BP Chemicals, Inc. - Executive Summary |
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BP Chemicals, Green Lake, Texas(6.5 miles south of Bloomington) EPA Risk Management Plan - Executive Summary 1.0 Scope The process used to produce BP Chemicals Green Lake products contain quantities of flammable or listed hazardous chemicals which require application of Process Safety Management (PSM) as required in OSHA 29 CFR Part 1910 and the EPA Risk Management Program (RMP). BP management strongly supports Process Safety Management and the Risk Management Program and recognizes it as a good business practice as well as a good approach to protecting workers and the public from industrial operation hazards. BP Chemicals Green Lake applies the basic principles of Process Safety Management and the Risk Management Program to all applicable processes. BP Chemicals is an OSHA VPP Star site. The facility is also ISO 9002 certified. The facility has been awarded "Best In Texas" from the Texas Chemical Council for the years '89, '91, '92, '95, '96, '97, and '98; The facility h as also been awarded the following; NPRA Gold Award & Award for Achievement - '95,'97, and '98, Governor's Award for Environmental Excellence-'93, US EPA Environmental Excellence Awards-1993 Underground Injection, 1994 NPDES, Waste Water Outfall, 1995 UIC and NPDES. The facility has also successfully achieved its clean industries 2000 goal of 50% reduction in TRI and hazardous waste. Regulated Substances Handled BP Chemicals Green Lake plant produces, ships, or uses as a raw material the following chemicals: Acrylonitrile Ammonia Butane Propylene Propane Chlorine Sulfur Dioxide Hydrogen Cyanide Worst Case Release Scenario(s) and the Alternative Release Scenario(s). Methodology given in the RMP Offsite Consequence Analysis Guidance by the EPA using equations (RMPComp version 1.02) has been employed by our facility to perform worst and alternative case release scenarios. A technical team consisting of six local area Chemical Manufacturers Associat ion member companies selected the basis for the scenarios. The team has been in existence since 1994. The teams findings were communicated in public meetings in October of '95 and again in May of '99 in an effort known as the Victoria/Calhoun County Communications tLiving Safely With Chemicalsv. The following paragraphs provide details of the chosen scenarios. Toxics Worst Case Release Scenario: The worst case submitted involves a catastrophic release from a full Crude (Off-Spec) atmospheric storage tank containing 8.1% Hydrocyanic Acid in the Acrylonitrile manufacturing process. This is conservative due to the Hydrocyanic Acid being calculated as a pure component. It is assumed that the entire quantity is released into a dike, which vaporizes and moves downwind. Under worst case weather conditions **, this scenario has offsite impacts corresponding to the endpoint indicated in the EPA Tables. For this scenario the planned emergency response would be to have water sprays a nd foam the diked area to minimize downwind effects and fire and explosion potential. The material would then be routed to a recycle sump. Alternative Release Scenario- Hydrocyanic Acid: This case involves a release from the Crude atmospheric storage tank containing off-spec material with 8.1% Hydrocyanic Acid in the Acrylonitrile manufacturing process. A vessel leak was assumed, with a 60 minute duration. This is conservative due to the Hydrocyanic Acid being calculated as a pure component. Under neutral weather conditions *, this scenario has offsite impacts corresponding to the endpoint indicated in the EPA Tables. For this scenario the planned emergency response would be to have water sprays and foam the diked area to minimize downwind effects and fire and explosion potential. The material would then be routed to a recycle sump. Alternative Release Scenario- Acrylonitrile: This case involves a release from the Acrylonitrile atmospheric storage tank in the Acrylonitr ile manufacturing process. A vessel leak was assumed, with a 60 minute duration. Under neutral weather conditions *, this scenario has offsite impacts corresponding to the endpoint indicated in the EPA Tables. For this scenario the planned emergency response would be to have water sprays and foam the diked area to minimize downwind effects and fire and explosion potential. The material would then be routed to a recycle sump. Alternative Release Scenario- Ammonia : This case involves a release from the Ammonia (anhydrous) pressure storage tank in the Acrylonitrile manufacturing process. A vessel leak was assumed, with a 60 minute duration. Under neutral weather conditions *, this scenario has offsite impacts corresponding to the endpoint indicated in the EPA Tables. For this scenario the planned emergency response would be to have water sprays to minimize downwind effects and fire and explosion potential. Alternative Release Scenario- Sulfur Dioxide: This case involves a release from a Sulfur Dioxide storage cylinder in the Acrylonitrile manufacturing process. A vessel leak was assumed. This scenario was calculated using 85 F and 67.34 psig since the cylinders are heated. The one ton cylinders are connected together with a common header so two cylinders were used in the calculation. Under neutral weather conditions *, this scenario has offsite impacts corresponding to the endpoint indicated in the EPA Tables. For this scenario the planned emergency response would be to have water sprays to minimize downwind effects. Alternative Release Scenario- Chlorine: This case involves a release from a Chlorine storage cylinder in the Acrylonitrile manufacturing process. A vessel leak was assumed. Under neutral weather conditions *, this scenario has offsite impacts corresponding to the endpoint indicated in the EPA Tables. For this scenario the planned emergency response would be to have water sprays to minimize downwind effects. Flammables Worst Case Release Scenario- Flammable Mixture: This case involves a catastrophic release from a full Propylene storage sphere in the Acrylonitrile manufacturing process. The scenario involves the release of a mixture of Propylene [1-Propene] (85%) and Propane (15%) . 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 **, this scenario has offsite impacts corresponding to an endpoint of 1 psi overpressure. For this scenario the planned emergency response would be to have water sprays to minimize downwind effects and fire and explosion hazards. Alternative Release Scenario- Flammable Mixture: This case involves a release of Propylene/Propane mixture from a railcar staged in the facilities railyard for transfer into the Acrylonitrile manufacturing process. A vessel leak was assumed, with a 60 minute duration. Under neu tral weather conditions *, this scenario has offsite impacts corresponding to an endpoint of 1 psi overpressure. For this scenario the planned emergency response would be to have water sprays to minimize downwind effects and fire and explosion hazards. ** --------Assumptions About Worst Case Scenario's--------- Wind Speed: 1.5 meters/second (3.4 miles/hour) Stability Class: F Air Temperature: 77 degrees F (25 degrees C) *-------Assumptions About Alternative Case Scenario's--------- Wind Speed: 3 meters/second (6.7 miles/hour) Stability Class: D Air Temperature: 77 degrees F (25 degrees C) 2.0 General Accidental Release Prevention Program 2.1 Responsibility Compliance to the EPA RMP is the responsibility of the plant manager and is effective on a plant wide basis. The plant manager is in direct consultation with the PSM/RMP Coordinator. 2.2 Policy BP Amoco's Policy Commitment to Health, Safety and Environmental (HSE) Performance Everybody who works for BP Amoco, anywhere , is responsible for getting HSE right. Good HSE performance and the health, safety and security of everyone who works for us are critical to the success of our business. Our goals are simply stated - no accidents, no harm to people, and no damage to the environment. We will continue to drive down the environmental and health impact of our operations by reducing waste, emissions and discharges, and using energy efficiently. We will produce quality products that can be used safely by our customers. We will: r consult, listen and respond openly to our customers, employees, neighbors, public interest groups and those who work with us; r work with others - our partners, suppliers, competitors and regulators - to raise the standards of our industry; r openly report our performance, good and bad; r recognize those who contribute to improved HSE performance. Our business plans include measurable HSE targets. We are all committed to meeting them. BP Chemicals Green Lake considers safety and health as important as production, quality or costs. BP Chemicals Green Lake is therefore committed to making safety, health and environmental considerations an integral part of our planning and manufacturing activities at BP Chemicals, including fire protection, site security and compliance with applicable legislation, such as Process Safety Management and the Risk Management Program. BP Chemicals Green Lake will operate the facilities in a manner that protects the environment, safety and health of our employees and contractors, their families and our community. BP Chemicals Green Lake is an active participant in Responsible Care as a member of the Chemical Manufacturers Association. Each BP Chemicals Green Lake employee and contractor has a responsibility to themselves, their co-workers and the community to contribute to the safety and welfare of the plant by constantly striving to work in a safe manner following established operating standards. As p art of the Total Quality Process, all BP Chemicals Green Lake employees are involved and committed to meeting all customer requirements, both internal and external. Employees understand the requirements of their jobs and attempt to meet those requirements safely the first time every time. Management will maintain the highest standards for safety and health in the design of buildings, equipment and processes. High standards will also be maintained in the development of job methods, the provision of personal protective equipment, the training of employees and in the development and implementation of Process Safety Management and the Risk Management Program. BP Chemicals Green Lake will use PSM/RMP Compliance Audits to identify areas of improvement in the Safety and Health Program. Management's goal is to promote a state of mind on the part of every employee which is conducive to safe and healthy habits both on and off the job. BP Chemicals Green Lake encourages employee par ticipation. Only through a combination of many individual employee efforts will continuos improvement be made in our Quality, Health, Safety, and Environmental initiatives including Process Safety Management and the Risk Management Program. It is the policy of BP Chemicals to consult with employees regarding the development and implementation of Process Safety Management and Risk Management plan activities, and to provide access to process hazard analyses, and all information developed in order to comply with OSHA 29 CFR Part 1910.119 and EPA's RMP Regulation. This will insure that employees are adequately informed of the hazards of the process and that personnel familiar with the process are utilized in defining or mitigating these hazards. 2.3 Organization Responsibilities The Plant Manager is responsible for overall PSM/RMP compliance at the site. This includes ensuring that all practices outlined in the policies are carried out and the effectiveness and adequacy of S afety and PSM systems as well as the RMP are subject to regular review. The HSE Manager is responsible to provide technical expertise in complying with regulatory requirements, to communicate applicable requirements to appropriate manufacturing managers, to ensure policies and procedures meet regulatory requirements, and to interface with regulatory agencies as needed. These responsibilities are all in support of the manufacturing functions. The PSM/RMP Coordinator provides technical expertise for process safety, communicates requirements to appropriate manufacturing managers and coordinates policies and procedures to meet process safety requirements in support of the manufacturing areas. 2.4 Employee Participation BP Chemicals Green Lake encourages employee participation in the plant's safety programs, including the Process Safety Management (PSM) and the Risk Management Program (RMP) Program. Development and implementation of the Process Safety Management standard and t he Risk Management Program is achieved through the efforts of employees at all levels. Employee consultations occur through existing forums and meetings as well as through employee PSM/RMP implementation efforts. Information required to be developed by the PSM standard and the RMP is made available to employees or their representatives upon request. It is the responsibility of each employee working at BP Chemicals Green Lake to participate in the plant's safety program and to follow all applicable safety rules, policies and procedures, including those required by PSM and the RMP. Each Manager, Team Leader and Shift Manager/Supervisor is responsible to make sure their team members are properly trained in the applicable safety practices, policies and procedures, including those required by PSM and the RMP. Information necessary for employees to safely conduct the activities of their job assignments is made available and is a part of employee training. It is the responsibi lity of the applicable Managers and/or Team Leaders in consultation with those leading the PSM/RMP efforts to determine the appropriate mix of employees and the degree of participation in development and implementation of specific elements of PSM/RMP. Participation is based on the knowledge and skill levels required in conjunction with employee availability. Individual employees are responsible for their own degree of participation beyond that which is assigned to them and beyond that necessary for them to safely conduct their job assignments. Other Forums Employee participation is encouraged in other forums both formal and informal. PSM/RMP is discussed in various staff meetings and team meetings. This includes the participants in Total Quality. Considerable informal participation takes place as part of the normal conduct of employees in their job functions. This process includes procedure writing and review, HAZOP participation, issuance of Hot Work Permits, developme nt of Process Safety Information, and training just to name a few. 2.6 Process Safety Information BP Chemicals has a compilation of process safety information (PSI). The PSI is available for conducting process hazards analyses. The PSI includes: MSDS information pertaining to the hazards of the chemicals used or produced by the processes Information on the process technology including block flow diagrams or simplified process flow diagrams, process chemistry, maximum intended inventory, safe upper and lower limits and other information included in operating manuals and SOP's. Information on the equipment used including P&ID's, electrical classification, relief system design and design basis, ventilation systems, safety systems, material and energy balances for new processes and equipment P.R. file information. Employees participate in the compilation of PSI to the extent required as determined by management and those leading the compilation efforts. Controlled copies of the PSI documents are kept in the department responsible for them. The PSI are kept current and up to date through application of BP Chemicals Green Lake Management of Change Procedure. Management of Change also involves a technical review which ensures and documents that changes in equipment comply with recognized and generally accepted good engineering practices. It is the policy of BP Chemicals that all applicable equipment is designed, maintained, inspected, tested and operated in a safe manner. It is the responsibility of each Operations Engineer, Maintenance Team Leader or Planner, Control Systems Team Member, Project Management representative or any others who lead activities which involve PSI to ensure the applicable PSI is compiled and updated in accordance with OSHA PSM, the EPA RMP and the Management of Change Procedure. 2.7 Process Hazards Analysis BP Chemicals Green Lake performs process hazards analyses (PHA's) on existing process units and on new process un its as part of project safety reviews. The hazards analyses are updated at least every five years. The priority order for the initial hazards analyses are based on a documented rationale. The PHA's are carried out using acceptable methodology and address: The hazards of the process Previous incidents Engineering and administrative controls Consequences of failure of controls Facility siting Human factors Qualitative evaluation of possible safety and health effects The PHA's are performed by a team with expertise in engineering and process operations. The teams include at least one employee with experience and knowledge in the process as well as one person knowledgeable in the PHA methodology being used. All PHA recommendations are addressed and resolved with appropriate documentation in a timely manner. Planned actions are adequately managed with scheduled milestone completion times. PHA reports and documentation are retained for the life of the process. Th e Process Safety Management and the Risk Management Program Coordinator is assigned to provide leadership for ensuring that the process hazards analyses are in accordance with requirements. The Area Manager is also responsible to provide the resources to resolve PHA recommendations, to complete recommended actions as needed and to communicate the actions to employees whose work may be affected by the recommendations or actions. 2.8 Operating Procedures BP Chemicals Green Lake maintains controlled written operating procedures that provide clear instructions for safely conducting process activities. The operating procedure system consists of Operating Manuals and SOP's. Included in the operating procedures are: Steps for each operating phase including start-up procedures, routine/normal operations, batch/temporary procedures, shutdown procedures and emergency procedures. Operating limits including risks and safeguards. Safety and health considerations. Safety systems a nd their functions. The operating procedures are readily accessible to employees on the process units. The procedures are reviewed as often as necessary to ensure they reflect current operating practice. Procedures are routinely reviewed for content at least every 3 years depending on the criticality of the procedure as determined by the area managers or their designee. Procedures are also modified and updated as needed as part of management of change. Each Area Manager certifies annually that the operating procedures are current and accurate for process units within his/her area of responsibility. BP Chemicals Green Lake maintains safe work practices in the Standing Orders for Safe Operation Manual (SOSO). The Area Manager is responsible for maintaining operating procedures for his/her department. The HSE Manager is assigned to maintain written safe work practices site wide. The Area Managers are responsible to ensure employees and contractors apply safe work practices in their departments. 2.9 Training Employees involved in operating a process receive both safety training and process unit specific training. Safety training includes safety and health hazards and safe work practices. Unit specific training includes process specific training including operating procedures and emergency operations. In accordance with the OSHA PSM regulation and the EPA RMP, applicable employees involved in operating a process on May 26, 1992 were certified to have the required knowledge skills and abilities to safely carry-out the duties and responsibilities of their position assignments. Refresher training is conducted at least every three years. The means used to verify that the employee understands the training consists of a written test and/or a field test. After satisfactorily completing the tests, a qualifications form is signed to complete the training documentation. The HSE department is responsible for the content of plant wide safety training . The manufacturing departments are responsible for unit specific training content. The Area Managers ensure employees within their areas of responsibility receive the training and qualification required for the employee's position assignments. 2.10 Contractors When selecting a contractor BP Chemicals Green Lake evaluates information regarding the contractor employees' safety performance and programs. Contractor safety is evaluated as part of the contractor bid review process as well as by the Green Lake Sr. Loss Prevention Supervisor. Each contract employee undergoes training which covers hazards, emergency action and safe work practices. The HSE department is responsible for the content of this training. It is the responsibility of the each BP Coordinator, or other individual assigned to supervise contract work to ensure contract employees receive the training. BP Chemicals Green Lake periodically evaluates contractor safety performance and maintains contract employe e injury and illness log. The Safety Department maintains this information. The PSM contract employer responsibilities are written into all new contracts between BP Chemicals Green Lake and contractors. The Purchasing Manager is responsible for new contracts. 2.11 Pre-startup Safety Review BP Chemicals Green Lake performs pre-startup safety reviews for both new and modified facilities. For large projects involving new facilities the BP Chemicals HSE-8 Procedure is utilized. For small projects involving modifications to existing facilities the management of change procedure covers pre-startup safety review issues. It is the responsibility of those employees leading the change for small projects and the project manager for large projects, to ensure pre startup safety reviews are conducted for new or modified facilities. 2.12 Mechanical Integrity BP Chemicals Green Lake has programs to maintain the ongoing mechanical integrity of process equipment. The programs include wr itten procedures, training, inspection and testing, correction of equipment deficiencies and quality assurance. Written Procedures Written procedures which provide guidelines for the mechanical integrity program include the following: Plant Maintenance/Mechanical Integrity Guidelines CP 52, "Inspection and Testing of Plant in Service, Part 1 - Principles" Selected, applicable API Standards (e.g. API 510 - Pressure Vessel) National Board Inspection Code State requirements BP Chemicals Engineering Specifications SOSO Manual The Chief Inspector is assigned to write and maintain the plant inspection procedures. The plant inspection procedures include procedures to maintain the on-going integrity of pressure vessels, storage tanks, piping systems, and relief and vent systems/devices. The Maintenance Specialists are assigned to write and maintain plant maintenance guidelines. The plant maintenance procedures include procedures to maintain the on-going integrity of pumps and rotating equipment, controls and emergency shutdown control systems. Assistance in the controls and shutdown systems procedures is provided by the Control Systems Engineer. Assistance for the pumps and rotating equipment procedures is provided by the Rotating Equipment Specialist. The plant safe practices in the SOSO Manual are maintained by the HSE Manager. These procedures include safe practices to maintain process equipment integrity such as lock out/tag out, confined space entry, hot work permit and control over entrance into a process facility. Blank lists are maintained by the production department. These are equipment specific applications of the safe practices which allow safe maintenance, testing and inspection of process equipment. Training Employees involved in maintaining the mechanical integrity of process equipment receive training in an overview of process hazards and in job specific tasks to assure they can perform their position assignment s in a safe manner. Inspection and Testing Inspections and tests are performed on in service process equipment in accordance with National and Industry codes in conjunction with the requirements of CP52 Part 1 - "Principles", as well as with generally accepted good engineering practices. The inspection authority ensures inspection and testing procedures are written, maintained and followed as needed to maintain process equipment mechanical integrity. As indicated in CP52, the inspection authority determines the frequencies of inspections and tests in conjunction with applicable procedures, manufacturers recommendations, good engineering practice and in consultation with the applicable Area Manager and his/her designees. The inspection and testing frequencies are adjusted as needed based on documented criteria such as prior operating experience. The inspection authority assures appropriate documentation is maintained on each inspection and test performed. The inspection authority also ensures adequate notice is given when equipment items are due for inspection. The Distribution & Plant Services Manager or his/her designee is responsible to schedule and prepare equipment for inspection and testing in order to meet requirements. The Chief Inspector is the assigned inspection authority for pressure vessels, storage tanks, piping systems, relief and vent systems, and other applicable static mechanical equipment. The Control Systems Operations Engineers reporting to the Engineering Manager are assigned the inspection authority for controls and emergency shutdown systems. The Rotating Equipment Specialist reporting to the Distribution and Plant Services Manager is the inspection authority for pumps and rotating equipment. Equipment Deficiencies Equipment deficiencies are corrected before further use or in a safe and timely manner when necessary means are taken to assure safe operation. The inspection authority communicates the equipment deficie ncy and recommendations to the Area Manager or his designee who is in turn responsible to correct the deficiency or take other measures to assure safe operations. Quality Assurance During construction of new plants and modifications to existing facilities, quality is assured by appropriate design specifications as well as checks and inspections. Each BP Representative assigned to lead construction and maintenance activities follows the BP Chemicals Engineering Specifications as well as other good engineering practices. When a deviation in specifications is required, the deviation is reviewed through the Management of Change process to assure safety is not compromised. Appropriate checks and inspections are performed by the inspection authority in conjunction with those leading the construction and maintenance activity to assure equipment is installed properly and consistent with design specifications. The checks and inspections include construction and maintenance field w ork, materials, equipment fabrication and spare parts. 2.13 Hot Work Permit BP Chemicals Green Lake maintains a Hot Work Permit Procedure as well as other safe practice procedures. The Hot Work Permit procedure (I-D-05.00) requires a permit to be issued for all work in the plant that could have the potential to provide a source of ignition. The Hot Work Permit procedure and other safe practice procedures are maintained by the HSE Manager. 2.14 Management of Change BP Chemicals Green Lake has established and implemented a Management of Change Procedure. It ensures all changes except for replacement in kind are reviewed and managed such that health, safety, environmental and quality are not compromised. In addition to required reviews and authorizations, the procedure addresses training, up date of process safety information and operating procedures. The management of change procedure is directly linked to the maintenance job order system to assure it is applied to all maintenance work. Changes in equipment and procedures not covered by a job order are also covered by management of change. The Management of Change (MOC) Procedure is maintained by the MOC Coordinator reporting to the Engineering Manager. It is the responsibility of all those employees leading applicable changes to follow the Management of Change Procedure. 2.15 Incident Investigation / Accident Release History All accidents, unsafe conditions and near misses are investigated. Incident investigations are initiated as promptly as possible, but not later than 48 hours following the incident. In all cases involving a disabling injury, or an incident resulting in a catastrophic release, a Committee Investigation is conducted. The committee consists of at least one person knowledgeable in the process involved, including a contract employee if the incident involves contractor work, and other persons with appropriate knowledge and experience to investigate and analyze the inc ident. Committee investigation are also done on high potential near misses. Incident investigations follow the "Reporting/Investigating Accidents/Incidents" procedure. Incident reporting is completed through the computer based reporting system. The procedures assure recommendations are adequately followed up with remedial action and communications to affected personnel as needed. Reports are retained for a minimum of five years. We have had no accidental releases of a regulated substance in the past five years which resulted in deaths, injuries, or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 2.16 Emergency Planning and Response In accordance with Sections 68.90 and 68.95 of the RMP rule, the HSE Manager is responsible for (1) designing, implementing, and maintaining the facility's emergency response plan, (2) ensuring that all associated training is conducted and do cumented as necessary, (3) coordinating the site emergency response plan with the community emergency response plan, and (4) responding to local emergency planners/responders when questions arise. The Emergency Operating Procedures are designed to minimize an employee's exposure to a hazardous chemical release, protect the environment and surrounding community, contain and/or neutralize a spill or release, and have consistent standards applied during a release within the plant boundary. The emergency operating procedures are updated and tested on an annual basis to ensure the plan stays current and will accomplish all of the desired results. In an effort to pre plan for emergencies the emergency operating procedures manual presents information on how to organize and respond to spills, rescues, fires and other plant emergencies such as natural disasters and criminal events. It also outlines both corporate and regulatory release reporting requirements. The emergency operatin g procedures manual does not provide detailed, step-by-step instructions on how to respond to an emergency. Because it is impossible to anticipate the precise way in which a problem may occur, any set of detailed, pre-arranged instructions would probably not fit the circumstances when the time came for implementation. Unit operators have detailed training and experience to help determine the specific type of operational change that may be required in the event of an emergency. In summary, the purpose of this emergency operating procedures manual is to help responders make informed decisions. The success of every emergency response depends on the good judgment of those at the scene. The site has a trained Emergency Response Team consisting of approximately 100 employees. The team trains on a quarterly basis with emergency response drills and scheduled training days. The facility has trained emergency Offsite responders and is a participating member of Chemnet. This team re sponds to chemical spills in the plants geographic area. The overall emergency response program for the Green Lake plant is coordinated with the Calhoun County 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 Green Lake plant 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 Green Lake plant conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the plant provides training to local emergency responders regarding the hazards of regulated substances in the plant. 2.17 Compliance Audits PSM/RMP compl iance audits are conducted at least every three years to verify that the PSM/RMP procedures and practices are adequate and are being followed. The compliance audits are conducted by at least one person knowledgeable in the process. Compliance audit reports are prepared. Responses to the audits are managed, and deficiency corrections are documented. The two most recent audit reports are retained. The Process Safety Management and the Risk Management Program Coordinator is assigned to ensure PSM Compliance Audits are conducted in accordance with requirements. 3.0 CHEMICAL SPECIFIC PREVENTION STEPS The process at the Green Lake plant has hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to the EPA RMP covered process at the Green Lake plant. The prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. In addition to the accident prevention program activities, the Green Lake plant has safety features on all units to help (1) contain/control a release, (2) quickly detect 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. Detectors with alarm. Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases. 2. Scrubber to neutralize chemical releases. 3. Valves to permit isolation of the process (manual or automated). 4. Automated shutdown systems for specific process parameters (i.e. high level, high temperature) 5. Vessel to permit partial removal of the process inventory in the event of a release (i.e. dump tank) 6. Curbing or diking to contain liquid releases 7. Redundant equipment and instrumentation (i.e. uninterruptible power supply for process control system, backup firewater pump) 8. Atmospheric relief devices Release Mitigation 1. Fire suppression and extinguishing systems 2. Deluge systems for specific equipment 3. Trained emergency response personnel 4. Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 5. Mobile fire fighting equipment 6. Blast-resistant buildings to help protect control systems and personnel 4.0 RMPlan Communication The PSM/RMP Coordinator has the responsibility of providing RMPlan information (other than the required EPA submission) to employees and the public as required under Section 68.210 of the RMP rule. These communications have been coordinated with local community cooperation and have been communicated in open forums in October of 1995 and again in May of 1999. 5.0 Planned changes to Improve Safety BP Chemicals has lowered the amount of Formaldehyde stored at the facility. |