Formosa Hydrocarbons Company Inc - Point Comfort - Executive Summary |
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Formosa Hydrocarbons Gas Plant Risk Management Plan: Executive Summary ACCIDENTIAL RELEASE PREVENTION AND RESPONSE POLICIES The Formosa Hydrocarbon - Point Comfort gas plant 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 policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Formosa Hydrocarbon - Point Comfort gas plant, located in Point Comfort, Texas, operates a single process to produce petroleum products (e.g., natural gas, natural gas liquids and condensate) from natural gas. The Formosa Hydrocarbon - Point Comfort gas plant has several regulat ed flammables as part of the natural gas liquids, they are methane, ethane, propane butane, and pentane. The plant does not contain any toxic materials above the threshold quantities requiring a RMP submittal. OFFSITE CONSEQUENCE ANALYSIS RESULTS No worst-case scenario (WCS) or alternative release scenario (ARS) exist for toxic substances at the gas plant. The WCS associated with a release of flammable substances in Program Level 3 processes at the gas plant is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing ethane, propane, butane and pentanes. A written procedure is in place to limit the storage inventory to 129,061 lb.; therefore, this inventory is assumed to release and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for the WCS is 0.41 mile. 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 the WCS. The ARS for flammable substances at the gas plant is a BLEVE of the NGL surge tank. The maximum distance to the radiant heat endpoint of 5 Kw/m2 is 1451 feet. This event was selected as being a practical scenario for use in emergency planning and response. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the plant. Because processes at the gas plant are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation The Formosa Hydrocarbon - Point Comfort gas plant encourages employees to participate in all facets of process safety management and accident preventio n. Examples of employee participation range from updating and compiling technical documents (operating procedures) and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the 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 plant and addresses each accident prevention program element. Process Safety Information The Formosa Hydrocarbon - Point Comfort gas plant 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. Plant personnel are assigned responsibility for maintaining up-to-date process safety information. A PSM management document summarizing the reference documents and their location is being developed and will be readily available to help employees 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 corrosion concerns. For specific process areas, the plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the operating procedures. The plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The plant 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, and electrical rating of equipment. 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 (PHA) The Formosa Hydrocarbon - Point Comfort gas plant 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 Formosa Hydrocarbon - Point Comfort gas 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 hazar d 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 the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are handled by local management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly fro m the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are planned for completion in 1999 and will be conducted every 5 years until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures The Formosa Hydrocarbon - Point Comfort gas 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, and (5) normal shutdown. These procedures can be used as reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept cur rent and accurate by revising them as necessary to reflect changes made through the management of change process. In addition, the Formosa Hydrocarbon - Point Comfort gas plant's operating procedures contain procedures that provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, the Formosa Hydrocarbon - Point Comfort gas plant is implementing a comprehensive training program for all employees involved in operating a process. New employees will receive basic training in gas plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator will be paired with a senior operator to learn process-specific duties and tasks. After operators de monstrate (e.g., through skill demonstrations) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators will 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 scheduled to be conducted at least every year. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The Formosa Hydrocarbon - Point Comfort gas plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. However, the use of contractors is minimal. Because some contractors work on or near process equipment, the gas plant is implementing practices to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) ar e aware of the hazards in their workplce, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform gas 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 their beginning work. In addition, the Formosa Hydrocarbon - Point Comfort gas plant uses the purchasing group at Formosa Plastics to evaluate contractor safety programs and performance during the selection of a contractor. Formosa Plastics personnel are also used to periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) The Formosa Hydrocarbon - Point Comfort gas 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, procedures, personnel, and 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 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 Formosa Hydrocarbon - Point Comfort gas plant is establishing 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. Maintenance personnel will 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 jobs in a safe manner. Written procedures will help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are planned to be 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 poss ible), or employees will use the management of change system to 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 Formosa Hydrocarbon - Point Comfort gas plant is developing procedures and practices, applicable to the level of risk, that incorporates quality assurance measures into equipment purchases and repairs. At present quality assurance is maintained by only using original equipment specifications to order replacement parts, using the original equipment manufacturers to do specialized maintenance and or using certified shops to conduct repair work to national codes. This helps ensure that new or repaired equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The Formosa Hydrocarbon - Point Comfort gas plant has long-standing safe work practic es 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 substances 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 other), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Formosa Hydrocarbon - Point Comfort gas plant is developing a comprehensive system to manage changes for the covered process. This system will require 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 will be 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 will be provided any necessary training on the change. Incident Investigation The Formosa Hydrocarbon - Point Comfort gas 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 and develop corrective actions to prevent a recurrence of the incident or similar incident. The investigation team d ocuments its findings, develops recommendation to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team's finding 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 5 years so that the reports can be reviewed during future PHAs and PHA revalidation's. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Formosa Hydrocarbon - Point Comfort gas 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 ever 3 years. The audit team develops findings that are forwa rded 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 recent audit reports are retained. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the Formosa Hydrocarbon - Point Comfort gas plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program summarized previously is applied to all RMP-covered processes at the Formosa Hydrocarbon - Point Comfort gas plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The Formosa Hydrocarbon - Point Comfort gas plant has safety features 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 the covered processes: Release Detection 1. Gas detection in the process unit to detect any hydrocarbon release. 2. Normal operator rounds over the entire process area to detect small releases (such as a valve stem leak) before the gas detection system picks up a release. Release Containment/Control 1. Some process relief valves discharge to a flare to capture and incinerate episodic releases. 2. Valves to permit isolation of the process (e.g., manual or automated). 3. Automated shutdown systems for specific process parameters (e.g., high temperature). 4. Redundant equipment and instrumentation (e.g., a uninterruptible power supply for process control system) 5. Atmospheric relief devices. 6. Manually activated shutdown system to allow the operators to safely shutdown the process, for a var iety of reason which could include a catastrophic release. Release Mitigation 1. Fire suppression and extinguishing systems. 2. Trained emergency response personnel. 3. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus). FIVE-YEAR ACCIDENT HISTORY The Formosa Hydrocarbon - Point Comfort gas plant has an excellent record of accident prevention over the past 5 years. There has been a no record of accidental releases. We investigate every incident very carefully to determine ways to prevent similar incidents from recurring. The following table is a summary of the number of incidents that have occurred during the past 5 years. 1995 1996 1997 1998 1999 Number of RMP Events with Onsite Effects 0 0 0 0 0 Number of RMP events with Offsite Effects 0 0 0 0 0 EMERGENCY RESPONSE PROGRAM INFORMATION The F ormosa Hydrocarbon - Point Comfort gas plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. Emergency response is managed for Formosa Hydrocarbons by the Formosa Plastics plant in Point Comfort, Texas. Formosa Hydrocarbons reports the emergency or potential emergency to Formosa Plastics, which provides 24 hour coverage. 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 release. 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 postincident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, insp ection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees will receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to gas plant processes. 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 Formosa Hydrocarbon - Point Comfort gas plant is coordinated with the Formosa Plastics plant in Point Comfort, Texas and the Calhoun County, 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 Formosa Hydrocarbon - Point Comfort gas plant has around-the-clock commu nications capability with Formosa Plastics who maintain communications with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, Formosa Plastics, who provide the emergency preparedness, has conducted drills that involve the LEPC and emergency response organizations, and Formosa Plastics provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the Formosa Hydrocarbons - gas plant. PLANNED CHANGES TO IMPROVE SAFETY The Formosa Hydrocarbon - Point Comfort gas plant resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned over the next few years in response to PHA, safety audit, and incident investigation findings: 7 Upgraded process control system to use a PLC control system 7 Revisions to personnel training programs 7 Revised written operating procedures 7 Revised Management of Change procedures 7 Revised Pre-startup safety review 7 Revised Mechanical Integrity program 7 Conducting a process hazard analysis on the control system upgrade along with the PHA revalidation in 1999 7 Audit of the Accident Prevention Program elements in 1999 7 Revision of the emergency response training to include: 7 Fire extinguisher training 7 Evacuation and mustering training 7 Notification of Formosa Plastics emergency response team through use of a RTI system 7 Training of personnel on alarm notification recognition and practices |