ExxonMobil Baton Rouge Polyolefins Plant (BRPO) - Executive Summary |
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LDEQ Facility ID 3519 ExxonMobil BRPO Risk Management Plan: Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES ExxonMobil Baton Rouge Polyolefins (ExxonMobil BRPO) 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 policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, Exxon BRPO trained personnel will respond to, control, and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES ExxonMobil BRPO operates a high density polyethylene production facility in Baton Rouge, Louisiana. The primary operation of the facility is the production of HDPE at a rate of up to 1.8 billion pounds per year. Ethylene and comonomers are metered into a recirculating loo p reactor. Polyethylene is produced in small particles and is recirculated as a slurry in the isobutane. Isobutane, as well as small amount of unreacted ethylene and comonomers, are recovered and recycled back to the reactor. Polyethylene product is dried and sold as a powder or pellet. ExxonMobil BRPO is permitted to operate a polyproylene unit. This unit will use processes similar to the existing polyethylene facility. This process will however use propylene as the raw material. The unit is scheduled to begin operation in early May 2000. Fuels used at the plant include natural gas, gasoline, and diesel. ExxonMobil BRPO was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, ExxonMobil BRPO identified the regulated substances and quantities kept on site. Listed flammable substances which are stored above threshold quantities at ExxonMobil BRPO are isobutane, ethylene/isobutane mixture, hydrogen, 1-butene and propylene/propane mixture. Based on worst-case analyses of the regulated substances, the distances to endpoints exceed the distances to public receptors. In addition, ExxonMobil BRPO is subject to OSHA PSM. Therefore, ExxonMobil BRPO is classified as a Program 3 process under the ARP Program. OFF-SITE CONSEQUENCE ANALYSIS RESULTS Flammable Substances - Worst-Case Scenario The endpoint for the worst-case release of flammable substances is 1 psi overpressure (i.e., 15.7 psia), resulting from a vapor cloud explosion. The ARP Program requirement for flammables assumes an instantaneous release and vapor cloud explosion. A yield factor of 10 percent of the available energy released in the explosion shall be used to determine the distance to the explosion endpoint. Since the worst-case scenario for a flammable substance is based on the assumption that the entire quantity of the substance forms a vapor cloud, passive mitigation systems are not applicable. Propylene/prop ane mixture is the worst-case flammable release with a 0.43-mile distance to the endpoint. Toxic Substances ExxonMobil BRPO does not have any toxic substances held above the threshold quantity; therefore, analysis of one worst-case release scenario for all regulated toxic substances is not required. Flammable Substances - Alternative-Case Scenario A single alternative release scenario for all flammable substances is required under the ARP Program. A hypothetical, but likely to occur, release scenario has been identified for isobutane. A 2-inch opening at the "F" reactor results in a release of 5,917 lbs of isobutane. The isobutane will vaporize and may ignite in a vapor cloud explosion with an endpoint of 1 psi overpressure. The alternative-case release of isobutane resulted in a 0.15 mile distance to the 1 psi overpressure endpoint. Toxic Substances ExxonMobil BRPO does not have any toxic substances held above the threshold quantity. Therefore, analysis of each regulated t oxic substance is not required. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at ExxonMobil BRPO plant. Because processes at the plant that are regulated by the EPA's risk management program (RMP) regulation are also subject to the OSHA's PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation The ExxonMobil BRPO facility encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation include updating and compiling technical documents and chemical information to participating as a member of an incident investigation team. Employees have access to all information created as part of the plant's accident prevention program. Specific ways that employees can be involved in the accident prevention program are documente d in an employee participation plan that is maintained at the facility and addresses each accident prevention program element. In addition, the facility 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. Process Safety Information The ExxonMobil BRPO facility 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 departments within ExxonMobil BRPO are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the written Process Safety Information procedure to help employees 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, ExxonMobil BRPO has documented safety-related limits for specific process parameters (e.g., temperature level, composition). ExxonMobil BRPO ensures 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). ExxonMobil BRPO also maintains numerous technical documents that provide information about the design and constructio n of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. 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 (PHA) The ExxonMobil BRPO facility 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 the adequate controls are in place to manage these hazards. The ExxonMobil BRPO facility 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 t echniques. 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 the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. 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 f rom the original design safety features, the 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 retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures The ExxonMobil BRPO facility 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 can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate whe n a process change occurs. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. In addition, The ExxonMobil BRPO facility maintains 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. Training To complement the written procedures for process operations, The ExxonMobil BRPO facility has implemented a comprehensive training program for all employees involved in operating a process. New employees receive job specific basic training in Exxon BRPO operations. After successfully completing this training, a new operator is paired with a qualified operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they are qualified and 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. Contractors The ExxonMobil BRPO facility uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, Exxon BRPO 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 emerge ncy, (5) understand and follow site safety rules, and (6) inform ExxonMobil BRPO personnel of any hazards that they find during their work. This is accomplished by providing contractors with a handbook that includes (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 BRPO facility evaluates contractor safety programs and performance during the selection of a contractor. ExxonMobil BRPO personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) The ExxonMobil BRPO facility conducts a PSSR for any 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 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 requirements are properly implemented. Mechanical Integrity The ExxonMobil BRPO facility 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 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 jobs 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 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 ExxonMobil BRPO 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 ExxonMobil BRPO facility 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 undergoing maintenance, (3) a procedure for safe removal of hazardous substances 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 ExxonMobil BRPO facility has a comprehensive system to manage and document changes to all covered 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. Incident Investigation The ExxonMobil BRPO facility promptly investigates all incidents that resulted in, or reason ably 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 ExxonMobil BRPO 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 revalidation's. Compliance Audits To help ensure that the accident prevention program is functioning properly, The ExxonMobil BRPO facility 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 staff personnel participate as audit team members. The audit team develops findings that are forwarded to ExxonMobil BRPO 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 ExxonMobil BRPO facility have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program su mmarized previously is applied to all RMP-covered processes at The ExxonMobil BRPO facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The ExxonMobil BRPO facility 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 the covered processes: Release Detection 1. Hydrocarbon detectors with alarms. 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. Vessel to permit partial removal of the process inventory in the event of a release (e.g. dump tank) 4. Automated shutdown systems for specific process parameters (e.g., high temperature) 5. Curbing or diki ng 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 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., chemical protective clothing, self-contained breathing apparatus) 5. Blast-resistant buildings to help protect control systems and personnel FIVE-YEAR ACCIDENT HISTORY The ExxonMobil BRPO facility has not had any accidental releases during the past five years which meet the criteria for an accidental release per 40 CFR 68.42. EMERGENCY RESPONSE PROGRAM INFORMATION The ExxonMobil BRPO facility maintains a written incident response plan, which is in place to protect worker and public safety as well as the environment during an emergency. The plan consists of procedures for responding to a release of a regulated s ubstance, 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 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 plan is updated when necessary based on modifications made to plant processes. The emergency response program changes are administered through management of change process, which includes informing and/or tr aining affected personnel in the changes. The overall emergency response program for the ExxonMobil BRPO facility is coordinated with the East Baton Rouge, Emergency Planning Committee. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The ExxonMobil BRPO facility has around-the-clock communications capability with the appropriate LEPC officials and emergency response organization (e.g. fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the ExxonMobil BRPO facility conducts periodic emergency drills that involve the LEPC and emergency response organization, and ExxonMobil BRPO provides annual refresher training to local emergency responders regarding the hazards of regulated substances in ExxonMobil BRPO. PLANNED CHANGES TO I MPROVE SAFETY The ExxonMobil BRPO facility has several elements of the management system of the accident prevention program in place to improve safety throughout the facility. These elements are part of an overall ongoing safety improvement process. The following elements of the management system are present to improve safety. ? Process Hazard Analysis ? Management of Change ? Compliance Audits ? Job Observations ? Application to become a VPP OSHA Star Site |