Accident History, Emergency Response Program, Planned Changes to Improve Safety and Community Communication. 
 
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES  
 
The Exxon Baytown Olefins Plant is located in Baytown, Harris County, Texas.  It operates to produce a variety of chemical intermediate feedstocks such as ethylene, propylene, and butadiene.  The plant has several regulated flammables such as propylene, ethylene, propane, and butenes.  In addition, the plant uses chlorine, which is a regulated substance under this Rule.  The entire plant is considered one covered process 
for purposes of this plan. 
 
HAZARD ASSESSMENT RESULTS  
 
The hazard assessments were done using the EPA supplied "look up tables" and equations.   These tables and equations cover all the parameters required by the RMP rule for both worst case (WCS) and alternate case (ACS) scenarios. 
 
The WCS associated with toxic substances at our plant is a potential release of chlorine from a shipping cylinder that has a potential off-site impact. Although we have numerous controls to prevent such releases and to manage their consequences should one occur, EPA allowed no credit for administrative controls or active mitigation measures to be taken into account in evaluating this scenario.  Chlorine cylinders are stored in two locations  approximately 1/4 mile apart.  Since the scenario circles are offset by 1/4 mile and could potentially affect slightly different population groups, two potential worst case scenarios are included in the plan.  The only difference between the two scenarios is the loca 
tion and number of potentially impacted people. This WCS has a potential off-site endpoint. 
 
The alternative case scenario for chlorine involves a piping failure on a shipping cylinder.  This scenario does factor in the safety measures that we have in place; including chlorine monitors, frequent inspections and detailed operating and maintenance procedures that would minimize the likelihood and magnitude of any potential release.  As a result, this scenario could only impact an industrial right of way. 
 
The WCS associated with a release of flammable substances at our plant is a potential vapor cloud explosion (VCE) involving the full inventory of a refrigerated storage tank containing a covered flammable, in our case a mixture of 1,3-Butadiene and other C4's.  The full tank inventory is assumed to release, completely vaporize, and ignite, resulting in a VCE.  Although we have numerous controls to prevent such releases and to manage their consequences should one occur, EPA allowed no cr 
edit for mitigation to be taken into account in evaluating this WCS. This WCS has a potential off-site endpoint. 
 
The alternative case scenario for flammable substances involves a leak from a failed piping flange gasket with subsequent explosion. This scenario does factor in the safety measures that we have in place; including hydrocarbon monitors, frequent inspections and detailed operating and maintenance procedures that would minimize the likelihood and magnitude of any potential release.  As a result, this scenario could only impact an industrial neighbor plant. 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS  
 
The following is a summary of the general accident prevention program in place at the Exxon Baytown Olefins Plant.  EPA's Program 3 prevention requirements have been implemented for our entire plant.  This is the same approach taken with the OSHA Process Safety Management (PSM) standard.  We believe that this approach provides the maximum safety for our employees and th 
e community.   
 
In addition, Exxon Corporation has implemented Operations Integrity Management Systems (OIMS) at each of its operations worldwide that includes the aspects of EPA's prevention program and this summary describes OIMS.  Further, as already mentioned, OIMS has been attested as equivalent to ISO 14001 as a valid management system to oversee the implementation of the risk management activities. 
 
Additional details are included in the Data Element section of this Risk Management Plan.  Due to the ongoing nature of our safety program, the dates associated with the various activities in our accident prevention program are constantly changing.  To minimize rework, we selected May 1, 1999, as the date to begin collecting this information.  Consequently, most of the reviews/updates conducted after that date are not reflected in the Data Element information. 
 
Employee Participation  
 
The Exxon Baytown Olefins Plant encourages employees to participate in all facets of process safety 
management and accident prevention, a key thrust of the OSHA VPP program.  Examples of employee participation range from updating and compiling operating and maintenance procedures to participating as a member of a process hazard analysis (PHA) team.  Employees have access to information created as part of the accident prevention program.  Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that addresses each accident prevention program element.  In addition, a number of initiatives are under way that address process safety and employee safety issues.  These initiatives include forming teams to promote both process and personnel safety.  The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. 
 
Process Safety Information  
 
The Exxon Baytown Olefins Plant keeps a variety of technical documents that are used to help maintain safe op 
eration 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 groups within the plant are assigned responsibility for maintaining up-to-date process safety information.   
 
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs).  This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals.  For specific process areas, the plant has identified Operating Envelopes; i.e. documented safety-related limits for specific process parameters such as temperature, level, and compositions.  The plant ensures that the process is maintained within these limits using computerized process controls and monitoring instrumen 
ts, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems, alarm systems). 
 
The plant 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 Exxon Baytown Olefins Plant 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 haz 
ards.  In addition, new projects that add new facilities are analyzed as part of the design process to ensure that the controls necessary to adequately manage the hazards associated with these new facilities are installed as part of the project. 
 
The Exxon Baytown Olefins Plant primarily uses the Knowledge Based Hazard and Operability (HAZOP) study that is an adaptation by Exxon Research and Engineering and Exxon Chemical Americas of widely used industry methodologies to perform these evaluations.  HAZOP analysis 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 experience and engineering expertise on the process to be evaluated (called a Process Hazard Analysis, or PHA, team).  The PHA 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 evaluation done by the PHA team.  This evaluation helps ensure that potential accident scenarios assigned greater risk receive attention first.  All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete.  The resolution of each finding is documented and retained. 
 
To ensure that the process controls and/or process hazards do not deviate significantly from the original design safety features, the Exxon Baytown Olefins Plant periodically updates and revalidates the hazard analysis results, as well as tracks changes through the management of change system (discussed below).  These periodic reviews are conducted at least every 5 years for the life of the process. The results and findings from these updates are documented and re 
tained. The team findings are forwarded to management for consideration, and resolution of the findings is documented and retained. 
 
Operating Procedures  
 
The Exxon Baytown Olefins Plant maintains written procedures that address various modes of process operations, such as (1) startup, (2) shutdown, (3), normal and (4) emergency operations.  These procedures can be used as a reference by experienced operators and provide a consistent basis for training of new operators. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. These procedures are periodically reviewed and annually certified as current and accurate.   
 
The plant has identified operating envelopes; i.e. documented safety-related limits for specific process parameters such as temperature, level, and compositions. This information, along with written operating procedures, is readily available to operators in the process unit and for other  
personnel to use as necessary to safely perform their job tasks. 
 
Training 
 
To complement the written procedures for process operations, the Exxon Baytown Olefins Plant has implemented a comprehensive training program for all employees involved in operating a process.  New employees receive basic training in chemical plant operations if they are not already familiar with such operations.  After successfully completing this training, a new operator is paired with an experienced operator to learn process-specific duties and tasks.  After employees 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 operations and mechanical technicians periodically receive refresher training on the 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 trai 
ning is documented for each operator, including the means used to verify that the operator understood the training. 
 
Contractors  
 
The Exxon Baytown Olefins Plant uses contractors to supplement its workforce.  Because some contractors work on or near process equipment, the chemical plant 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 plant 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 Exxon Baytown Olefins Plant evaluates contractor safety programs and performance during t 
he selection of a contractor.  Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 
 
Pre-startup Safety Reviews (PSSRs)  
 
The Exxon Baytown Olefins Plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information and therefore, is controlled by management of change (MOC).  The purpose of the PSSR is to ensure 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 as a quality assurance function by requiring verification that accident prevention program requir 
ements are properly implemented. 
 
Mechanical Integrity  
 
The Exxon Baytown Olefins Plant 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 a 
nd 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 an appropriate 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 Exxon Baytown Olefins Plant 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 Exxon Baytown Olefins Plant has long-standing safe work practices in place to help ensure worker and process safety.  Thes 
e include orientations for visitors/contractors, control of the entry/presence/exit of support personnel, energy isolation for equipment being worked on, procedures for the safe removal of hazardous materials before opening of process piping/equipment, hot work permit/procedure to safely manage spark-producing activities, vehicle entry into process area, confined space entry permit/procedure to help ensure precautions are taken before entering confined spaces, and job safety analyses to identify and mitigate hazards associated with maintenance tasks.  These practices, along with related procedures and training of affected personnel, form a system to help ensure operations and maintenance activities are performed safely. 
 
Management of Change  
 
The Exxon Baytown Olefins Plant has a comprehensive system to manage changes to processes.  This system requires that changes to items such as process equipment, chemicals, technology, 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 before the change is implemented. 
 
Incident Investigation  
 
The Exxon Baytown Olefins Plant 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 root cause and develop corrective actions to prevent a recurrence of the incident or a similar incident.  The investigation team documents its findings, develops recommendatio 
ns to prevent a recurrence, and forwards these results to plant management for resolution.  Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete.  The 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 OSHA PSM program is functioning properly, the Exxon Baytown Olefins Plant periodically conducts an audit to determine whether the procedures and practices required by the program are being implemented.  Compliance audits are conducted at least every 3 years by Exxon personnel from other sites who are considered experts in the safety and environmental fields.  The audit team develops findings th 
at are forwarded to chemical plant management for resolution.  Corrective actions taken in response to the audit team's findings are tracked until they are complete.  The resolution of each finding is documented, and the two most recent audit reports are retained.   
 
In addition, an annual assessment of our management systems is conducted by BOP personnel to ensure they are functioning as intended.  Work plans are developed and tracked for systems where the assessment team has identified improvement opportunities. 
 
This system will be modified as necessary to incorporate the elements necessary to ensure compliance with the Risk Management Plan Prevention Program prior to the next audit cycle.  The data submitted in the plan is the data from the most recent audit driven by OSHA PSM.  Because that audit occurred less than a month prior to this submission, the dates for completion of follow-up items were not yet finalized.  Therefore, that data element (7. 10.b.) was left blank in this su 
bmission. 
 
CHEMICAL SPECIFIC PREVENTION STEPS  
 
The processes at the Exxon Baytown Olefins Plant have hazards that must be managed to ensure continued safe operation.  The accident prevention program summarized previously is applied to all covered processes, not just the RMP covered processes, at the Exxon Baytown Olefins Plant.  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, the Exxon Baytown Olefins Plant has safety features on many units to help, (1) quickly detect a release, (2) contain/control a release and (3) reduce the consequences of (mitigate) a release.  The following types of safety features are used in various processes: 
 
Release Detection 
1. Hydrocarbon detectors with alarms 
2. Operator surveillance  
 
Release Containment/Control 
1. Process relief valves that discharge to a flare to capture and inciner 
ate releases 
2. Valves to permit isolation of the process (manual or automated) 
3. Alarms that give early indication of approaching operating limits and provide opportunity for operator intervention 
4. Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 
5. Curbing,  dikes, or water sumps to contain liquid releases 
6. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 
 
Release Mitigation 
1. Fire suppression and extinguishing systems 
2. Deluge system for specific equipment 
3. Trained emergency response personnel 
4. Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 
5. Blast-resistant buildings to help protect control systems and personnel 
 
FIVE-YEAR ACCIDENT HISTORY  
 
The Exxon Baytown Olefins Plant has an excellent record of accident prevention over the life of the plant.  There have been no accidents for the past 5 years that 
are reportable under this regulation.  
 
EMERGENCY RESPONSE PROGRAM INFORMATION  
 
The Exxon Baytown Olefins Plant 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 Exxon Baytown Olefins Plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment.  Employe 
es receive annual training in these procedures to perform their specific emergency response duties.  The emergency response program is updated as necessary based on modifications made to plant processes or other plant facilities.  The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes. 
 
The Exxon Baytown Olefins Plant also maintains a volunteer fire brigade comprised of plant employees for the purpose of prevention, controlling/containing and suppressing industrial fires or chemicals releases.  The Exxon Baytown Olefins Plant is a member of the Baytown Exxon Emergency Response Network (BEERN) and the Channel Industries Mutual Aid group (CIMA).  Membership in both of these organizations allows BOP to give or receive aid to/from other area industries in the form of manpower, equipment and materials in the event of an emergency. 
 
The overall emergency response program for the Exxon Baytown 
Olefins Plant is coordinated with the City of Baytown Local Emergency Planning Committee (LEPC).  This coordination includes periodic meetings of the committee, which includes citizens, local emergency response officials, local government officials, and industry representatives.  The Exxon Baytown Olefins Plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., City of Baytown Fire Department).  This provides a means of notifying the public of an incident as well as facilitating quick response to an incident.  
 
CHANGES TO IMPROVE SAFETY  
 
The Exxon Baytown Olefins Plant resolves all findings from PHAs, some of which result in modifications to the process.   Within the past several years, the many changes have been made as a result of hazard analysis reviews, reducing the risk of incidents.  Following are several that are representative of the types of changes made: 
 
 7 Routed the vents from the chlorine safety va 
lves into the cooling tower to minimize release to atmosphere in the event of overpressure. 
 7 Installed stainless steel jacket on spheres storing flammable liquids to serve as insulation from fire. 
 7 Installed facilities to allow for dewatering of sphere to minimize risk of peroxide formation. 
 7 Installed high level alarm to prevent overfilling of knockout drum / pot. 
 
In addition, the following types of changes are planned for the future: 
 
 7 Upgrade as necessary the pressure relief valves and alarm systems on several cone roof tanks to improve incident prevention and mitigation capabilities. 
 7 Evaluate installing motor operated valves to enhance the ability to isolate equipment in the event of an emergency. 
 7 Evaluate need for additional electrical system redundancy on critical pumps.  
 
COMMUNITY COMMUNICATION  
 
The Exxon Baytown Olefins Plant is committed to open dialogue with the surrounding community.  As such, we participated in the East Harris County Manufacturer's As 
sociation community rollout of the release scenario information contained in this plan.  The information, provided in both English and Spanish, included general descriptions of the RMP regulation, scenario circles, and Shelter-in-Place information, as well as facility specific Worst Case and Alternative Case Scenarios, mitigation techniques and 5-year accident histories. 
 
RMP briefings were scheduled for the trustees of the local school district and community college, LEPC, city council and business/service organizations and a plan has been developed to meet with over 50 local professional, neighborhood, civic and church organizations.   Thus far, feedback from the community has been positive and gratifying. 
 
The Exxon Baytown Olefins Plant is also a member of the Plant Managers' Network which sponsors the Baytown Area Citizens Advisory Panel.  This panel is comprised of a cross section of individuals from the Baytown and Mont Belvieu communities and meets monthly with representatives  
of the Plant Managers' Network.  Topics of discussion include safety, emergency response, plant operations and RMP communications.  
 
Members of the local community interested in receiving additional information regarding the Exxon Baytown Olefins Plant's Risk Management Plan or Emergency Response Plan should contact the Exxon Baytown Area Public Affairs Manager.
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