BP Amoco Chemical Company, Joliet Plant - Executive Summary |
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EXECUTIVE SUMMARY BP Amoco Chemical Company - Joliet Plant, Joliet, Illinois EPA Risk Management Plan (RMP) ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The BP Amoco Chemical Company, Joliet Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation and maintenance of our processes. Our plant adheres to process safety policies, guidelines, and best practices that have been developed based on company and industry experience over the years. Our policy is to implement the controls necessary to prevent releases of regulated substances to the environment. However, if a release does occur, our trained personnel will respond to control and contain the incident. DESCRIPTION AND REGULATED SUBSTANCES The Joliet Plant is located at 23425 Amoco Road in Joliet (Channahon Township), Illinois. The plant is owned by BP Amoco PLC. Various chemicals are processed to produce materials for polyester fibers, fiberglass gasoline tanks, paints, wire coatings, plastics, insecticides, and food additives. The only RMP-regulated substance at the plant in excess of the threshold quantity is butane, which is the primary material used in the Maleic Anhydride (MAN) production process. HAZARD ASSESSMENTS Worst Case Scenarios The worst case scenario (WCS) for flammable substances is a vapor cloud explosion (VCE) with an overpressure endpoint of 1 pound per square inch (psi). The WCS endpoint is based on the instantaneous release of the entire contents (2,635,000 pounds) from our butane sphere resulting in a VCE. The effects of administrative controls, mitigation systems, and safety systems are not included in determining the effects of a VCE. Distances to the endpoint were calculated using the methodology outlined in EPAs RMP Offsite Consequence Analysis Guidance. Nearby residences and business es could be affected by this type of release. Specific information on this release is presented in more detail in the plan. Alternative Release Scenarios The alternative release scenario for flammable substances at the plant is a VCE resulting from the release of butane from a pressure relief valve at the top of the butane sphere. The release is expected to be isolated by process operators within ten minutes. This release would not reach the plant fenceline. Specific information on this release is presented in more detail in the plan. FIVE-YEAR ACCIDENT HISTORY The Joliet Plant has an excellent record of accident prevention over the past five years. If an incident were to occur, it would be investigated very carefully to determine ways to prevent a recurrence or a similar incident from occurring. There have been no accidental releases of butane within the past five years. PREVENTION PROGRAM The following is a summary of the accident prevention efforts in place at the Joliet Plant. Because the MAN production process that is regulated by the EPA RMP regulation is also subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard, this summary also addresses the OSHA PSM elements and describes the management system in place to implement the prevention program. Employee Participation The Joliet Plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from compiling and updating technical information to participating as a member of a team that systematically analyzes new and and modified processes for hazards. Teams that represent a good cross-section of levels and areas of the plant are formed to revise and update safety standards and to investigate accidents and issue reports to all personnel. Safety focus teams in each area promote individual responsibility for safe work behaviors. Some individual emp loyees write operating procedures and Job Safety Analysis (JSA) plans; others serve as compliance auditors for the plant; and still others serve as members of the plants Fire and Emergency Response Team. Process Safety Information The Joliet Plant maintains documents describing all process safety information for the MAN process in the MAN unit control room. These documents describe chemical properties and associated hazards, limits for key process parameters, chemical inventories, and equipment design basis/configuration information. Chemical specific information, including exposure hazards and treatments, and emergency response considerations are provided in material safety data sheets which are also located the the control room. The process operators use modern instrumentation to assist them in controlling the process within the design ranges. 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 ratings of equipment, piping and instrument drawings, 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 properly maintained. Process Hazard Analysis The Joliet Plant has a structured program to help ensure that hazards associated with the RMP-regulated process is controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place. The Joliet Plant uses the Hazard and Operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized by OSHA as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of p eople who have operating and maintenance experience as well as engineering expertise. A HAZOP study of the entire process unit is completed every five years. The HAZOP teams recommendations for improvement are forwarded to management for resolution. All recommendations are tracked until they are complete. The final resolution of each recommendation is documented and retained. Operating Procedures The Joliet Plant maintains written procedures that address various modes of process operations, including such activities as unit startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and initial startup of a new process. These procedures are used as a reference by experienced process operators and provide a basis for consistent training of new process operators. All operating procedures are reviewed annually by each operator. The procedures are located in the unit control room for ready-reference by process operators. Training In addition to the wr itten operating procedures, operators receive two other elements of formal training. Basic operator training is available at the local junior college and consists of the essentials that process operators need to know about process equipment and controls, regardless of their work location. Basic operating training is completed before an operator starts the training specific to the process unit. Unit-specific training is self-paced and conducted in the unit with experienced process operators or foremen over a period of several months. An operator must become qualified on each section of the unit by demonstrating a hands-on mastery of every section task before operating that section independently. Contractors Contractors are utilized at the Joliet Plant for construction and maintance activities. Because some contractors work on or near process equipment, the 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 work starting. All contractors must complete the Three Rivers Manufacturing Council Safety Course for contractors before being allowed into the plant to work. They must recertify in this course annually. In addition, the Joliet Plant evaluates contractor safety programs and performance during the selection of the contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-Startup Safety Reviews (PSSRs) The Joliet Plant conducts a PSSR for an y new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, equipment, procedures, and personnel are properly prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention measures are properly implemented. Mechanical Integrity Well-established practices and procedures are in place to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in safe operating condition. The basic aspects of this program include: (1) conduc ting training, (2) developing written procedures and plans, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. The combination of these activities forms 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 ensure that they perform their job in a safe manner. Written procedures ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed on process equipment to ensure that equipment functions as intended, and to verify that equipment complies with design standards and specifications. Another integral part of the mechanical integrity program is quality assurance. The Joliet Plant incorporates quality assurance measur es 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 Joliet Plant has long-standing safe work practices in place to ensure worker and process safety. Detailed and rigorous safety standards control entry into work areas and confined spaces, specify procedures to follow for isolating energy sources by lockout/tagout, and describe permitting process for completing work in the plant. There are separate procedures specified for cleaning and isolating all major pieces of equipment. Safety standards and work procedures are reviewed annually by all personnel who use them. Hot Work Permit The Joliet Plant has a hot work permit program which details areas which require a permit and those areas for which a permit is not required. A permit is required in process areas for all cutting, welding, spark producing equipment, etc. except in designated free burn areas. The procedure includes accountability and responsibility for authorizing and issuing the hot work permit, display of the permit at the site of the hot work until the work is completed, site inspection, designation of appropriate precautions to be taken with the hot work, and assignment of a fire watch where appropriate. Management of Change The Joliet Plant has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, process operating conditions, and procedures be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and to verify that existing controls have not been compromised by the change. Chemical hazard information, process operating limits, equipment information, and procedures are all updated to incorporate these changes. In addition, all personnel involved in the proc ess are provided any necessary training on the change. This system ensures that all documentation is updated and training completed prior to the commissioning of the change. Incident Investigation The Joliet Plant promptly investigates incidents that resulted in, or reasonably could have resulted in a fire/explosion, toxic gas release, major property damage, environmental damage, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident. The investigation team documents its findings, develops recommendations 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 final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees and contractors who could be affected by the findings. Incident investigation reports are retained for at least 5 years, so that the reports can be reviewed during future HAZOP studies. Compliance Audits To help ensure that the Process Safety Management program is functioning properly, the Joliet Plant periodically conducts an audit. A complete audit of the entire PSM program is conducted every three years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the Joliet Plant have hazards that must be managed to ensure continued safe operation. The Process Safety Management Program summarized previously is applied to the MAN production process (the only EPA RMP-regulated process at the Joliet Plant). Collectively, these program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. In addition to PSM, the plant has instrumentation and equipment to detect, contain, and reduce the consequences of a release at and around the MAN production unit and butane sphere, including: Release Detection 7 Hydrocarbon detectors with alarms 7 Monitoring equipment to detect density, temperature, level, and pressure changes Release Containment/Control 7 Atmospheric relief devices 7 Valves to permit isolation of the process 7 Automated shutdown systems 7 Diking to contain liquid releases 7 Redundant equipment and instrumentation (i.e. uninterruptible power supply for the process control system) Release Mitigation 7 Fire suppression and extinguishing systems 7 Deluge system and snuffing steam 7 Trained emergency response personnel 7 Emergency response equipment located onsite EMER GENCY RESPONSE PROGRAM INFORMATION The Joliet 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 an RMP- regulated substance, including the possibility of a fire or explosion if a flammable substance is 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 plant has procedures in place that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific em ergency response duties. The emergency response program is updated when necessary based on modifications made to plant processes or emergency response procedures. The overall emergency response program for the Joliet Plant is coordinated with the Will 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 plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire departments, industrial neighbors, and mutual aid with industry). 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 plant conducts periodic emergency drills that involve the LEPC and local emergency response organizations. Additionally, the plant provide s occasional refresher training to local emergency responders. PLANNED CHANGES TO IMPROVE SAFETY The Joliet Plant resolves all findings from HAZOP studies, some of which result in modifications to the process. The following types of changes are being implemented: 7 Additional hydrocarbon release detectors/sensors. 7 Identification of liquid butane lines in diked area around NF-100 butane sphere. 7 Develop firm guidelines or procedures to control the amount and location of material storage and vehicle activity around the butane sphere. |