BP Amoco Stratton Ridge Facility - Executive Summary |
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Risk Management Plan BP Amoco Stratton Ridge Facility Executive Summary Policies 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 Stratton Ridge Facility is an underground salt dome storage facility support ing our Chocolate Bayou Plant location. It is operated as part of the Chocolate Bayou Plant, but it is a separate stationary source since the sites are approximately 15 miles apart. The facility stores flammable materials consisting of ethane, propane, ethylene, propylene, and butanes/butenes. These are present in the plant both in pure form and in mixtures. There is some above-ground processing of material, including drying and compression. The facility handles no toxic substances over the threshold quantity. The Stratton Ridge Facility operates 24 hours a day, 365 days a year. The facility has management representation 24 hours a day through the use of a shift foremen. In addition, emergency management is managed through the Shift Superintendent at Chocolate Bayou. In section 1.8, we have listed Bobby Monk as the emergency contact. Mr. Monk is one of four Chocolate Bayou shift superintendents. The phone number for the emergency contact is the shift superintendent's office number. Release scenarios The worst-case scenario is the release of the flammable material ethylene from a storage cavern, with an explosion in the resulting vapor cloud. Since this material is stored underground, the salt dome is considered passive mitigation for this release. The amount of material released was calculated as the amount that could flow from the cavern in 10 minutes. The effects of this release were analyzed using the EPA Off-site Consequence Analysis guidance document. The area of impact for serious injury (i.e., 1.0 psi overpressure) includes off-site receptors. It is unlikely for such an extreme failure to take place. 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 ethylene from a hole in a processing line containing liquefied ethylene under pressure. It is expected that this type of leak may be stopped within ten minutes due to monitoring of operati ons 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. Prevention Program 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 fire or explosion 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 Institute (API) standards. Automatic shutoff valves are used on the storage caverns, in accordance with the rules of the Railroad Commission of Texas. 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 relief valves which are sent to a flare. 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 resulted in an injury to personnel or significant property damage onsite, nor any off-site impacts. Employee Participation The Stratton Ridge Facility encourages employees to participate in all facets of process safety management and accident prevention. Examples of empl oyee 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 initiatives under way that address process safety and personal safety issues. These initiatives include forming 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 Stratton Ridge Facility 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. 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 monitoring 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 Stratton Ridge Facility 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 Stratton Ridge Facility 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 f rom the original design safety features, the Stratton Ridge Facility 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 Stratton Ridge Facility 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 operators, 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 thro ugh 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 Stratton Ridge Facility 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 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 operations and maintenance activities are performed safely Training To complement the written procedures for process operations, the Stratton Ridge Facility 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 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 tha t the operator understood the training. Contractors The Stratton Ridge Facility 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 and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to work starting. In addition, the Stratton Ridge Facility evaluates contractor safety programs and performance during the selection of a contractor. Pl ant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-Startup Safety Reviews (PSSRs) The Stratton Ridge Facility 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 Stratton Ridge Facility has well-establ ished 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 equip ment 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 Stratton Ridge Facility 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 Stratton Ridge Facility 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 producin g 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 Stratton Ridge Facility 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 wel l 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. Incident Investigation The Stratton Ridge Facility 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 recurrence, 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. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Stratton Ridge Facility 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 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 re cent audit reports along with the resolution of findings are retained. Emergency response The facility uses the volunteer fire brigade of our Chocolate Bayou Plant to respond to emergencies. Personnel receive training in responding to industrial fires. The facility periodically conducts drills of our emergency response system. 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. |