Exxon Chemical Americas Baton Rouge Chemical Plant - Executive Summary

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EXXON BATON ROUGE CHEMICAL PLANT 
EXECUTIVE SUMMARY 
 
286 LDEQ FACILITY ID NUMBER 
______________________________________________ 
 
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
Exxon modified its safety programs in 1991 by adopting structured safety management systems entitled, "Operations Integrity Management Systems (OIMS)."  The Exxon Baton Rouge Chemical Plant utilizes a formal program of operations integrity along with the Chemical Manufacturers Association (CMA) Responsible Care initiative to assure proper design, operation, maintenance, inspection, work permits, change management, and emergency response in a proactive effort to minimize risk to the public, environment, and the plant. 
 
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES 
 
The Exxon Chemical Plant employs 1542 employees who live and work in the Baton Rouge, LA area.  In business at the same location since 1940, the company is a quality producer of industrial chemicals such as ethylene, pro 
pylene, and isopropyl alcohol.  Our products are used around the world to make a variety of consumer products such as tubeless tires for automobiles, paint for our homes, and disposable diapers for babies. 
 
Exxon Chemical Plant has 35 chemicals in threshold quantities affected by the rule - ammonia (anhydrous), ammonia (>20%), bromine, chlorine, ethylenediamine, methyl chloride, oleum, sulfur dioxide, sulfur trioxide, 1,3 butadiene, butane, butene, 1-butene, 2-butene, 2-butene-cis, 2-butene-trans, ethane, ethyl mercaptan, ethylene, hydrogen, isobutane, isopentane, isoprene, methane, 2-methyl-1-butene, 3-methyl-1-butene, 2-methyl propene, 1,3-pentadiene, pentane, 1-pentene, 2-pentene,(E), 2-pentene,(Z), propane, propylene, vinyl acetylene. 
 
HAZARD ASSESSMENT RESULTS 
 
Hazard assessments were done using the EPA supplied "look-up tables" for the Worst Case Scenarios (WCS) and Alternate Release Scenarios (ARS).  The WCS for toxics is the total release of the entire contents of chlorine from 
a rail car.  Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating this scenario.  The WCS has offsite impacts. 
 
 
 
 
The WCS for flammables is the total release of the entire contents of 1-pentene from a storage sphere.  The entire volume is assumed to vaporize instantaneously and ignite,  
resulting in a vapor cloud explosion.  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 this WCS.  This WCS has offsite impacts. 
 
The ARS listed below all have limited offsite impact: 
 
1. 
Ammonia (anhydrous) release resulting from instrument failure due to corrosion. 
 
 
2. 
Ammonia (concentration 20% or greater) release resulting from a flange leak from a gasket failure. 
 
 
3. 
Bromine release resulting from the diaphragm failure of a 1" v 
alve. 
 
 
4. 
Chlorine release resulting from a transfer hose failure. 
 
 
5. 
Ethylenediamine release resulting from a mechanical pump seal failure. 
 
 
6. 
Methyl chloride release resulting from a vessel leak in a small bore piping connection. 
 
 
7. 
Oleum release resulting from corrosion of small bore piping at the tank wall. 
 
 
8. 
Sulfur dioxide release resulting from a mechanical pump seal failure. 
 
 
9. 
Sulfur trioxide release resulting from the corrosion of small bore piping at the tank wall. 
 
 
10. 
Ethylene release from piping failure resulting in a vapor cloud explosion. 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS 
 
The following is a summary of the general Accident Prevention Program in place at the Exxon Baton Rouge Chemical Plant.  EPA's Program 3 prevention requirements were implemented because some processes at the plant meet Program 3 criteria and are also subject to the OSHA Process Safety Management (PSM) standard.  In addition, Exxon Corporation has implemented Operations I 
ntegrity Management Systems (OIMS) at each of its operations worldwide that includes the aspects of EPA's prevention program.  OIMS has been attested as equivalent to ISO 14001 as a valid management system to oversee the implementation of the risk management activities. 
 
Additional details are included in the Data Element Section of this RM Plan.  Due to the ongoing nature of our safety program, the dates associated with the various activities in  
 
 
 
our Accident Prevention Program are constantly changing.  To minimize rework, we selected May 1, 1999 as the date to begin collecting this information.  Consequently, most of the reviews/updates conducted after that date may not be reflected in the data element information. 
 
EMPLOYEE PARTICIPATION 
 
The Exxon Baton Rouge Chemical Plant encourages employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation range from updating and compiling operating and maintenance procedur 
es 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 Accident Prevention Program are documented in an Employee Participation Plan that is maintained at the site and addresses each Accident Prevention Program element.  In addition, the plant has a number of initiatives underway that address process safety and employee safety issues. 
 
PROCESS SAFETY INFORMATION 
 
The Exxon Baton Rouge Chemical 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.  Specific groups within the plant are assigned responsibility for maintaining up-to-date process safety information.  A table summar 
izing the reference documents and their location is readily available as part of the OIMS documentation to help employees locate any necessary process safety information.  Most of this information is available electronically via a Document Management System (DMS). 
 
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in Material Safety Data Sheets (MSDS).  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 identified operating envelopes, i.e., documented safety related limits for specific process parameters such as temperature, level, and compositions.  The plant ensures that the process is maintained within these limits using computerized process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., a 
utomated shutdown systems, alarm 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, electrical rating of equipment, 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 Exxon Baton Rouge Chemical 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 Exxon Baton Rouge Chemical Plant primarily uses the  
Knowledge Based Hazard and Operability (HAZOP) study that is an adaptation by Exxon Research and Engineering and Exxon Chemical Americas of widely used industry methodologies 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 experience and engineering expertise on the process to be evaluated.  This PHA 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 appropriate. 
 
The PHA team findings are forwarded to local management for resolution.  Implementation of mitigation options in response to PHA findings is based on a relative risk evaluation done by the PHA team.  This evaluation helps ensure that potential accident scenarios assigned greater risk receive attention first.  All approved mitigation optio 
ns being implemented in response to PHA team findings are tracked until they are complete.  The resolution of each finding is documented and retained. 
 
To ensure that the process controls and/or process hazards do not deviate significantly from the original design safety features, the Exxon Baton Rouge Chemical Plant periodically updates and revalidates the hazard analysis results.  These periodic reviews are conducted at least every five years for the life of the process.  The results and findings from these updates are documented and retained.  The team findings are forwarded to management for consideration and resolution of the findings is documented and retained. 
 
OPERATING PROCEDURES AND SAFE WORK PRACTICES 
 
The Exxon Baton Rouge Chemical Plant maintains written procedures that address various modes of process operations, such as (1) startup, (2) shutdown, (3) normal and (4) emergency operations.  These procedures can be used as a reference by experienced operators and provide a c 
onsistent basis for training of new operators.  The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process.  These procedures are periodically reviewed and annually certified as current and accurate. 
 
 
 
 
The plant has identified operating envelopes, i.e., documented safety related limits for specific process parameters such as temperature, level, and compositions.  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.  Operating procedures are also available in DMS. 
 
The Exxon Baton Rouge Chemical Plant has long-standing safe work practices 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 underg 
oing 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 ensure that operations and maintenance activities are performed safely. 
 
TRAINING 
 
To complement the written procedures for process operations, the Exxon Baton Rouge Chemical Plant has implemented a comprehensive training program for all employees involved in operating a process.  New employees receive basic training in plant operations.  After successfully completing this training, a new operator is paired with an experienced operator to learn process specific duties and tasks.  After employees demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to pe 
rform the duties and tasks in a safe manner on their own, they can work independently.  In addition, all operations personnel 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 for each operator, including the means used to verify that the operator understood the training. 
 
CONTRACTORS 
 
The Exxon Baton Rouge Chemical Plant uses contractors to supplement its workforce 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 safety orientation; (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 Exxon Baton Rouge Chemical 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. 
 
PRE-STARTUP SAFETY REVIEWS (PSSRs) 
 
The Exxon Baton Rouge Chemical Plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information and, therefore, is controlled by Management of Change (MOC).  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 as a quality assurance function by requiring verification that accident prevention requirements are properly implemented. 
 
MECHANICAL INTEGRITY 
 
The Exxon Baton Rouge Chemical 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; (3) performing inspections and tests; (4) correcting identified deficiencies; and (5) applying quality assurance measures.  In combination, these activities f 
orm 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 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 (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 possible) or a 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 Exxon Baton Rouge Chemical 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 
 
The Exxon Baton Rouge Chemical Plant has a Work Permit System in place to protect personnel, site facilities, and the surrounding community.  The purpose of the Work Permit System is to ensure that jobs are planned, equipment is prepared, personnel are informed of hazards and procedures, precautions are taken, and work is executed in a manner to protect safety, health, and the environment.  The Work Permit System covers hot work and other categories of work such as opening equipment, excavation, lifting, and confined spaces. 
 
MANAGEMENT OF CHANGE 
 
The Exxon Baton Rouge Chemical Plant has a comprehensive system to manage changes to processes.  This system requires that changes to items such as p 
rocess 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 before the change is implemented. 
 
INCIDENT INVESTIGATION 
 
The Exxon Baton Rouge Chemical 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 recurrenc 
e of the incident or a similar incident.  The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution.  Corrective actions are taken in response to the investigation team's findings and recommendations are tracked until they are complete.  The 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 five 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 Exxon Baton Rouge Chemical 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 ev 
ery three years.  The audit team develops findings that are forwarded to management for resolution.  Corrective actions taken in response to the audit team's findings are tracked until they are  
 
 
complete.  The resolution of each finding is documented, and the most recent audit reports are retained. 
 
CHEMICAL SPECIFIC PREVENTION STEPS 
 
The processes at the Exxon Baton Rouge Chemical Plant have hazards that must be managed to ensure continued safe operation.  The  Accident Prevention Program summarized previously is applied to all covered processes at the plant.  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 plant has safety features on many units to help, (1) quickly detect a release, (2) contain/control a release, and (3) reduce the consequences of (mitigate) a release.  The following types of safety feature 
s are used in various processes: 
 
   Release Detection 
 
   1.    Hydrocarbon detectors with alarms 
 
   2.    Chlorine detectors with alarms 
 
   3.    TV surveillance cameras 
 
   Release Containment/Control 
 
   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.    Curbing or diking to contain liquid releases 
 
   5.    Redundant equipment and instrumentation (e.g., uninterruptible power  
       supply for process control system, backup firewater pump) 
 
   6.    Atmospheric relief devices 
 
   Release Mitigation 
 
   1.    Fire suppression and extinguishing systems 
 
   2.    Deluge system for specific equipment 
 
 
   3.    Trained emergency response personnel 
 
   4.    Personal protective equipment (e.g., protective clothing, self-contained  
       breathing apparatus) 
 
   5.    Blast resistant buildings to help protect control systems and  
personnel 
 
FIVE YEAR ACCIDENT HISTORY 
 
The Exxon Baton Rouge Chemical Plant has an excellent record of accident prevention over the life of the plant.  There has been one accident during the past five years, which is reportable under this regulation. 
 
EMERGENCY RESPONSE PROGRAM INFORMATION 
 
The Exxon Baton Rouge Chemical 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, t 
he plant has procedures that address 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 to perform their specific emergency response duties.  The emergency response program is updated based on modifications made to plant processes or 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 Exxon Baton Rouge Chemical Plant is coordinated with the East Baton Rouge Parish 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 plant has around-the-clock communications capability with appropriate LEPC officials and emergency re 
sponse organizations (e.g., City of Baton Rouge Fire Department).  This provides a means of notifying the public of an incident as well as facilitating quick response to an incident.  In addition to periodic LEPC meetings, the plant conducts periodic emergency drills that involve the local response agencies. 
 
 
 
 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
The Exxon Baton Rouge Chemical Plant resolves all findings from PHAs, some of which result in modifications to the process.  The following types of changes are planned: 
 
   1.    Eliminating use of chlorine as a cooling tower treatment 
 
   2.    Evaluating alternatives to central ammonia storage 
 
   3.    Delivery of MSDSs to all users in electronic system 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
D.J.Pidgeon/lhp 
June 9, 1999 
ww:\dee\rmp\286 LDEQ.....doc 
 
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