Port of Port Lavaca- Point Comfort - Executive Summary |
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Calhoun County Navigation District Port of Port Lavaca - Point Comfort EPA Risk Management Plan - Executive Summary 1.0 Introduction 1.1 Relationship of Owner and Operator The Port of Port Lavaca - Point Comfort (Port), directed by the Calhoun County Navigation District (CCND), is the owner of the facility. The portion of the Port facility that is subject to Risk Management Plan (RMP) regulations is operated by BP Chemicals Green Lake (BP Chemicals). The RMP incorporates the release prevention, emergency response, and training provisions of both the owner and operator, since these two entities coordinate on-site procedures to ensure that both Port and site BP Chemicals employees are properly prepared to prevent and respond to emergencies. 1.4 Owner History The Port was constructed in the 1950s and was designed to accommodate the transfer of chemicals and petrochemicals between ship or barge traffic and pipelines connected directly to remote client facilities. In 1998, a major expansion of the Port was initiated to accommodate BP Chemicals material transfers and storage. The construction phase of the project and the operational startup of the storage facility is scheduled for June 20-22, 1999. The Port owns all equipment used to transfer and store chemicals at the facility, and BP Chemicals is responsible for operation of the equipment to properly manage the chemicals. 1.3 Operator History The process used to produce BP Chemicals Green Lake products contain quantities of listed hazardous chemicals that require application of Process Safety Management (PSM) as required in OSHA 29 CFR Part 1910 and the RMP. BP Chemicals Green Lake Plant has an outstanding environmental record and is an OSHA VPP Star site, is ISO 9002 certified, and is a participant of the Clean Texas 2000 initiative. The facility has received the following awards: "Best In Texas" from the Texas Chemical Council for the years '89, '91, '92, '95, '96, '97 and '98; NPRA Gold Award & Award for Achievement - '95, '97 and '98; Governor's Award for Environmental Excellence - '93; and US EPA Environmental Excellence Awards - '93 (Underground Injection), '94 (NPDES) and '95 (UIC and NPDES). 1.5 Regulated Substances Handled The Port manages and stores acrylonitrile and ammonia for BP Chemicals. 1.6 Worst-Case and Alternative Release Scenario(s) Methodology given in the RMP Offsite Consequence Analysis Guidance was employed to determine worst and alternative case release scenarios. A technical team consisting of six local area Chemical Manufacturers Association member companies, including BP Chemicals, selected the basis for the scenarios. The team's findings were communicated in public meetings in October 1995 and again in May 1999 in an effort known as the Victoria/Calhoun County Communications. The following paragraphs provide details of the chosen scenarios. 1.6. 1 Worst-Case Release Scenario The worst-case scenario involves a catastrophic release of acrylonitrile from a full storage tank during worst-case weather conditions. It is assumed that the entire quantity is released into a dike. The distance to the toxic endpoint calculated by RMP*Comp (TM) is 11 miles. For this scenario, the planned emergency response is use of water sprays and foam in the diked area to minimize downwind effects and fire and explosion potential. 1.6.2 Alternative Release Scenario - Acrylonitrile This case involves a vessel leak through which acrylonitrile was released in 60 minutes through a 1 square inch hole during neutral weather conditions. The distance to the toxic endpoint calculated by RMP*Comp (TM) is 1.5 miles. For this scenario, the planned emergency response is use of water sprays and foam in the diked area to minimize downwind effects and fire and explosion potential. 1.6.3 Alternative Release Scenario - Ammonia This case involves a vessel l eak through which ammonia (anhydrous) was released in 60 minutes through a 1 square inch hole during neutral weather conditions. The distance to the toxic endpoint calculated by RMP*Comp (TM) is 0.8 miles. For this scenario, the planned emergency response is water sprays to minimize downwind effects and fire and explosion potential. 1.6.4 Weather Conditions Worst-Case Conditions Wind Speed: 1.5 meters/second (3.4 miles/hour) Stability Class: F Air Temperature: 77oF (25oC) Neutral Conditions Wind Speed: 3 meters/second (6.7 miles/hour) Stability Class: D Air Temperature: 77oF (25oC) 2.0 Release Prevention Program 2.1 Responsibility Compliance with the RMP is the responsibility of the Port Director. The Port Director works in cooperation with the BP Chemicals Plant Manager who is in direct consultation with the PSM/RMP Coordinator. The PSM/RMP Coordinator provides technical expertise for process safety, communicates requirements to appropriate m anufacturing managers, and coordinates policies and procedures to meet process safety requirements in support of the manufacturing areas. Because the day-to-day operations at the Port facility associated with BP Chemicals' materials are the responsibility of BP Chemicals, the PSM program has been developed by BP Chemicals, along with the Process Hazard Analyses, Process Safety Information compilation, Standard Operating Procedures, Inspection and Testing procedures, and other safety-related programs. Due to the nature of the owner/operator relationship, emergency planning and response procedures and plans have been a collaboration of the Port and BP Chemicals. Both the Port and BP Chemicals employees who are assigned to Port operations undergo operating and emergency response training specific to the potential hazards related to management of acrylonitrile and ammonia at the Port. 2.2 Employee Participation Employee participation, as appropriate, in the development of all safety- related programs and procedures has been utilized to ensure the practicality of the systems and to advance the understanding of both employees and system developers. It is the responsibility of each Port employee and each BP Chemicals employee assigned to the Port facility to participate in the safety programs prepared for the marine cargo handling facility and to follow all applicable safety rules, policies and procedures, including those required by PSM, the RMP and general Port policies. All employees are properly trained in the applicable safety practices, policies and procedures to safely conduct the activities of their job assignments and to respond to emergency events. 2.3 Process Safety Information BP Chemicals has a compilation of process safety information (PSI). The PSI is available for conducting process hazards analyses. The PSI includes: MSDS information pertaining to the hazards of the chemicals used or produced by the processes; I nformation on the process technology including block flow diagrams or simplified process flow diagrams, process chemistry, maximum intended inventory, safe upper and lower limits and other information included in operating manuals and Standard Operating Procedures (SOP's); and Information on the equipment used including P&ID's, electrical classification, relief system design and design basis, ventilation systems, safety systems, material and energy balances for new processes and equipment. Controlled copies of the PSI documents are kept in the department responsible for them. The PSI are kept current through application of BP Chemicals Green Lake Management of Change Procedure. Management of Change also involves a technical review that ensures and documents that changes in equipment comply with recognized and generally accepted good engineering practices. It is the policy of BP Chemicals that all applicable equipment is d esigned, maintained, inspected, tested and operated in a safe manner. For new processes, a project change procedure is utilized for construction until construction is complete and authorized for commission by the Plant Manager, at which time the process becomes subject to the Management of Change procedure. It is the responsibility of each Operations Engineer, Maintenance Team Leader or Planner, Control Systems Team Member, Project Management representative or any others who lead activities which involve PSI to ensure the applicable PSI is compiled and updated in accordance with OSHA PSM, the EPA RMP and the Management of Change Procedure. 2.4 Process Hazards Analysis BP Chemicals performs process hazards analyses (PHAs) on existing process units and on new process units as part of project safety reviews. The hazards analyses are updated at least every five years. The priority order for the initial hazards analyses are based on a documented rationale. The PHAs are carried out u sing acceptable methodology and address: Hazards of the process Previous incidents Engineering and administrative controls Consequences of failure of controls Facility siting Human factors Qualitative evaluation of possible safety and health effects The PHAs are performed by a team with expertise in engineering and process operations. The teams include at least one employee with experience and knowledge in the process as well as one person knowledgeable in the PHA methodology being used. All PHA recommendations are addressed and resolved with appropriate documentation in a timely manner. Planned actions are adequately managed with scheduled milestone completion times. PHA reports and documentation are retained for the life of the process. The PSM/RMP Coordinator is assigned to provide leadership for ensuring that the process hazards analyses are in accordance with requirements. The Area Manager is also respo nsible to provide the resources to resolve PHA recommendations, to complete recommended actions as needed and to communicate the actions to employees whose work may be affected by the recommendations or actions. 2.5 Operating Procedures BP Chemicals maintains controlled written operating procedures that provide clear instructions for safely conducting process activities. The operating procedure system consists of Operating Manuals and SOPs. Included in the operating procedures are: Steps for each operating phase including start-up procedures, routine/normal operations, batch/temporary procedures, shutdown procedures and emergency procedures. Operating limits including risks and safeguards. Safety and health considerations. Safety systems and their functions. The operating procedures are readily accessible to employees on the process units and are reviewed as often as necessary to ensure they reflect current operating practice. Procedures are routinely reviewed for content at least every 3 years depending on the criticality of the procedure as determined by the area managers or their designee. Procedures are also modified and updated as needed as part of management of change. Each Area Manager certifies annually that the operating procedures are current and accurate for process units within his/her area of responsibility. The Area Manager is responsible for maintaining operating procedures for his/her department. The HSE Manager is assigned to maintain written safe work practices site wide. The Area Managers are responsible to ensure employees and contractors apply safe work practices in their departments. 2.6 Training Employees involved in handling hazardous chemicals receive both safety training and process unit specific training. Safety training includes safety and health hazards and safe work practices. Unit specific training includes process specific training including operating pro cedures and emergency operations. Periodic reviews of safety and environmental issues are conducted. The Area Managers ensure employees within their areas of responsibility receive the training and qualification required for the employee's position assignments. 2.7 Contractors Contract employees undergo training that covers hazards, emergency action and safe work practices. The content of the training is determined by the Port and BP Chemicals prior to allowing work by contractors on Port property. 2.8 Pre-Startup Safety Review BP Chemicals performs pre-startup safety reviews for both new and modified facilities. It is the responsibility of those employees leading the change for small projects and of the project manager for large projects to ensure pre-startup safety reviews are conducted for new or modified facilities. 2.9 Mechanical Integrity BP Chemicals has programs to maintain the ongoing mechanical integrity of process equipment. The programs include written procedu res, training, inspection and testing, correction of equipment deficiencies and quality assurance. 2.10 Incident Investigation / Accident Release History Neither the Port nor BP Chemicals has had an accidental releases of a regulated substance in the past five years which resulted in deaths, injuries, or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. It is the policy of the Port and BP Chemicals that all accidents, unsafe conditions and near misses are investigated, and remedial activities identified and implemented to prevent a reoccurrence of the condition. 2.11 Emergency Planning and Response Emergency procedures have been designed to minimize an employee's exposure to a hazardous chemical release, protect the environment and surrounding community, contain and/or neutralize a spill or release, and have consistent standards applied during a release within the plant boundary. The emergency procedures for the Port facility are updated and tested on an annual basis to ensure the plan stays current and will accomplish all of the desired results. The overall emergency response program is coordinated with 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 Port has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., local fire department). The BP Chemicals Green Lake Plant has a trained Emergency Response Team consisting of approximately 100 employees. The team trains on a quarterly basis with emergency response drills and scheduled training days. The facility has trained emergency Offsite responders and is a participating member of Chemnet. This team responds to chemical spills in the plants geographic ar ea, including the Port. 2.12 Compliance Audits PSM/RMP compliance audits are conducted at least every three years to verify that the PSM/RMP procedures and practices are adequate and are being followed. The compliance audits are conducted by at least one person knowledgeable in the process. Compliance audit reports are prepared. Responses to the audits are managed, and deficiency corrections are documented. The two most recent audit reports are retained. 3.0 Chemical-Specific Prevention Steps In addition to the release prevention program activities, safety features have been designed for all units to: quickly detect a release, contain/control a release, and reduce the consequences of (mitigate) a release. 3.1 Release Detection Detectors with alarms located strategically throughout the process area 3.2 Release Containment/Control Curbing or diking to contain liquid releases Redundant equipment and instrumentat ion (i.e. uninterruptible power supply for process control system, backup firewater pump) Atmospheric relief devices 3.3 Release Mitigation Fire suppression and extinguishing systems Trained emergency response personnel Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) Mobile fire fighting equipment Blast-resistant buildings to help protect control systems and personnel 4.0 RMP Communication The Port Director has the responsibility of providing RMP information (other than the required EPA submission) to employees and the public pursuant to Section 68.210 of the regulation. These communications have been coordinated with local community cooperation and have been communicated in open forums in May 1999. 5.0 Planned Changes to Improve Safety The Port storage facility is scheduled to start operation in June 1999 following the pre-startup safety review. If the pre-startup review results in a necessary change to improve safety, then that change will be implemented prior to startup. Once the facility is operational, the system of audits, review and management of change will ensure that any additional safety controls are identified and implemented. |