Exxon Company USA - Baton Rouge Refinery - Executive Summary

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            Risk Management Plan: Executive Summary 
                         Page 10 of 10 
2638 LDEQ Facility ID Number 
The Exxon Baton Rouge Refinery has a long-standing commitment to 
worker and public safety and protecting the environment.  This 
commitment is demonstrated by the resources invested in accident 
prevention, such as personnel training and safety in the design, 
installation, operation, and maintenance of our processes.  Our 
objective is to implement reasonable controls to prevent 
foreseeable releases of regulated substances.  However, if a 
release does occur, our trained personnel will respond to 
control, contain and mitigate the release. 
Exxon modified its safety programs in 1991 by adopting a 
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 meets the requirements of ISO 14001. 
After an extensive review which included a number of facility 
audits, it concluded that the "environmental components of OIMS 
are consistent with the intent and meet the requirements of the 
ISO 14001 Environmental Management Systems Standard."  It 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 
The Exxon Baton Rouge Refinery, located in Baton Rouge, 
Louisiana, U.S.A., operates a variety of processes to produce 
petroleum products (e.g., propane, butane, gasoline products, jet 
fuels, diesel fuels and coke) from raw crude oil.  The refinery 
has several regulate 
d flammables, such as propane, butane, etc. 
In addition, the refinery uses and/or processes hydrogen sulfide, 
which is also a regulated substance.  Hydrogen sulfide is below 
the regulated threshold quantity to be addressed in the Federal 
Risk Management Plan but is still covered by the accidental 
release prevention and the emergency response programs.  The 
Refinery contains a total of 17 covered processes for the 
purposes of this plan. 
Hazard assessments were done using the EPA supplied "look up 
tables" which have been incorporated into the computer program 
supplied by ABS Group Inc.  This program uses all the parameters 
required by the RMP rule for both worst case (WCS) and alternate 
release (ARS) scenarios. 
The WCS associated with a release of flammable substances in 
Program 3 processes at the refinery is a vapor cloud explosion 
(VCE) involving the full inventory of the largest storage tank 
containing butane.  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, no credit for passive mitigation 
measures was taken into account in evaluating this WCS. This WCS 
has an off-site impact. 
The ARS for flammable substances at the refinery is a gasket leak 
at the gasoline blending facility of Butane followed by a VCE. 
This ARS has an off-site impact. 
The following is a summary of the general accident prevention 
program in place at the Exxon Baton Rouge Refinery.  EPA's 
Program 3 prevention requirements were implemented because some 
processes at the refinery meet Program 3 criteria and are also 
subject to the OSHA Process Safety Management (PSM) standard.  In 
addition, Exxon Corporation has implemented Operations Integrity 
Management Systems (OIMS) at each of its operations worldwide 
that includes the aspects o 
f EPA's prevention program. 
Because the refinery is focused on fuels production, most of the 
light hydrocarbons are mixed without regard to the purity of the 
components.  Isomers and olefins of propane and butane origin are 
mixed without regard to the specific components, because they all 
behave similarly in their use as fuel.  Where we had specific gas 
chromatograph information on the species of the hydrocarbon 
compounds, these have been marked in the inventory.  If these 
data were not readily available, only the normal paraffinic 
component (propane, butane) is listed.  In all cases, the normal 
paraffinic component is heavier and has a higher energy value 
than the olefins or isomers. 
Additional details are included in the Data Element section of 
the RMPlan.  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 April 30, 1999 as t 
he date to begin collecting this 
information.  Consequently, most of the reviews/updates conducted 
after that date are not reflected in the Data Element 
Employee Participation 
The Exxon Baton Rouge Refinery encourages employees to 
participate in all facets of process safety management and 
accident prevention.  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 all information created as part 
of the refinery accident prevention program.  Specific ways that 
employees can be involved in the accident prevention program are 
documented in an employee participation plan that is maintained 
at the refinery and addresses each accident prevention program 
element.  In addition, the refinery has a number of initiatives 
under way that address process safety and employee safety issues. 
These initiatives include formi 
ng teams to promote both process 
and personal safety.  The teams typically have members from 
various areas of the plant, including operations, maintenance, 
engineering, and plant management. 
Process Safety Information 
The Exxon Baton Rouge Refinery keeps a variety of technical 
documents that are used to help maintain safe operation of the 
processes.  These documents address chemical properties and 
associated hazards, limits for key process parameters and 
specific chemical inventories, and equipment design 
basis/configuration information.  Specific groups within the 
refinery are assigned responsibility for maintaining up-to-date 
process safety information.  A table summarizing the reference 
documents and their location is readily available as part of the 
OIMS documentation to help employees locate any necessary process 
safety information. 
Chemical-specific information, including exposure hazards and 
emergency response/exposure treatment considerations, is provid 
in material safety data sheets (MSDS).  This information is 
supplemented by documents that specifically address known 
corrosion concerns and any known hazards associated with the 
inadvertent mixing of chemicals.  For specific process areas, the 
refinery has identified Operating Envelopes; i.e. documented 
safety-related limits for specific process parameters such as 
temperature, level, and compositions.  The refinery ensures that 
the process is maintained within these limits using computerized 
process controls and monitoring instruments, highly trained 
personnel, and protective instrument systems (e.g., automated 
shutdown systems, alarm systems). 
The refinery 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 
res 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 Baton Rouge Refinery has a comprehensive program to 
help ensure that hazards associated with the various processes 
are identified and controlled.  Within this program, each process 
is systematically examined to identify hazards and ensure that 
adequate controls are in place to manage these hazards. 
The Exxon Baton Rouge Refinery 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.  This 
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 appropriate. 
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 Baton Rouge Refinery periodically updates and 
idates the hazard analysis results.  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 
retained. The team findings are forwarded to management for 
consideration, and resolution of the findings is documented and 
Operating Procedures and Safe Work Practices 
The Exxon Baton Rouge Refinery 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 maintained 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 refinery 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. 
The Exxon Baton Rouge Refinery has long-standing safe work 
practices in place to help ensure worker and process safety. 
Examples of these include (1) control of the entry/presence/exit 
of support personnel, (2) a lockout/tagout procedure to ensure 
isolation of energy sources for equipment undergoing maintenance, 
(3) a procedure for safe removal of hazardous materials before 
process piping or equipment is opened, (4) a permit and procedure 
to control spark-producing activities (i.e., hot work), and (5) a 
permit and procedure to ensure that adequate precautions are in 
place before entry into a confined space.  These procedures (and 
others), along with training of affecte 
d personnel, form a system 
to ensure that operations and maintenance activities are 
performed safely. 
To complement the written procedures for process operations, the 
Exxon Baton Rouge Refinery has implemented a comprehensive 
training program for all employees involved in operating a 
process.  New employees receive basic training in refinery 
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 personnel 
periodically receive refresher training on the operating 
procedures to ensure that their skills and knowledge are 
maintained at an acceptable level.  This refresher training is 
ed at least every 3 years.  All of this training is 
documented for each operator, including the means used to verify 
that the operator understood the training. 
The Exxon Baton Rouge Refinery uses contractors to supplement its 
workforce during periods of increased maintenance or construction 
activities.  Because some contractors work on or near process 
equipment, the refinery has procedures in place to ensure that 
contractors (1) perform their work in a safe manner, (2) have the 
appropriate knowledge and skills, (3) are aware of the hazards in 
their workplace, (4) understand what they should do in the event 
of an emergency, (5) understand and follow site safety rules, and 
(6) inform refinery personnel of any hazards that they find 
during their work.  This is accomplished by providing contractors 
with (1) a process overview, (2) information about safety and 
health hazards, (3) emergency response plan requirements, and (4) 
safe work practices prior to the 
ir beginning work.  In addition, 
the Exxon Baton Rouge Refinery evaluates contractor safety 
programs and performance during the selection of a contractor. 
Refinery personnel periodically monitor contractor performance to 
ensure that contractors are fulfilling their safety obligations. 
Pre-startup Safety Reviews (PSSRs) 
The Exxon Baton Rouge Refinery 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 
that safety features, procedures, personnel, and the equipment 
are appropriately prepared for startup prior to placing the 
equipment into service.  This review provides one additional 
check to make sure construction is in accordance with the design 
specifications and that all supporting systems are operationally 
ready.  The PSSR review team uses checklists to verify all 
aspects of readiness.  A PSSR involv 
es field verification of the 
construction and serves as a quality assurance function by 
requiring verification that accident prevention program 
requirements are properly implemented. 
Mechanical Integrity 
The Exxon Baton Rouge Refinery 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) 
icable safe work practices to help ensure that they can 
perform their job in a safe manner.  Written procedures help 
ensure that work is performed in a consistent manner and provide 
a basis for training.  Inspections and tests are performed to 
help ensure that equipment functions as intended, and to verify 
that equipment is within acceptable limits (e.g., adequate wall 
thickness for pressure vessels).  If a deficiency is identified, 
employees will correct the deficiency before placing the 
equipment back into service (if possible), or an MOC 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 Baton Rouge Refinery 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. 
Hot Work 
The Exxon Baton Rouge Refinery has a work permit system in place 
to protect personnel, site facilities, and the surrounding 
community.  The purpose of the work permit system is to ensure 
that jobs are planned, equipment is prepared, personnel are 
informed of hazards and procedures, precautions are taken, and 
work is executed in a manner to protect safety, health, and the 
environment.  The permit system covers hot work and other 
categories of work such as opening equipment, excavation, lifting 
and confined spaces. 
Management of Change 
The Exxon Baton Rouge Refinery has a comprehensive system to 
manage changes to processes.  This system requires that changes 
to items such as process equipment, chemicals, technology 
(including process operating conditions), procedures, and other 
facility changes be properly reviewed and authorized before being 
implemented.  Changes are reviewed to (1) ensure that adequate 
controls are in  
place to manage any new hazards and (2) verify 
that existing controls have not been compromised by the change. 
Affected chemical hazard information, process operating limits, 
and equipment information, as well as procedures are updated to 
incorporate these changes.  In addition, operating and 
maintenance personnel are provided any necessary training before 
the change is implemented. 
Incident Investigation 
The Exxon Baton Rouge Refinery promptly investigates all 
incidents that resulted in, or reasonably could have resulted in, 
a fire/explosion, toxic gas release, major property damage, 
environmental loss, or personal injury.  The goal of each 
investigation is to determine the facts and develop corrective 
actions to prevent a recurrence of the incident or a similar 
incident.  The investigation team documents its findings, 
develops recommendations to prevent a recurrence, and forwards 
these results to refinery management for resolution.  Corrective 
actions taken in  
response to the investigation team's findings 
and recommendations are tracked until they are complete.  The 
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 
Compliance Audits 
To help ensure that the accident prevention program is 
functioning properly, the Exxon Baton Rouge Refinery periodically 
conducts an audit to determine whether the procedures and 
practices required by the accident prevention program are being 
implemented.  Compliance audits are conducted at least every 3 
years.  The audit team develops findings that are forwarded to 
refinery management for resolution.  Corrective actions taken in 
response to the audit team's findings are tracked until they are 
complete.  The resolutio 
n of each finding is documented, and the 
two most recent audit reports are retained. 
The processes at the Exxon Baton Rouge Refinery have hazards that 
must be managed to ensure continued safe operation.  The accident 
prevention program summarized previously is applied to all 
covered processes at the Exxon Baton Rouge Refinery. 
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 Baton Rouge Refinery 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.   Hydrogen sulfide (H2S) detectors with alarms 
3.   TV survei 
llance cameras 
Release Containment/Control 
1.   Process relief valves that discharge to a flare to capture 
 and incinerate episodic releases 
2.   Valves to permit isolation of the process (manual or 
3.   Automated shutdown systems for specific process parameters 
 (e.g., high level, high temperature) 
4.   Curbing or diking to contain liquid releases 
5.   Redundant equipment and instrumentation (e.g., 
 uninterruptible power supply for process control system, backup 
 firewater pump) 
6.   Atmospheric relief devices 
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 
The Exxon Baton Rouge Refinery has an excellent record 
accident prevention over the life of the refinery.  There has 
been one accident during the past 5 years that is reportable 
under this regulation. 
The Exxon Baton Rouge Refinery 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 Baton Rouge Refinery has procedures 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 to perform their specific emergency response 
duties.  The emergency response program is updated based on 
modifications made to refinery processes or other refinery 
facilities.  The emergency response program changes are 
administered through the MOC process, which includes informing 
and/or training affected personnel in the changes. 
The overall emergency response program for the Exxon Baton Rouge 
Refinery is coordinated with the East Baton Rouge Parish 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 Exxon Baton Rouge Refinery has 
around-the-clock communications capability with appropriate LEPC 
officials and emergency response organiza 
tions (e.g., City of 
Baton Rouge Fire Department).  This provides a means of notifying 
the public of an incident as well as facilitating quick response 
to an incident.  In addition to periodic LEPC meetings, the Exxon 
Baton Rouge Refinery conducts periodic emergency drills that 
involve the City of Baton Rouge Fire Department. 
Our Operations Integrity Management systems form the cornerstone 
for continuous improvement in our safety-related systems.  These 
systems are evergreen and are in a continuous state of 
improvement.  Some examples are the recommendations from our 
hazard reviews and any incident investigations.   Other planned 
changes to improve safety are: 
z    Improve Comprehensive Incident Investigation Procedures. 
z    Enhance Safety/Operation Integrity audit process. 
z    Improve process monitoring by upgrading the process alarm 
 system consistent with the latest Alarm Management Guidelines. 
z    Continue to train approp 
riate employees on Tap Root process 
 to improve incident investigations. 
The Exxon Baton Rouge Refinery currently has two air operating 
permits, one covering the Light Ends processes (permit #:  2589) 
and one covering the Catalytic Cracking processes (permit #: 
2385).  Five other air operating permits associated with covered 
processes have or will be requested in the future.
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