BP Chemicals, Inc. - Executive Summary |
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BP Chemicals Inc., Lima, Ohio EPA Risk Management Plan - Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES We at BP Chemicals, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. 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 incident. DESCRIPTION AND REGULATED SUBSTANCES The BP Chemicals, Inc. plant is located at 1900 Ft. Amanda Road, Lima OH 45804 and is owned by BP Amoco, PLC. Adjacent t o this facility is PCS Nitrogen , Ohio, L.P. which is manned and operated by BP Chemicals, Inc. Our facility's primary activities encompass BP Lima Chemicals is a major producer of industrial chemical products. The plant's primary product, acrylonitrile, is manufactured by combining ammonia, propylene and air. Acrylonitrile is a key ingredient in synthetic fibers, plastics and nitrile rubber. Lima Chemicals also produces Barex , an acrylo-based resin which is clear, shatter-resistant, nearly impervious to oxygen and excels as a packaging material for many household and industrial products.A new process added to the Lima Integrated Complex is BDO. This process makes butanediol which is produced by oxidation of butane to maleic acid, hydrogenation of maleic acid to raw butanediol and purification of butanediol by distillation. Butanediol is used to make chemical/plastics that are used in the pharmaceuticals, auto parts, cosmetics and spandex fiber. We have 7 regulated substances present at our facility. These substances include Acrylonitrile [2-Propenenitrile], Hydrocyanic Acid, Propylene [1-Propene], Ammonia (anhydrous), Formaldehyde (solution), Sulfur dioxide (anhydrous) and butane. Acrylonitrile [2-Propenenitrile]is sold directly to outside customers and is used as a raw material for the Barex process. Hydrocyanic Acid [HCN]is a co-product produced in the acrylonitrile process and is used as a raw material for making a variety of chemicals. Propylene [1-Propene] is used for as a raw material for the production on acrylonitrile. Ammonia (anhydrous) is used as a raw material to combine with propylene for the production of acrylonitrile. Formaldehyde (solution) is used in a purification step for acrylonitrile co-product production. Sulfur dioxide (anhydrous) is used as a inhibitor for the purification and storage of hydrocyanic acid. Butane is used as a raw material for the production of butanediol. . HAZARD A SSESSMENTS The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario have been performed for all listed flammable and toxic chemicals at the facility. To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. A technical team consisting of seven local area chemical manufacturers and the City of Lima selected the basis for the scenarios. The team findings were communicated in public meetings in May of ?99. The following paragraphs provide details of the chosen scenarios. Worst Case Scenario The worst case scenario (WCS) for flammable substances is a vapor cloud explosion (VCE) with an overpressure endpoint of 1 pound per square inch (psi). The WCS endpoint is based on the instantaneous release of the entire contents of Propylene [1-Propene]/ Propane Mixtur e from a storage vessel resulting in a VCE. The effects of administrative controls, mitigation systems, and safety systems are not included in determining the effects of a VCE. Distances to the endpoint were calculated using the methodology outlined in EPA?s RMP Offsite Consequence Analysis Guidance. Nearby public receptors could be affected by this type of release. For this scenario the planned emergency response would be to have water sprays to minimize effects of fire and explosion hazards. BP Chemical has performed the WCS analysis as required by the rule, and has shared the results with the EPA and with the Allen County LEPC. Specific information on this release is presented in more detail in the plan. The worst case release scenario (WCS) submitted for Program 3 toxic substances as a class involves a catastrophic release from Nitriles Manufacturing. In this scenario Hydrocyanic Acid is released from a storage vessel. The toxic liquid released is assumed to form a 1 cm dee p pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The effects of administrative controls, mitigation systems, and safety systems are not included in determining the distance to the endpoint. At Class F atmospheric stability and 1.5 m/s windspeed. Public receptors would be affected by this type of release. For this scenario the planned emergency response would be to have water sprays and foam to minimize downwind effects. BP Chemical has performed the WCS analysis as required by the rule, and has shared the results with the EPA and with the Allen County LEPC. This release is unlikely due to the double-wall construction and high-integrity design of the tank and associated equipment. Specific information on this release is presented in more detail in the plan. Alternative Release Scenarios The alternative release scenario submitted for Program 3 flammable substances involves a release from Nitriles Manufacturing. The release is as sumed to result in a Vapor Cloud Explosion. The scenario involves a pipe leak that releases 45,000 lb. of Propylene [1-Propene] / Propane Mixture instantaneously. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.2 miles. Specific information on this release is presented in more detail in the plan. The alternative release scenario submitted for Program 3 toxic substances involves Hydrocyanic Acid and a release from Nitriles Manufacturing. The scenario involves the release of 560 lb. of liquid from a leaking pipe flange. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.011 mg/L of Hydrocyanic Acid is 0.4 miles. For this scenario the planned emergency response would be to have water sprays and foam the diked area to minimize downwind effects. Specific information on this release is presented in more detail in the plan. The alternative release scenario for Acrylonitrile [2-Propenenitrile] involves a release from Nitriles Manufacturing. The scenario involves the release of 3940 lb. of liquid acrylonitrile from leaking flange. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 60 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.076 mg/L of Acrylonitrile [2-Propenenitrile] is 0.2 miles. For this scenario the planned emergency response would be to have water sprays the diked area to minimize downwind effects. Specific information on this release is presented in more detai l in the plan. The alternative release scenario for Ammonia (anhydrous) involves a release from Nitriles Manufacturing. The scenario involves the release of 2000 lb. of ammonia from a leaking pipe. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.3 miles. For this scenario the planned emergency response would be to have water sprays to minimize downwind effects. Specific information on this release is presented in more detail in the plan. The alternative release scenario for Sulfur dioxide (anhydrous) involves a release from Nitriles Manufacturing. The scenario involves the release of 1080 lb. of sulfur dioxide from a leaking transfer line. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The e ntire pool is estimated to have evaporated after 60 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 0.1 miles. For this scenario the planned emergency response would be to have water sprays to minimize downwind effects. Specific information on this release is presented in more detail in the plan. The alternative release scenario for Formaldehyde (solution) involves a release from Nitriles Manufacturing. The scenario involves the release of 500 lb. of formaldehyde solution from a leaking pipe . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.012 mg/L of Formaldehyde (solution) is 0.3 miles. For this scena rio the planned emergency response would be to have water sprays the diked area to minimize downwind effects. Specific information on this release is presented in more detail in the plan. PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the BP Chemical, Lima plant. Our facility has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Because processes at the plant that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard this summary also addresses the OSHA PSM elements and describes the management system in place to implement the prevention program. Employee Participation The BP Chemical plant encourages employees to participate in all facets of process safety management and accident prevention. Exam ples of employee participation range from updating and compiling technical 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 prevention program. Specific ways that employees can be involved in the prevention program are documented in the employee participation plan that addresses each prevention program element. In addition the plant has a number of initiatives under way that address process safety and personal 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 operation, maintenance, engineering, and plant management. Process Safety Information The BP Chemicals, Inc. 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 k ey process parameters and specific chemical inventories, and equipment design basis/configuration information. Each process has documentation available showing the location of this information 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 exposure concerns and any known hazards associated with the inadvertent mixing of chemicals. For process areas. the plant has documented safety-related limits for specific process parameters (i.e. 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 (i.e. automated shutdown systems). In addition, information is available summarizing the consequences of deviation from these limits and the corrective actions to take. 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 ratings 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 BP Chemicals, Inc. 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 manag e these hazards. This plant 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 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. Any findings related to the hazard analysis are addressed in a timely manner. To help ensure that the process controls and or process hazards do not eventually deviate significantly from the original design safety features, this plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years as long as the process exist s. The recommendations from these updates are also forwarded to management. Final resolution of the recommendations is tracked, documented, and retained. Operating Procedures The BP Chemicals, Inc. 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 developed/revised by experienced operators as needed and provide a basis for consistent training of new operators. The procedures are periodically reviewed and annually certified as current and accurate. The procedures are revised as necessary to reflect changes made through the management of change process. Also safe operating limits are maintained to provide guidance on how to respond to upper or lower exceedences for specific process or equipment parameters. This information, along with the written operating proced ures, is readily available to the process operators and other personnel to use as necessary to safely perform their job tasks. The BP Chemicals, Inc. 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 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, and (4) 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 Training To complement the written procedures for process operations, the BP Chemicals, Inc. plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in chemical plant operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After the new operator demonstrates (i.e. through tests, skills demonstration, etc.) having adequate knowledge 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 three years. All of this training is documented, including the means used to verify that the operator understood the training. Contractors The BP Chemicals, Inc. plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equi pment, 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 process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to work starting. In addition, the BP Chemicals, Inc. 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 BP Chemicals, Inc. plant conducts a PSSR for any new facility or facility modifica tion that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, equipment, procedures, and personnel 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 BP Chemicals, Inc. 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) co nducting 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 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 (i.e. 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 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 BP Chemical, Inc. 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 Permit The BP Chemicals, Inc. plant has a hot work permit program which details those areas which require a permit and those areas for which a permit is not required. A permit is required in process areas for all cutting, welding, spark producing equipment, etc. except in designated areas. The procedure includes accountability and responsibility for authorizing and issuing the hot work permit, display of the permit at the site of the hot work until the work is completed, site inspection, d esignation of appropriate precautions to be taken with the hot work, and assignment of a fire watch where appropriate. Management of Change The BP Chemicals, Inc. 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 commissio ning of the change. Incident Investigation The BP Chemicals, Inc. 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 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 revie wed during future PHAs and PHA revalidation?s. Compliance Audits To help ensure that the accident prevention program is functioning properly, the BP Chemicals, Inc. 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 with internal audits conducted on an annual bases. Both hourly and management personnel participate as audit team members. The audit team develops 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. Five-year Accident History BP Chemicals, Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period that has affected the community. Over the past five years th ere have been other incidents where chemical releases have occurred but did not affect the local community. These are documented in our incident reporting system along with notification given to the proper governmental agencies. Information on these incidents are available at the facility from the RMP Coordinator (419-226-1200). CHEMICAL SPECIFIC PREVENTION STEPS The processes at the BP Chemical, Inc. plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA RMP covered processes at this facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. In addition to the accident prevention program activities, the BP Chemical, Inc. 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 (mitigat e) a release. The following types of safety features are used in various processes: Release Detection 1. Hydrocarbon detectors with alarm. Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases. 2. Scrubber to neutralize chemical releases. 3. Valves to permit isolation of the process (manual or automated). 4. Automated shutdown systems for specific process parameters (i.e. high level, high temperature) 5. Vessel to permit partial removal of the process inventory in the event of a process problem (i.e. dump tank) or a means of safely removing inventory (i.e. thermo oxidizer ) 6. Curbing or diking to contain liquid releases 7. Redundant equipment and instrumentation (i.e. uninterruptible power supply for process control system, backup firewater pump) 8. Atmospheric relief devices Release Mitigation 1. Fire suppression and extinguishing systems 2. Deluge systems for specific equipment 3. Trained emergency respons e personnel 4. Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 5. Mobile fire fighting equipment EMERGENCY RESPONSE PROGRAM INFORMATION The BP Chemicals, Inc. 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 BP Chemicals, Inc. 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 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 BP Chemcials, Inc. plant is coordinated with the Allen 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 BP Chemicals, Inc. plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., Shawnee Fire Department). T his 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 BP Chemical, Inc. plant conducts periodic emergency drills that involve the LEPC and emergency response organizations. The plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. PLANNED CHANGES TO IMPROVE SAFETY The BP Chemicals, Inc. plant resolves all findings from PHAs, some of which result in modifications to the process. In addition to meeting Process Safety Management requirements this plant location is committed to meeting OHSA?s Voluntary Protection Program (VPP), CMA?s Responsible Care and the ISO 14001 standard for Environmental Management Systems. Under the ISO 14001 standard and Responsible Care, CMA members are pledged to continually improve their over-all health, safety and environmental performance which includes redu cing vulnerability and risk potential. Further information on these programs are available at the facility from the Quality/Safety Systems Manager or the RMP Coordinator (419-226-1200). |