BP Amoco Chemical Cedar Bayou Plant - Executive Summary
Risk Management Plan |
BP Amoco Cedar Bayou Plant
BP Amoco has a strong corporate commitment to health, safety, and environmental performance. Our goals are to have no accidents, no harm to people, and no damage to the environment. It is our commitment to provide a working environment that is safe by identifying hazards; designing and constructing our facilities according to recognized standards, procedures, and management systems; operating and maintaining facilities within the current design envelope; carefully selecting and training our workforce; managing changes to the organization, personnel, systems, procedures, and equipment; and maintaining emergency management plans to identify equipment, training, and personnel necessary to protect the workforce, public, and environment in the event of an incident.
Description of facility/Regulated substances handled
The BP Amoco Cedar Bayou Plant manufactures polypropylene plastic. The facility handles no tox
ic substances over the threshold quantity. Flammable substances held over the threshold quantity are propylene, propane and hydrogen. These are present in the plant both in pure form and in mixtures. They are transported into the plant via pipeline, thus there is no large volume of flammable mixtures being stored at the site.
The Cedar Bayou Plant operates 24 hours a day, 365 days a year. The facility has management representation 24 hours a day through the use of a shift foreman. In section 1.8, we have listed Edwin Morrow as the emergency contact. Mr. Morrow is one of four shift foreman. The phone number for the emergency contact is the shift foreman's office number.
The worst-case scenario is the release of propylene from a processing vessel, with an explosion in the resulting vapor cloud. This release was analyzed using the EPA Off-site Consequence Analysis guidance document. The area of impact for serious injury (i.e., 1.0 psi overpressure) includes o
ff-site receptors. It is unlikely for such an extreme vessel failure to take place; the plant has a comprehensive inspection and maintenance program to prevent such an incident. Further, measures are taken to limit the possibility that any release might reach a source of ignition.
The alternative release scenario is the release of propylene from a hole in an incoming line containing liquefied propylene under pressure. It is expected that this type of leak may be stopped within ten minutes due to monitoring of operations by detection equipment and our personnel. This release was analyzed using our own modeling. Some of the material from this release will disperse away from the release point before ignition can occur. The area of impact for serious injury (i.e., 1.0 psi overpressure) includes off-site receptors.
Through the East Harris County Manufacturers Association (EHCMA), both release scenarios were reviewed and validated. In addition, both scenarios were communicated to t
he LEPC and the local community in Baytown as part of a joint industry effort lead by EHCMA.
The most effective part of preventing off-site impacts from hazardous chemicals is to reduce the amount of those chemicals stored at the site, or eliminate them altogether. The plant has eliminated the use of some regulated toxic materials, including chlorine and titanium tetrachloride. We have also reduced the potential for releases of hydrogen by importing it by pipeline, thus reducing the volume that is stored on site.
The facility is subject to the Program 3 prevention requirements of the EPA RMP rule, and to the OSHA PSM rule upon which those requirements were based. The facility reduces the possibility of a fuel through several mechanisms. Process hazard analyses (PHAs) are done on a routine schedule for the process, and any change to the process undergoes PHA before it is operated. The plant has an ongoing inspection program according to American Petroleum Insti
tute (API) standards. Training programs and operating and maintenance procedures are also routinely reviewed. Operators are trained and certified initially and on a three year interval. The facility has strict policies on controlling hazardous energy during maintenance activities. In the event of an upset, the facility has numerous control systems to prevent an emergency such as a relief system which sends vapors to a flare for safe burning. For work that is performed by a contractor, procedures are in place to evaluate the contractor prior to work and to evaluate the contractors performance on an on-going basis. The plant reduces the possibility that a source of ignition might be present by maintaining hot work procedures and through proper classification of electrical equipment.
Five-year accident history
The plant has had no releases in the past five years that impacts, or had a potential to impact, any off-site receptor. There have been no releases that resulted in an on
-site fatality, injury, or significant property damage.
The Cedar Bayou plant encourages employees to participate in all 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 plant prevention program. Specific ways that employees can be involved in the prevention program are documented in the employee participation plan that addresses each prevention program element. In addition, the plant has a number of processes and teams that address and promote process safety and personal safety issues. The teams typically have members from various areas of the plant, including operation, maintenance, engineering, and plant management.
Process Safety Information
The Cedar Bayou plant keeps a variety of technical documents that are use
d 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. The facility has documentation available showing the location of this information to help employees, contractors 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. For process areas, the plant has documented safety-related limits for specific process parameters (i.e. temperature, level, composition). The plant assures that the process is maintained within these limits using process controls and mo
nitoring instruments, highly trained personnel, and protective instrument systems (i.e. automated shutdown systems). In addition, information is available summarizing the consequences of deviation from these limits and the corrective actions to take.
The plant 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 Cedar Bayou plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled
. Within this program, each part of the process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.
The Cedar Bayou plant 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 doc
umented and retained.
To help ensure that the process controls and or process hazards do not eventually deviate significantly from the original design safety features, the Cedar Bayou plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years as long as the process exists. In addition, a PHA is done for even small changes to the process. Only the section of the unit under going the change is studied in these cases. The recommendations from these updates are also forwarded to management. Final resolution of the recommendations is tracked, documented, and retained.
The Cedar Bayou plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures are developed/revised by experienced op
erators, supervisors and engineers 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.
Also safe operating limits are maintained to provide guidance on how to respond to upper or lower exceedences for specific process or equipment parameters. This information, along with the written operating procedures, is readily available to the process operators and other personnel to use as necessary to safely perform their job tasks.
The Cedar Bayou plant 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 procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous material
s 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 operations and maintenance activities are performed safely.
To complement the written procedures for process operations, the Cedar Bayou plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in chemical plant 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.) having 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 trai
ning 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.
The Cedar Bayou plant uses contractors to supplement its work force during periods of increased maintenance or construction 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 a
nd health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to work starting. In addition, the Cedar Bayou plant evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-Startup Safety Reviews (PSSRs)
The Cedar Bayou plant 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.
The Cedar Bayou plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures 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.
Another integral part of the mechanical integrity program is quality assurance. The Cedar Bayou plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.
Hot Work Permit
The Cedar Ba
you plant has a hot work permit program which details those area 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 Cedar Bayou plant 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 on the change. The system ensures that all documentation is updated and training completed prior to the commissioning of the change.
The Cedar Bayou plant promptly investigates all incidents that resulted in, or reasonably could have resulted in a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts, identify the root cause and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurr
ence, and forwards these results to 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 (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.
To help ensure that the accident prevention program is functioning properly, the Cedar Bayou plant 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. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to plant ma
nagement 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.
Our facility has its own volunteer fire brigade to respond to emergencies. Personnel receive training in responding to industrial fires. The facility periodically conducts drills of our emergency response system. We coordinate with two mutual aid groups in our area, the Mutual Aid of Mont Belvieu (MAMB) and the Channel Industries Mutual Aid (CIMA). The city of Baytown has a public notification system consisting of alarms, sirens and a emergency phone number that the public can call for information. Emergency response is also coordinated with the LEPC.
Planned changes to improve safety
No large mitigation or control equipment is planned for installation at this time. Improvement in safety
will continue to come from our hazard identification system (PHAs) and our personnel training.