BP Amoco Polymers, Inc. - Executive Summary |
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BP Amoco Polymers, Inc., Greenville, South Carolina EPA Risk Management Plan - Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The BP Amoco Polymers, Inc., Greenville, SC plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources that facility management invests in accident prevention, such as training personnel and considering safety in the design, installation, operation and maintenance of our processes. Our plant adheres to process safety policies, guidelines, and best practices that have been developed based on company and industry experience over the years. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the incident. DESCRIPTION AND REGULATED SUBSTANCES The BP Amoco Polymers, Inc. plant is located at 7139 Augusta Road, Greenville, South Carolina. The plant is owned by BP Amoco Chemical Company. Various chemicals are processed to produce carbon fibers and resins for use in the aerospace industry and in sporting goods. For example, carbon fiber is a strong, light-weight material that when used to replace metal in aircraft results in reduce fuel usage while maintaining a secure, safe structure. The regulated substance at the plant in excess of the threshold quantity is acrylonitrile. Acrylonitrile is stored in an atmospheric tank and is charged to low pressure, low temperature reactors where it is converted to acrylic polymer suitable for spinning and converting to carbon fiber. HAZARD ASSESSMENTS Worst Case Scenarios The toxic worst case scenario (WSC) for the plant is a ten minute release of acrylonitrile from the acryonitrile storage tank. The worst case endpoint is based on releasing the entire contents of the acrylonitrile storage tank as described in the EPA Offsite Consequences Analysis Guidance. The effects of administrative controls, active mitigation systems, and safety systems are not included in the determination of the endpoint. The passive mitigation considered is the concrete dike around the tank that limits the exposed surface area of a pool which reduces the the release rate and the distance to the endpoint. Nearby public receptors could be affected by this type of release. Specific information on this release is presented in more detail in the plan. Alternative Release Scenarios The alternative release scenario for acrylonitrile assumes a 30 minute release duration from a piping leak which was modeled and calculated based on the SLAB model. The extent of the release will be mitigated by early detection through a gas chromatograph detection system, a dike around the tank, and vapor suppression with foam. The distance to the ERPG-2 endpoint is such that the release may leave the plant boundaries unless the available mitigation systems, both passive and active, are implemented. Specific information on this release is presented in more detail in the plan. PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the Greenville BP Amoco Polymers plant. Because processes at the plant that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard this summary also addresses the OSHA PSM elements and describes the management system in place to implement the prevention program. Employee Participation The Greenville BP Amoco Polymers 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 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 participatio n 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 operation, maintenance, engineering, and plant management. One initiative is the B-Safe Program, which is a behavior based safety system, in which all employees participate in developing safe work habits. After a work group has successfully integrated a targeted safe work practice into a habit that is always followed, the group celebrates their success. Also, each work group participates in monthly safety meetings. Members from a work group are responsible for determining the topics and then presenting the information to their co-workers. Topics range from safety issues off-the-job to safety issues in the workplace. Process Safety Information The Greenville BP Amoco Polymers 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. There is documentation available showing the location of this information to help employees 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 pro cess 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 Greenville BP Amoco Polymers plant has a comprehensive program to help en sure that hazards associated with the various processes are identified and controlled. Each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The 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 HAZOP teams recommendations are reviewed with management for approval. All approved recommendations are tracked until they are completed. The final resolution of each recommendation is d ocumented 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 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. The recommendations from these updates are also forwarded to management. Final resolution of the recommendations is tracked, documented, and retained. Operating Procedures The Greenville BP Amoco Polymers 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 operators as needed and provide a basis for consistent training of new operators. The procedures are periodically reviewed and annua lly 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 process operators and other personnel to use as necessary to safely perform their job tasks. The plant has many safe work practices in place to help ensure worker and process safety. Examples of these include (1) a lockout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (2) a procedure for safe removal of hazardous materials before process piping or equipment is opened, and (3) 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 Greenville BP Amoco Polymers 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 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 that the operator understood the training. Contractors The Greenville BP Amoco Polymers 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 and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to work starting. In addition, the plant evaluates contractor safety programs and performance duri ng 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 Greenville BP Amoco Polymers 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 is composed of process and project engineers, maintenance and operations personnel as well as health, safety, and environment personnel. The 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 Greenville BP Amoco Polymers 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 ensu re 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 or a management of change 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 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 Greenville BP Amoco Polymers plant has a hot work permit program which is facilitated through the plant's hazardous work program. The hazardous work program describes those areas 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 hazardous 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 hazardoust work, and assignment of a fire watch where appropriate. Management of Change The Greenville BP Amoco Polymers 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 chang es be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and verify that existing controls have not been compromised by the change. Any changes to chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated and documented. 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 Greenville BP Amoco Polymers 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 a simil ar incident. The investigation team documents its findings, develops recommendations to prevent 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 Greenville BP Amoco Polymers 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 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 along with the resolution of findings are retained. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the Greenville BP Amoco Polymers plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to the Program 3 EPA RMP covered process at the plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. In addition to the accident prevention program activities, the Greenville plant has safety features to help (1) contain/control a release, (2) quickly detect a re lease, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in our processes: Release Detection: 1. Acrylonitrile detectors set at the OSHA TLV with alarms 2. Acrylonitrile relief valve opening alarms Release Containment/Control 1. Valves to permit isolation of the process (manual or automated) 2. Automated shutdown systems for specific process parameters (i.e. high level, high temperature) 3. Curbing or diking to contain liquid releases 4. Redundant equipment and instrumentation (i.e. uninterruptible power supply for process control system, backup firewater pump) 5. Process vent/Incineration system for capturing and destroying vapors Release Mitigation 1. Fire suppression and extinguishing systems 2. Foam system for vapor suppression 3. Trained emergency response personnel 4. Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 5. Integrated relationship with the Donaldson Center HAZ MAT team 6. Enclosed spill collection system FIVE YEAR ACCIDENT HISTORY There have been no releases of acrylonitrile at the Greenville plant in the past five years that meet the RMP reporting requirements. EMERGENCY RESPONSE PROGRAM INFORMATION The Greenville BP Amoco Polymers plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. 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 released. 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 post incident cleanup and decontamination requirements. In addition, the plant has procedures that addr ess maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees 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 plant processes or other plant facilities. The emergency response program changes are administered through the management of change process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the plant is coordinated with the local HAZMAT team. This coordination includes sharing knowledge on the specific hazards at the facility, layouts of the facility processes, and training with the plant emergency response team. The plant has around-the-clock communications capability with appropriate emergency response organizations, such as the local HAZMAT team. This provi des a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. The plant conducts periodic emergency drills that involve the local HAZMAT team and other emergency response organizations. The plant provides for annual refresher training of the plant emergency response team with the local HAZMAT team regarding the hazards of regulated substances in the plant. PLANNED CHANGES TO IMPROVE SAFETY The Greenville BP Amoco Polymers plant resolves all findings from HAZOPs, some of which result in modifications to the process. The following types of changes are planned: Add spare pump for an acrylonitrile recovery tank. Revise process computor controls for flow indication of acrylonitrile in the process reactor. Improve labelling on piping and equipment in the PAN Chemical area. Revise training for the operators to shut down the foam system in the event of plant air system failure. Revise written operating procedures in the troub leshooting section for the AN stripping column condensor. |