Phillips Chemical Co. -- Houston Chemical Complex - Executive Summary
PHILLIPS CHEMICAL COMPANY |
HOUSTON CHEMICAL COMPLEX
RISK MANAGEMENT PLAN
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Phillips Chemical Company Houston Chemical Complex (HCC) has a long-standing commitment to worker and public safety. HCC is focused on preventing serious process-related incidents that might affect plant personnel, visitors, the community or the environment. The HCC process safety management (PSM) program demonstrates this focused commitment. The HCC PSM program involves the application of management systems to control process hazards through programs, procedures, audits, evaluations, and training that considers safety in the design, installation, operation, and maintenance of our processes.
Although, the management systems for chemical process operations target continuous improvement in the storage, use, and manufacturing of regulated substances, our trained personnel will respond to control and contain a process-related incid
ent in the event one should occur. The knowledge that is gained from accident/incident reports, maintenance records, case histories, and trend analysis of incidents will provide basic information and changes that can be utilized to help further prevent catastrophic events.
DESCRIPTION OF STATIONARY SOURCES AND REGULATED SUBSTANCES
The Phillips Chemical Company Houston Chemical Complex (HCC) located in Pasadena, Texas operates several plastic resin manufacturing processes and one specialty chemical manufacturing process. The plastic resin manufacturing processes utilize various regulated flammable chemicals such as ethylene, propylene, 1,3-butadiene, isobutane, propane, and pentane to produce plastic resin. The specialty chemical manufacturing process utilizes the regulated flammable chemicals such as ethylene, 2-methylpropene and propane.
HAZARD ASSESSMENT RESULTS
The worst-case scenario (WCS), associated with a flammable substances at HCC, is an instantaneous loss of the conten
ts of the largest 1,3-butadiene storage vessel. This WCS assumes the entire inventory of the vessel is released, vaporizes and ignites, resulting in a vapor cloud explosion. Although there are several controls to prevent such a release and to manage the consequences (e.g. periodic inspections of storage vessels, remotely-activated valves used to isolate and limit the release, and the release detection system connected to a plant-wide Emergency Alarm System), no credit for mitigation was taken into account in evaluating the scenario. The maximum distance to the 1-psi endpoint for this WCS will result in off-site impacts of our industrial neighbors. EPA's OCA Guidance Reference Equations were used to determine if the WCS would result in an off-site impact (distance to 1-psi endpoint).
The alternative case scenario (ARS), associated with flammable substances, at HCC is the separation of a 3-inch unloading arm of an isobutane railcar during operation. The ARS assumes the active and p
assive safety systems are functional and the Emergency shutdown system isolates the release. The maximum distance to the 1-psi endpoint for this WCS will not result in an off-site impact. EPA's OCA Guidance Reference Equations were used to determine if the WCS would result in an off-site impact (distance to 1-psi endpoint).
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
The following is a summary of the general accident prevention programs in place at the Phillips Houston Chemical Complex. HCC is an OSHA PSM regulated facility. Therefore, the elements of the HCC PSM program / OSHA PSM standard, which essentially mirror the prevention program requirement of the EPA's RMP standard, have been in place since 1992.
The intent of employee participation is to ensure that HCC employees are informed, consulted and involved in all aspects of process safety management. Employees have access to all information developed to comply with the PSM standard in the HCC Cent
ral Office Building Library. Examples of employee participation range from reviewing process safety information and Standard Operating Procedures to serving on Process Hazard Analysis teams.
HCC also utilizes other processes such as company communication tools and the Employee Safety Process to keep employee participation evergreen and provide periodic reminders to the employees that their process safety concerns and suggestions are welcome.
Process Safety Information (PSI)
HCC compiles and maintains written process safety information to enable both the employer and employee the ability to effectively identify and understand the hazards posed by the process. Written PSI provides employees with a baseline of information to identify hazards of the chemicals used or produced in the process, information about the technology of the process, and information about the equipment in the process. This PSI provides the foundation for performing the unit Process Hazards Analysis, developi
ng operating procedures, and determining the applicability of management of change. The record copy of this formation is maintained in the HCC Central Office Building Library.
Process Hazard Analysis (PHA)
A process hazard analysis is a detailed and systematic evaluation of all aspects of the process (equipment, chemicals, technology, and procedures) to identify the potential hazards associated with the processing and handling of highly hazardous chemicals. PHAs are performed on existing and new units in all of HCC's nine covered processes. The Checklist and Hazard and Operability Study (HAZOP), or other appropriate equivalent methodologies, were used to perform the PHAs on each covered process at HCC. A PHA results in action items (findings/recommendations) that identify and address perceived potential hazards. The action items are prioritized for management and employee resolution utilizing the scheme below:
Priority 1 - Includes recommendations to ensure that a primary safeg
uard is provided and the likelihood of human error-related accidents is reduced.
Priority 2 - Includes recommendations related to providing a secondary level of safeguard or to minimize challenges to the primary safeguard.
Priority 3 - Includes general safety and operation improvement suggestions.
Written standard operating procedures (SOP) provide clear instructions for the safe operations and control of the process and associated equipment. SOP's are readily accessible to operations personnel in the control rooms and all other employees via the electronic delivery system, PRiSM. The SOP's address various phases of operation, such as initial startup, normal operations, temporary operations, emergency operations; emergency shutdown, normal shutdown, and subsequent startup. SOPs also address safety and health considerations and information on Safe Work Practices. Revisions to SOP's may be prompted as a result of management of change, process hazard an
alysis, and an annual review of SOP's.
HCC has implemented a comprehensive training program for all HCC employees especially those involved in operating a process. Operator Training has been developed to equip operators with the knowledge and skill necessary to safely and proficiently perform their job duties. This training emphasized specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. Written tests, oral tests, observation, or demonstration are utilized to verify the training.
Refresher training/certification is provided every three years to operations personnel on the operating units for which they are responsible. Training in safe work practices is given to all employees during new employee safety orientation, annual safety training, special classes and monthly safety meetings.
Contract employees at HCC provide labor for general maintenance or repairs, turnaroun
ds, major renovations, construction, demolition, equipment installation or specialty work on or adjacent to covered processes. Thus, their actions may have an influence on process safety. HCC informs contractors of known potentials fire, explosion or toxic release hazards related to the contractor's work and the process as well as the emergency action plan, safe work practices and sign-in/sign-out requirements for HCC during the Contractor Safety Orientation. The contractor employer is responsible for assuring that each contract employee is trained in the work practices necessary to safely perform his/her job. To verify that each employee has the job skills necessary to safely perform the assigned job, an Employee Training Observation Form must be completed by a representative of the contract employer prior to the employee performing work at HCC.
The intent of the mechanical integrity program is to provide a management system that ensures: (1) the equipmen
t is maintained in a manner to prevent or minimize the consequences of a catastrophic release of a highly hazardous chemical and (2) the equipment is maintained by trained and qualified personnel to assure its continued integrity. The Mechanical Integrity Covered Equipment (MICE) at HCC includes the following type of equipment, pressure vessels,
storage tanks, piping, valves, relief and vent systems, emergency shutdown systems, controls, and pumps. The basis aspects of the mechanical integrity system include: (1) design and construction requirements; (2) preventive maintenance practices; (3) testing and inspection; (4) repair, modification and alteration procedures; and (5) inspector and craftsman training and qualifications.
Safe Work Practices
HCC has several long-standing safe work practices that promote worker and process safety. Examples of these include (1) hot work permits to control work involving flame or spark-producing operations; (2) confined space entry permits to
ensure adequate safety precautions have been taken prior to entering vessels, tanks and other confined spaces; (3) lockout/tagout procedures to guarantee isolation of energy sources prior to working on equipment; and (4) pressure-relief device (PRD) removal procedures to insure adequate alternate relief paths are available prior to removal of any PRD. These procedures along with others form a system to help secure that operations and maintenance activities are performed in a safe manner.
Management of Change and Pre-Startup Safety Review
HCC has a comprehensive system to manage changes to processes. Changes may introduce new hazards or compromise safeguards incorporated in the original design of the process and must be reviewed prior to their implementation. This system requires that change to items such as process equipment, chemicals, technology (including process-operating conditions), software, procedures (including operating, maintenance, and safe work) and emergency proced
ures be properly reviewed and authorized using the MOC/PSR Certification form before being implemented. This system requires that any change executed address the following: the technical basis for the proposed change; the impact of the change on safety and health; modifications to operating procedures; necessary time period for change; and authorization requirements for the proposed change.
Affected process safety information (e.g. mechanical, electrical/instrument, chemical, and operating limits) and procedures (e.g. operating, maintenance, and safe work) are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.
HCC conducts a PSR (Pre-startup Safety Review) for any new facility or facility modification that requires a change in the process safety information. A PSR is conducted for the following types of change: equipment, facilities, and/or process chemicals, technology, and software. The PSR se
rves as a final check prior to the introduction of highly hazardous chemicals into the process at a new facility and conducted prior to start-up, commissioning, or engagement of the change, for existing, modified facilities. The PSR must confirm the following: a PHA has been performed for new facilities and that PHA recommendations have been resolved; MOC requirements have been executed for changes to modified facilities; construction and equipment installation is in accordance with design specifications; training of each employee involved in operating a process has been completed; and, safety, operating, maintenance, and emergency procedures are in place and are adequate.
HCC utilizes the Incident Investigation Procedure, Section M of the HCC Safety and Loss Control Manual to promptly investigate all incidents, including those, which resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical. An HCC Work Group In
vestigation is initiated, as required, within the same day and /or shift in which the incident occurred. All recommendations generated from an incident investigation are entered in a tracking system and tracked until resolution. All incident investigation reports are maintained for a minimum of five years so that they can be reviewed during future PHA revalidations and/or included in RMP updates.
HCC conducts compliance audits to periodically evaluate the effectiveness of the PSM Program at HCC; to ensure that each program element complies with the standard; and to ascertain whether the programs' internal procedures and practices are adequate and are being implemented. Compliance audits are conducted at least every three years. The audit team is comprised of a variety of multi-disciplined employees who utilize a set of self-audit checklists based on the OSHA PSM standard. All audit findings and responses are entered and maintained in a Corporate computer-based
tracking system. The final resolution of each finding is documented and the two most recent audit reports are retained.
The processes at HCC have hazards that must be managed to help ensure continued safe operation. The Accident Prevention Program summarized previously is applied to all OSHA PSM / EPA RMP covered processes at the plant. 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, HCC has safety features on many of its units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes:
Release detection system connected to a plant-wide Emergency Alarm System.
Periodic inspection of process equi
Inspections by Operators each shift.
Routine leak detection and repair program for all system components.
Remotely-activated valves to isolate and limit release.
Emergency equipment shutdown systems that are activated automatically, locally or remotely.
Diked and sloped area with sump for spill containment.
Relief devices to prevent system overpressure.
Automatic overfill prevention instrumentation.
Specialized "excess flow" valves to restrict release.
State-of-the-art release prevention devices for pumps.
Process Relief Valves that discharge to a flare to capture and incinerate releases.
Valves to permit isolation of the process (manual or automated).
Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump).
All equipment designed and constructed to comply with industry codes, standards, and practices.
Internal and external audits to verify conformance with regulatory and Company standards.
Established Emergency Response Plan.
State-of-the-art Emergency Alarm System.
Automatic water sprinkler system and fire hydrants with nozzles in specific areas.
Fire Suppression and Extinguishing Systems.
Mobile emergency response equipment.
Personal Protective Equipment (e.g., protective clothing, self-contained breathing apparatus).
Trained Emergency Responders onsite 24 hours/day.
Communications link to offsite response teams (CIMA and LEPC).
FIVE-YEAR ACCIDENT HISTORY
HCC has an excellent record of accident prevention over the past five years. There have been no releases of regulated flammable substances in the past five years that have resulted in deaths, injuries, significant property damage onsite, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
EMERGENCY RESPONSE PROGRAM
HCC operates an extensive emergency response program to protect worker and public safety as well as the environment.
HCC has several written documents, which detail the actions to be taken in response to an unwanted release of a highly hazardous chemical. General Plant Safety Rules, Section D-1 of the HCC Safety and Loss Control Manual provides basic instructions to employees for reporting and responding to an emergency. The HCC Emergency Procedures Manual and the Emergency Action Plan further provide detailed instructions and information utilized by essential personnel with regard to the emergency planning and response systems that are implemented at HCC.
The program consists of procedures for responding to various emergencies, including a small incidental emergency, a zone or complex-wide emergency, an external emergency, a hurricane or severe weather emergency, and a bomb threat. The Incident Command System (ICS) is utilized to manage all emergency response situations. The HCC Emergency Response Team, a volunteer group of trained employees, responds to all plant emergencies to help minimize
loss of like, property and to provide emergency medical care to the injured. Trained Emergency Responders are onsite 24 hours per day.
HCC is divided into seven zones, all other areas are considered Outside Zones. The zones are further divided into Affected Zones and Un-affected Zones depending upon the location and nature of the incident. The Emergency Alarm System is designed to make either an Alarm or Announcement Tone followed by a voice message in the event of an incident. The Emergency Alarm System is maintained to help response personnel or personnel working in either the Affected, Un-affected or Outside Zone determine the appropriate actions specified in the Emergency Action Plan. Other communication tools include two-way radios and pagers.
HCC is a member of Channel Industries Mutual Aid (CIMA) which is an organization of companies and agencies which are prepared to handle their own normal emergencies, but are also prepared to lend emergency assistance to other mem
bers when it is requested. HCC is also involved with CAER (Community Awareness and Emergency Response) and the Pasadena LEPC (Local Emergency Planning Committee).
PLANNED CHANGES TO IMPROVE SAFETY
HCC has implemented numerous safety improvements over the past decade. Many of these changes were prompted by the OSHA Process Safety Management Standard (PSM), which required very detailed hazard assessment studies. Company policies and standards have also resulted in improvements.
Phillips' Process of Safety and Environmental Excellence (PSEE) system is used to set both short-term and long-term goals and objectives at each unit throughout the Company. HCC develops annual safety and environmental improvement objectives as part of its business planning and budgeting cycle. Some of the planned objectives are:
Implement department Employee Safety process (ESP) action plans.
Increase participation with community agencies and communities.
Review and improve the Mechanical Integrity
Covered Equipment (MICE) program.
Conduct an audit of all health, environmental and safety systems to ensure compliance with both governmental and Company policies and standards.
Revise the Contractor Management Program.
Conduct training on the new Incident Investigation Program.