BP Amoco Chemicals, Decatur Plant - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES |
The BP Amoco Chemicals Decatur 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 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 release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The BP Amoco Chemicals Decatur Plant is located on Finley Island Road, Decatur, Alabama 35601. The plant is owned by BP Amoco Chemicals Company. The plant manufactures paraxylene, purified terephthalic ac
id, and dimethyl 2,6-naphthalene dicarboxylate as intermediates for the polyester industry. In these processes, the plant uses four covered flammable chemicals and no toxic chemicals in sufficient quantities to be listed. Ethylene and propane are used as refrigerants, hydrogen is used as a reactant in purification, and 1-3 butadiene is used as a reactant. Three of the plant's processes are covered under the RMP regulation.
The BP Amoco Chemicals Decatur Plant is subject to the Clean Air Act Title V permitting regulation. The permit was filed on 12/14/1998 but has not been reviewed and granted, so no ID is available.
HAZARD ASSESSMENT RESULTS
Flammable Worst Case Scenarios:
The worst case scenario (WCS) for flammable substances is a vapor cloud explosion (VCE) with an overpressure end point of 1 pound per square inch (psi). The WCS end point is based on the instantaneous release of the entire contents of a vessel resulting in a VCE. The effects of administrative controls, mitig
ation systems, and safety systems are not included in determining the effect of a VCE. Distances to the end point were calculated using the methodology outlined in the EPA's RMP Off site Consequence Analysis Guidance. The following represents the WCSs calculated for the entire plant. One WCS is presented to represent all Program 3 processes.
WCS for flammable is a VCE resulting from the release of 1,3-butadiene from a ruptured tankcar located on plant tracks. BP Amoco has performed the WCS analysis as required by the rule and has shared the results with the EPA and with the LEPC.
Flammable Alternative Release Scenarios:
The alternative release scenario (ARS) for flammable substances at the plant is a VCE resulting from a release of 1,3-butadiene from a ruptured transfer line. The release would be expected to be isolated by operators within 10 minutes. The distance to the end point, a 1 psi overpressure, was calculated using the PHAST modeling software. This end point of 0.08
mile does not reach any off-site receptor.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
Following is a summary of the general accident prevention program in place at the Decatur, Alabama plant of BP Amoco Chemicals. Because processes at the plant that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.
The BP Amoco Chemicals Decatur 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 documents 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 plant accident prevention program. Specific ways that employees can be involved in the accid
ent prevention program are documented in an employee participation plan. In addition, the plant has a number of initiatives under way that address process safety and employee 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 operations, maintenance, engineering, and plant management. Some of these teams are the Process Safety Management Steering Committee, Plant Safety Team, and Contractor Safety Committee.
Process Safety Information
The Decatur, Alabama 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. Operating areas within the plant are assigned responsibility for maintaining up-to-date process safety info
rmation. A table summarizing the reference documents and their location is readily available as part of the process safety overview information for each process 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 corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition). The plant assures 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). In addition, tables summarizing the consequences
of deviation from these limits and the corrective actions to take are readily available.
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 rating 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 Decatur, Alabama 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.
he Decatur, Alabama plant exclusively 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 plant has conducted HAZOP studies on a 5-yr cycle since 1988, with the third cycle currently underway.
The PHA team findings are reviewed by management for resolution. A written action plan is generated by management assigning responsibility and determining an expected completion date for each recommendation made during the HAZOP study. All approved mitigation options being implemented i
n response to PHA team findings are tracked in an electronic database until they are complete. 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 from the original design safety features, the Decatur, Alabama plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and tracked. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained.
The Decatur, Alabama 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 written by experienced operators or foremen as needed 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 maintained current and accurate by revising them as necessary to reflect changes made through the management of change process.
In addition, safe operating limits are maintained to provide guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.
To complement the written procedures for process operations, the Decatur, Alabama plant has implemented a comprehensive training program for all employees involved in operating a process. Entr
y level standards have been set for new operators in conjunction with educational institutions. In addition, new operators receive basic training in plant operations. After successfully completing this training, a new operator is placed on shift with experienced personnel to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge and skills 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 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training.
The Decatur, Alabama plant uses contractors to supplement its work force during periods of in
creased 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 work place, (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 their beginning work. In addition, the Decatur, Alabama plant evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. A Contractor Sa
fety Committee actively pursues safety improvement for on-site contractors. A Contractor Safety Forum is an active group of contractor management personnel who meet periodically to share lessons learned and best practices.
Pre-startup Safety Reviews (PSSRs)
The Decatur, Alabama 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 the 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 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 requi
rements are properly implemented.
The Decatur, Alabama 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 ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent man
ner 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 (e.g., adequate wall thickness for containment systems). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or an MOC 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 Decatur, Alabama 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.
Safe Work Practices
The Decatur, Alabama plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of th
ese include (1) control of the entry/presence/exit of support personnel, (2) a lockout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials 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 others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
Management of Change
The Decatur, Alabama 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 changes be properly reviewed and authorized before being implemented. Changes are
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 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.
The Decatur, Alabama 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 similar incident. The investigation team documents its findings, develops reco
mmendations to prevent a recurrence, and forwards these results to plant 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.
To help ensure that the accident prevention program is functioning properly, the Decatur, Alabama 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 have participated as audit team members. The audit team dev
elops 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 are retained.
CHEMICAL SPECIFIC PREVENTION STEPS
The processes at the Decatur, Alabama plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied not only to all Program 3 EPA RMP-covered processes at the Decatur, Alabama plant, but also to the entire facility. 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, the Decatur, Alabama plant has safety features on many 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:
7 Hydrocarbon detectors with alarms
7 An on-going fugitive emissions monitoring program
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases
2. Valves to permit isolation of the process (manual or automated)
3. Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
4. Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump valve)
5. Curbing or diking to contain liquid releases
6. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)
7. Atmospheric relief devices
1. Fire suppression and extinguishing systems
2. Deluge systems for specific equipment
3. Trained emergency response personnel
4. Personal protective equipment (e.g., prot
ective clothing, self-contained breathing apparatus)
5. Mobile fire fighting equipment
EMERGENCY RESPONSE PROGRAM INFORMATION
The Decatur, Alabama 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 Decatur, Alabama plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of e
mergency 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 MOC process, which includes informing and/or training affected personnel in the changes.
The overall emergency response program for the Decatur, Alabama plant is coordinated with the Morgan 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 Decatur, Alabama plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessa
ry, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Decatur, Alabama plant conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant.
FIVE-YEAR ACCIDENT HISTORY
The Decatur, Alabama plant keeps records for all significant accidental chemical released that occur at the facility. The plant has no accidents involving listed chemicals in the past five years that met the on-site reporting criteria or involved off-site consequences.
PLANNED CHANGES TO IMPROVE SAFETY
The Decatur, Alabama plant of BP Amoco Chemical uses a system of five-year cycles of HAZOP studies of the process units, management of change, and investigation of incidents to detect potential causes of releases within the facility. Safety recommendations coming from these studies and investigations a
re resolved on a timely schedule, with the longest expected completion time of two years following the study. The HAZOP studies began in 1988 and are expected to continue beyond the third cycle that is now in progress. These systems are utilized to provide continuous improvement in the plant safety systems.