ExxonMobil Chemical Baytown Chemical Plant - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
The ExxonMobil Baytown Chemical Plant has a long-standing commitment to worker and public safety and protecting the environment. This commitment is demonstrated by the resources invested in accident prevention, personnel training, and safety in the design, installation, operation, and maintenance of our processes. Our objective is to implement effective controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control, contain and mitigate the release.
ExxonMobil modified its safety programs in 1991 to adopt structured environmental and safety management systems, entitled Operations Integrity Management System (OIMS). In 1997, Lloyd's Register Quality Assurance reviewed OIMS and evaluated it against the international standard for Environmental Management Systems (ISO 14001) to determine if OIMS meets the requirements of ISO 14001. After an
extensive review which included a number of facility audits, they concluded that the "environmental components of OIMS are consistent with the intent and meet the requirements of the ISO 14001 Environmental Management Systems Standard." They went on to say, "We further believe ExxonMobil to be among the industry leaders in the extent to which environmental management considerations have been integrated into its ongoing business processes."
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The ExxonMobil Baytown Chemical Plant is located in Baytown, Harris County, Texas. It operates to produce a variety of petrochemical products such as Butyl Rubber, polypropylene plastic, and a number of chemical intermediate feedstocks such as propylene. The plant has several regulated flammables such as propylene, ethylene, propane, and isobutylene. In addition, the plant uses anhydrous ammonia, chlorine, bromine, and methyl chloride that are regulated substances under RMP. The p
lant includes a total of sixteen covered processes for purposes of this plan.
HAZARD ASSESSMENT RESULTS
The hazard assessments were done using the EPA supplied "look up tables". These tables cover all the parameters required by the RMP rule for both worst case (WCS) and alternate case (ACS) scenarios.
The WCS associated with toxic substances in Program 3 processes at our plant is a release of bromine from a storage tank that would have an off-site endpoint. Although we have numerous controls to prevent such releases and to manage their consequences should an incident occur, no credit for administrative controls or active mitigation measures was taken into account in evaluating this scenario.
The WCS associated with a release of flammable substances in Program 3 processes at the plant is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing a covered flammable, in our case isobutylene (2-methylpropene). The full tank inventory is ass
umed to release, completely vaporize, and ignite, resulting in a VCE. Although we have numerous controls to prevent such releases and to manage their consequences should an incident occur, no credit for mitigation was taken into account in evaluating this WCS. This WCS has an off-site endpoint.
The alternative case scenario (ARS) for Anhydrous Ammonia is a failure of a loading hose during transfer operations. This ARS has an off-site endpoint.
The alternative case scenario for bromine is a leak in a loading hose during unloading operations. This scenario would have an off-site endpoint.
The alternative case scenario for chlorine involves a piping failure on a shipping cylinder. This scenario has an off-site endpoint.
The alternative case scenario for methyl chloride involves the failure of a piping flange gasket. This scenario would have an off-site endpoint.
The alternative case scenario for flammable substances involves a leak from a failed piping flange gasket with subsequen
t explosion. This scenario would have an off-site endpoint.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program in place at the ExxonMobil Baytown Chemical Plant.
EPA's Program 3 prevention requirements have been implemented for our entire plant even though some processes clearly do not meet Program 3 or are not covered by this Rule. This is the same approach taken with respect to the OSHA Process Safety Management (PSM) standard. We believe that this approach provides the maximum safety for our employees and the community.
In addition, Exxon Mobil Corporation has implemented its Operations Integrity Management System (OIMS). OIMS includes aspects of EPA's prevention program. As already mentioned, 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 t
his RMPlan. 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 accommodate the ever-changing nature of the database, we selected April 1, 1999, as the date to collect this information. Most of the reviews/updates conducted after that date are not reflected in the Data Element information.
The ExxonMobil Baytown 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 procedures to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that addresses each accident
prevention program element. In addition, a number of initiatives are 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.
Process Safety Information
The ExxonMobil Baytown 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 chemical plant are assigned responsibility for maintaining up-to-date process safety information.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety da
ta 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 chemical plant has identified Operating Envelopes; i.e. documented safety-related limits for specific process parameters such as temperature, level, and compositions. The chemical 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., automated shutdown systems, alarm systems).
The chemical plant also maintains numerous technical documents that provide much information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment. This information, in combination with written procedures and trained personn
el, 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 ExxonMobil Baytown 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 ExxonMobil Baytown Chemical Plant primarily uses the Knowledge Based Hazard and Operability (HAZOP) study that is an adaptation by ExxonMobil Research and Engineering and ExxonMobil 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 exp
erience 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 the team believes such measures are appropriate.
The PHA team findings are forwarded to local management for resolution. Mitigation options are identified and evaluated. Selected mitigation options are tracked until they are complete. The resolution and completion of each finding is documented and retained.
To ensure that process controls do not deviate significantly from the original design safety features, the ExxonMobil Baytown Chemical Plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years for the life of the process.
Operating Procedures and Safe Work Practices
The ExxonMobil Baytown Chemical Plant maintains written procedures that addre
ss 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 consistent basis for training 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 chemical 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.
To complement the written procedures for process operations, the Baytown Chemical Plant has implemented a comprehensive training program f
or all employees involved in operating a process. New employees receive basic training in chemical plant operations if they are not already familiar with such 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) adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operations technicians 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. Training is documented for each operator, including the means used to verify that the operator understood the training.
The ExxonMobil Baytown Chemical Plant uses contractors to supplement its workforce during periods of increased mai
ntenance or construction activities. Because some contractors work on or near process equipment, the chemical 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 chemical 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 ExxonMobil Baytown Chemical Plant evaluates contractor safety programs and performance during the selection of a contractor. Chemical plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety ob
Pre-startup Safety Reviews (PSSRs)
The ExxonMobil Baytown Chemical Plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information 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 an additional check to ensure construction is in accordance with 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 program requirements are properly implemented.
The ExxonMobil Baytown Chemical Plant has well-established practices and procedures to maintain pressure ve
ssels, 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 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 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 wit
hin 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 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 ExxonMobil Baytown 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 & Other Safe Work Practices
The ExxonMobil Baytown Chemical Plant has long-standing safe work practices in place to ensure worker and process safety. These include orientations for visitors/contractors, control of the entry/presence/exit of support personnel, energy isolation for equipment being
worked on, procedures for the safe removal of hazardous materials before opening of process piping/equipment, hot work permit/procedure to safely manage spark-producing activities, vehicle entry into process area, confined space entry permit/procedure to help ensure precautions are taken before entering confined spaces, and job safety analyses to identify and mitigate hazards associated with maintenance tasks. These practices, along with related procedures and training of affected personnel, form a system to help ensure operations and maintenance activities are performed safely.
Management of Change
The ExxonMobil Baytown Chemical 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 contro
ls 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.
The ExxonMobil Baytown 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 recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to chemical plant management for resolution. Corrective actions 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 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 ExxonMobil Baytown 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 every 3 years. The audit team develops findings that are forwarded to chemical plant 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 two most recent audit reports will be retained.
CHEMICAL SPECIFIC PREVENTION STEPS
The accident prevention program summarized previously is applied to all covered processes at the ExxonMobil Baytown Chemical Plant. Collectively, these prevention program activities help to 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 ExxonMobil Baytown Chemical 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 features are used in various processes:
1. Hydrocarbon detectors with alarms
2. Bromine detectors with alarms
3. Operator rounds
1. Process relief valves that discharge to a flare to capture and incinerate releases
2. Valves to permit i
solation of the process (manual or automated)
3. Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
4. Curbing, dikes, or water sumps to contain liquid releases
5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)
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 ExxonMobil Baytown Chemical Plant has an excellent record of accident prevention over the life of the chemical plant. There have been two accidents in the past 5 years, which are reportable under this regulation. One involved a freeze-burn to the hand of an employee that required minor medical treatm
ent and one involved a fire that resulted in only on-site equipment damage. Neither incident had off-site impact.
EMERGENCY RESPONSE PROGRAM INFORMATION
The ExxonMobil Baytown 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, the ExxonMobil Baytown Chemical 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 as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to chemical plant processes or other chemical 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 ExxonMobil Baytown Chemical Plant is coordinated with the City of Baytown Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes citizens, local emergency response officials, local government officials, and industry representatives. The ExxonMobil Baytown Chemical Plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizati
ons (e.g., City of Baytown Fire Department). This provides a means of notifying the public of an incident as well as facilitating quick response to an incident.
PLANNED CHANGES TO IMPROVE SAFETY
Our Operations Integrity Management System forms the cornerstone for continuous improvement in our safety-related systems. These systems are evergreen and are in a continuous state of improvement, usually through many small improvement steps. Some examples are the implementation of recommendations from our hazard reviews and incident investigations. Other examples are the improvement steps that result from review of our operating and mechanical procedures systems that are tightly integrated with our training programs. A key improvement step underway involves entry into the OSHA Voluntary Protection Program (VPP). This is a joint effort with our unions that will strengthen our overall prevention programs. One key risk reduction project underway is an inventory reduction project in our li
ght hydrocarbon storage areas. Another area of current and future emphasis involves the area of human factors. This involves the identification of improvements that minimize the likelihood of human error.
RMP COMMUNICATIONS AND COMMUNITY DIALOGUE
The ExxonMobil Baytown Chemical Plant views RMP as an opportunity to build onto existing community outreach programs, and as a catalyst to open new and continuing dialogue with our neighbors and citizens in Baytown. Our communications goal is to go beyond the requirements defined in the RMP rule. From the outset, our plan has been to communicate RMP elements to as broad a local audience as we can reach. The RMP rule also is enabling us to educate and inform the Baytown community about safety measures in place and the close working relationship we have between ExxonMobil emergency responders, the City of Baytown Fire and Police Departments and the Local Emergency Planning Committee (LEPC).
The ExxonMobil Baytown Chemical Plant committed
to participating with over 120 other member companies of the East Harris County Manufacturers Association (EHCMA) to communicate RMP broadly and openly. Through several EHCMA RMP work groups, industry and citizen volunteers worked to develop a communication plan which would 1) include a large regional event with opportunities for expression of diverse viewpoints on chemical risk management and a forum for each member company to provide its offsite consequences materials to the media and the public; and 2) provide industry in each of several local communities along the Houston Ship Channel--the Baytown area being one--an opportunity to communicate RMP throughout their community.
EHCMA's RMP community hall meeting was held on February 4, 1999, at the Pasadena (Texas) Convention Center and attended by over 800 people. Reporters from at least 11 radio and TV stations, seven local area newspapers, the Houston Chronicle and several chemical industry publications were present and reported
extensively about the event.
In Baytown, the ExxonMobil Baytown Chemical Plant worked jointly with other local area chemical plants, citizen volunteers, our Baytown area LEPC and Fire Chief and Mayor to style a program to communicate RMP to all Baytown citizens interested in learning about RMP. Through the input of citizen volunteers, a communications plan was developed to meet with over 50 local professional, neighborhood, civic, and church organizations. Additionally, RMP briefings were scheduled for the trustees of the local school district and community college, LEPC, city council and business/service organizations. To date (early April), ExxonMobil has participated in or has been the lead presenter at the first six of these community meetings attended by about 650 of our neighbors. Feedback from the community has been positive and gratifying.
For the 4,000+ ExxonMobil Baytown area employees, the ExxonMobil site managers made over 20 RMP presentations during January 1999. An
invitation to attend one of these meetings was extended to every employee of the ExxonMobil Baytown Complex.
RMP is indeed providing the ExxonMobil Baytown Chemical Plant with the opportunity to open additional avenues of dialogue with the community in order to educate and inform citizens about our operations. Our community outreach programs are intended to earn the trust of the Baytown community and provide a means for continuing dialogue between the community and ExxonMobil. The RMP rule is providing a most effective addition to ExxonMobil's community outreach programs in Baytown.