BP Amoco Chemical Company - Executive Summary

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BP Amoco Chemical Company 
Pasadena, Texas Plant  
EPA Risk Management Plan - Executive Summary 
BP Amoco Chemical Co. is committed to operating and maintaining all of our processes, especially those using hazardous substances, in a safe and responsible manner.  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 plant adheres to process safety policies, guidelines, and best practices that have been developed based on company experience over the years.  Our policy is to implement reasonable controls to prevent foreseeable releases of all hazardous substances.  However, if a release should occur, our trained personnel are ready to respond to control and contain the incident. 
Facility Description and Regulated Substances 
The BP Amoco Chemical Pasadena Plant is located at 1500 North South Street in Pasadena Texas, 77501.  The facilit 
y produces linear alpha olefins and industrial grade alcohols using ethylene as the major feed stock in the two process operations.  Both of these processes have been in service for over 20 years and are closely interconnected and dependent on each other for efficient operation.  The processes start with ethylene under relatively high pressure and react it with an aluminum alkyl to form different aluminum alkyls containing long, straight hydrocarbon branches.  A number of subsequent steps remove and then separate the resulting long chain hydrocarbons into distinct alcohols and linear alpha olefin products.  These materials are primarily sold to other manufacturers for use in their production processes and shipped by either truck, rail or barge. 
Our processes use the following chemicals in excess of the threshold quantities specified in EPAs Risk Management Plan (RMP) regulation: 
7 Titanium Tetrachloride, which is used to improve alcohol yield.  We can store up to 84,500 lbs. 
of this material on site. 
7 Iron Pentacarbonyl, which is used in the production of one of our final products.  We can store up to 4,440 lbs. of this material on site. 
7 Butene, which is a product of our operations.  We can store over one million gallons of this material on site. 
7 Ethylene, which is the main feed stock to our processes.  Ethylene is supplied by pipeline at a rate of about 2,000 lbs/min. 
Our comprehensive operations and maintenance procedures, accidental release prevention activities and contingency planning efforts allow us to effectively manage the hazards that these materials pose to our employees, the public, and the environment.  This has been demonstrated by our past performance, 20 years of ongoing operations without a serious incident with off site impacts. 
Key Offsite Consequence Analysis 
Provided below are brief summaries of the worst-case release scenarios and alternative release scenarios, developed in accordance with the RMP rule.  
Also included is information about the key administrative controls and mitigation measures in place to limit the impact distances for each scenario. 
Toxic Release  Scenario -Iron Pentacarbonyl 
This worst case scenario assumes that the iron pentacarbonyl storage tank is full and ruptures spilling its entire contents of 4,440 lbs. into the existing containment area.  (For this to occur, it must be assumed that the storage drums safety relief valve does not work).  This scenario further assumes that operations personnel, who would normally be alerted to a possible release by an existing CO monitor, fail to take any remedial actions such as putting water on the spilled material.  These assumptions result in a hypothetical release that has impacts that extend off site and could reach near by residential communities. 
Alternate Toxic Release Scenarios-Iron Pentacarbonyl/Titanium Tetrachloride 
For both of these chemicals, unlike in the worst case scenario, a significant release is mo 
re likely to occur while unloading the materials into their respective primary storage drums.  For iron pentacarbonyl, the alternate scenario would have a release occur while unloading an iron pentacarbonyl cylinder into its storage drum.  It assumes that the 1" diameter unloading hose develops a leak.  This scenario is based on the operator, who is standing by while the cylinder is being unloaded, taking corrective actions such as immediately blocking in the leaking.  Based on a theoretical 100 lb. leak the EPA model indicated potential impacts could include one of our industrial neighbors. 
For titanium tetrachloride, a release is also most likely to occur while unloading a trailer into its storage tank.  A leak in the 2" diameter unloading line could result in a 1,000 lb. release.  The operator standing-by during the unloading is assumed to immediately block in the release and spray water on the spill.  The calculate impact zone for this hypothetical release could include one of our 
industrial neighbors but not the general public. 
Worst-case Flammable Release Scenario -Butene 
Butene is produced on site and is stored at several locations in the plant.  The worst case scenario assumes that the plants largest storage vessel is completely full and ruptures, instantly spilling its entire contents of 433,000 gallons.  This scenario then assumes that all of the spilled material ignites resulting in a vapor cloud explosion.  For this scenario to occur, requires the assumption that the storage vessels safety relief valves fail to work and that there is no pooling of liquid in the diked area around the vessel.  The theoretical impact zone for this case would include our industrial neighbors. 
Alternative Flammable Release Scenario - Ethylene 
A more reasonable alternate scenario for a flammable release would be a leak in the 6" ethylene supply line to the plant.  (Ethylene is the primary raw material for our production processes.)  Such a leak could release 100,000 
lbs. of Ethylene while the lines automatic shutoff system and operating personnel isolate the piping system.  The theoretical impact zone for such a release could include our industrial neighbors but not the general public. 
The results from these scenarios are being used to help ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 
General Accidental Release Prevention Program 
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals.  The processes in the plant that are covered by the EPA RMP regulation are also subject to other regulations, such as OSHAs Process Safety Management (PSM) standard.  Listed below are some of the many element we employee to maintain compliance with applicable regulations and to minimize incidents and releases. 
*  Employee participation 
*  Process safety information 
*  Process hazard analysis 
*  Equipment design, fabrication and construc 
tion standards 
*  Operating procedures 
*  Training 
*  Mechanical integrity 
*  Management of change 
*  Pre-startup review 
*  Compliance audits 
*  Incident investigation 
*  Hot work permitting 
*  Contractor management 
As indicated, there are many elements to our program, but several of these warrant brief discussion. 
Employee participation 
We encourage employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation range from compiling and updating technical information and operating procedures to participating as a member of a process hazard analysis teams.  Employees routinely participate process unit and plant wide safety improvement teams, focusing not only on process safety but also personal safety issues. 
Process Hazard Analysis 
The Pasadena Chemical plant has a comprehensive program to help ensure that hazards associated with our various chemical processes are identified and controlled.  Within this pro 
gram, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.  We primarily use 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 available. 
These studies are conducted using teams of people who have operating and maintenance experience as well as engineering expertise.  These teams identify and evaluate hazards of the process, as well as accidents prevention and mitigation measures, and make suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.  At least every five years, the plant updates and revalidates these hazard analysis results.  Recommendations from these studies are sent to management for evaluation and implementation.  Final resolution of the recommendations is tracked, documented and retained. 
g Procedures 
The plant maintains written procedures that address various modes of process operations, such as startup, normal operation, temporary operations, emergency operations and shutdown.  These procedures are developed and periodically revised by experienced operators, as needed.  Such procedures not only aid in consistent day-to-day operation but also provide a basis for consistent training of new operations personnel. 
Mechanical Integrity 
The Pasadena Chemical plant has well-established practices and procedures in place to properly maintain pressure vessels, piping systems, relief and vent systems, monitoring and control systems, pumps, compressors and all other critical equipment.  The basis aspects of the program include: proper training, written procedures and plans, periodic inspections and testing, correcting identified deficiencies and applying quality assurance measures.  In combination these activities for a system that maintains the mechanical integrity of the proc 
ess equipment. 
All of the individual elements of our prevention program work together to help prevent process upsets and accidental chemical releases. 
Chemical Specific Prevention Steps 
In addition to the general system elements discussed above, the Pasadena Chemical plant has additional safety features on specific areas of concern.   
Release Detection 
7 Hydrocarbon detectors with alarms 
7 Infrared/flame detectors with alarms and/or automatic deluge systems 
7 CO detectors with alarms 
Release Containment/Control 
7 Process relief valves that discharge to a flare 
7 Valves to permit prompt isolation of the process (both manual and automated) 
7 Automatic shutdown/bypass systems for specific process parameters (i.e. high level, high temperature, etc.) 
7 Curbing or diking to contain liquid releases 
7 Redundant critical equipment and instrumentation 
Release Mitigation 
7 Fixed fire suppression and extinguishing systems 
7 Deluge systems for specific equipment 
7 Trained emergency respon 
se personnel on scene around-the-clock 
7 Mobile fire fighting equipment 
7 Blast-resistant containment structures for specific equipment 
Five-Year Accident History 
There have been no significant accidental chemical releases involving materials covered under EPA's RMP rule during the past five years.  (In fact, there have been no significant chemical releases in the past 20 years that resulted in off site impacts.)  For any serious incident or near misses that do occur, we conducted formal incident investigations to identify and correct the root causes of the event. 
Emergency Response Program 
We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning.  Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations.  Furthermore, we coordinate our plan with the community emergency respons 
e plan.  We have mobile fire protection equipment, alarm systems, trained emergency responders and communications links to off-site responders to help prevent  or minimize a release. 
Planned Activities to Further Improve Safety 
The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: 
1) Evaluate alternative, less-toxic materials for possible substitution 
2) Evaluate upgrading instrumentation and detection equipment handling RMP toxics  
3) Install additional isolation valves on Ethylene supply system 
4) Continue to upgrade training for Operations and Maintenance personnel, including use of computer 
    based training system 
5) Audit and/or test systems to ensure Y2K compliance. 
6) Perform process hazard analysis studies focused specifically on procedures and systems handling RMP 
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