BP Amoco Naperville Complex - Executive Summary |
|
BP Amoco Naperville Complex, Illinois EPA Risk Management Plan - Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The BP Amoco Naperville Complex facility 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 facility 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 reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the incident. DESCRIPTION AND REGULATED SUBSTANCES The BP Amoco Naperville Complex is located at 150 West Warrenville Road, Naperville, Illinois 60563. The facility is owned by BP Amoco C orporation. The primary purpose of the facility is to conduct both petroleum and chemical research and development. A secondary purpose is to provide office space for a other BP Amoco employees unrelated to the research and development activities. At present, the facility has only one process -- the 300 Tank Farm -- which is subject to the Clean Air Act Risk Management Planning requirements. This process contains three flammable regulated substances which are in excess of the threshold quantity as follows: isobutylene mixture, propylene and ethylene. Please note that the BP Amoco Naperville Complex has no regulated toxic substances in excess of the threshold quantity. HAZARD ASSESSMENTS Worst Case Scenario 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 isobutylene (60,000 pounds) from t he 300 Tank Farm 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 public receptors could be affected by this type of release. Specific information on this release is presented in more detail in this document. Alternative Release Scenarios The alternative release scenario for flammable substances at the facility is a VCE resulting from the release of propylene through a relief valve at the 300 Tank Farm. It is not anticipated that this release would travel beyond property boundaries. However, operators would still respond to the situation in a timely manner. Specific information on this release is presented in more detail in the plan. PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the BP Amo co Naperville Complex for all EPA RMP covered processes, presently only the 300 Tank Farm. Since this process is also regulated by the OSHA PSM standard, this summary is organized in the format of the OSHA PSM elements. Employee Participation The BP Amoco Naperville Complex encourages employees who work at the 300 Tank Farm to participate in multiple facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the facility prevention program. Specific ways that employees can be involved are documented in the employee participation plan. Process Safety Information The personnel at the 300 Tank Farm keep a variety of technical documents that are used to help maintain safe operation. These documents address chemical properties and associated hazards, limit s for key process parameters and specific chemical inventories, and equipment design basis/configuration information. The 300 Tank Farm has documentation available showing the location of this information to help employees and visitors locate any necessary 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 exposure concerns and any known hazards associated with the inadvertent mixing of chemicals. The 300 Tank Farm has documented safety-related limits for specific process parameters. The 300 Tank Farm personnel help assure that the process is maintained within these limits using process controls and monitoring instruments, trained personnel, and protective instrument systems. In addition, information is available summarizing the consequences of deviation from these limits and the corrective actions to take. The 300 Tank Farm also maintains 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 not compromised. Process Hazard Analysis The BP Amoco Naperville Complex has a program to help ensure that hazards associated with the various processes are identified and controlled. This process applies to the 300 Tank Farm. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage the se hazards. The BP Amoco Naperville Complex primarily uses the hazard and operability (HAZOP) analysis technique 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 and maintenance experience as well as engineering expertise. This 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 teams recommendations are forwarded to management for resolution. These recommendations are reviewed and all approved recommendations are tracked until they are completed. The final resolution of each recommendation is documented and retained. To help ensure that the process controls and or process hazards do not eventually deviate significantly from the or iginal design safety features, the BP Amoco Naperville Complex periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years as long as the process exists. The recommendations from these updates are also forwarded to management. Final resolution of the recommendations is tracked, documented, and retained. Operating Procedures The BP Amoco Naperville Complex maintains written procedures that address the operation of the 300 Tank Farm. These procedures are developed/revised by experienced operators as needed and provide a basis for consistent training of new operators. The procedures are periodically reviewed and annually certified as current and accurate. The procedures are revised as necessary to reflect changes made through the management of change process. The BP Amoco Naperville Complex has established safe work practices in place to help ensure worker and process safety. Examples of these include ( 1) control of site entry/presence/exit of support personnel, (2) a lockout 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, and (4) 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 affected personnel, form a system to help ensure that research and maintenance activities are performed safely. Training To complement the written procedures for process operations, the BP Amoco Naperville Complex has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in research and development operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After the new operator demonstrates (i.e. through tests, skills demonstration, etc.) adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators 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 conducted at least every three years. All of this training is documented, including the means used to verify that the operator understood the training. Contractors The BP Amoco Naperville Complex routinely uses contractors to supplement maintenance, construction and operation efforts. Because some contractors work on or near process equipment, the facility has procedures in place to help 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 emer gency, (5) understand and follow site safety rules, and (6) inform facility 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. In addition, the BP Amoco Naperville Complex evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-Startup Safety Reviews (PSSRs) The BP Amoco Naperville Complex conducts a PSSR for any 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 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 a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The BP Amoco Naperville Complex has practices and procedures to maintain pressure vessels, piping ystems, 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 and plans, (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 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 (i.e. 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. Hot Work Permit The BP Amoco Naperville Complex has a hot work permit program whic h details those 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. 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 BP Amoco Naperville Complex has a system to manage changes to the 300 Tank Farm. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other 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 and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. The system helps to ensure that all documentation is updated and training completed prior to the commissioning of the change. Incident Investigation The BP Amoco Naperville Complex 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 management for resolution. Corrective actions taken in response to th e 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 (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 accident prevention program is functioning properly at the 300 Tank Farm, the BP Amoco Naperville Complex periodically conducts an audit. Compliance audits are conducted at least every 3 years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to 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 along with the resolution of findings are retained. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the BP Amoco Naperville Complex have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA RMP covered processes at the BP Amoco Naperville Complex, currently only the 300 Tank Farm. Collectively, these 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 BP Amoco Naperville Complex has process safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safety features are used in the 300 Tank Farm. Release Detection 1. Hydrocarbon detectors with alarm. Release Containment/Control 1. Valves to per mit isolation of the process (manual or automated). 2. Curbing or diking to contain liquid releases 3. Redundant equipment and instrumentation (i.e. uninterruptible power supply for process control system, backup firewater pump) 4. 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) EMERGENCY RESPONSE PROGRAM INFORMATION The BP Amoco Naperville Complex maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program includes 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 BP Amoco Naperville Complex 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 as necessary to perform their specific emergency response duties. The emergency response program is updated as necessary. The overall emergency response program for the BP Amoco Naperville Complex is coordinated with the Naperville Fire Department. This coordination includes periodic training and exercises with local emergency response officials. The BP Amoco Naperville Complex has around-the-clock communications capability with the Naperville Fire Department. This provides a mean s of notifying the public of an incident. PLANNED CHANGES TO IMPROVE SAFETY The BP Amoco Naperville Complex is committed to the safety of its employees and the surrounding community. In particular, the safe operation of the 300 Tank Farm is enhanced through continuous improvement. For example, through internal audits and employee participation, safety items are regularly identified, evaluated and implemented as appropriate. At the time of this writing, the 300 Tank Farm is in the process of implementing safety items identified during the last PSM audit. |