Chevron Phillips Chemical Company LP, Sweeny - Executive Summary |
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CHEVRON PHILLIPS CHEMICAL COMPANY LP SWEENY COMPLEX RISK MANAGEMENT PLAN EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Chevron Phillips Chemical Company LP Sweeny Complex has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training and consideration of safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement controls to prevent foreseeable releases of hazardous chemicals. However, if a release does occur, our trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES Chevron Phillips Chemical Company LP Sweeny Complex consists of eight operating units linked by multiple pipelines. The complex, near Old Ocean, Texas, is at the intersection of State Highway 35 and FM 524, about 60 miles southwest of downtown Houston. The complex also operates a terminal and a storage facility, along with the pipelines that connect this facility to the main plant and its markets. The complex produces 4.5 billion pounds of ethylene per year. In our process, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics: None Flammables: Normal Butane, Ethylene, Propane, Propylene, Ethane, 2-Butene-trans, 1-Butene, 2-Butene-cis, Butene, Isobutane, 2-Butene, Hydrogen, Isopentane, Methane, Pentane, 1,3- Butadiene, Propyne, Isoprene, 1-Pentene, Propadiene, 1,3-Pentadiene, 2-Pentene (E), Vinyl acetylene HAZARD ASSESSMENT RESULTS There are no toxic chemicals stored or used within the complex which are above the inventory limits as defined by the EPA. For this reason, Chevron Phillips Chemical Company LP has no worst case (WCS) and alternate release scenarios (ARS) for toxic chemicals entered in this Risk Managem ent Plan. The WCS associated with flammable substances is a vapor cloud explosion (VCE) involving 424,260 lbs of propylene from a fractionation column in Unit 33, an ethylene unit. This WCS assumes the entire inventory of this vessel is released, vaporizes and ignites, resulting in a vapor cloud explosion. Although there are several controls to prevent such releases and to manage their consequences, no credit for mitigation was taken into account in evaluating this scenario. The maximum distance to the 1 psi endpoint for this WCS is 0.6 miles (calculated using EPA's RMPComp). This scenario has offsite impacts. The ACS associated with flammable substances is a VCE involving a release of NGL (Propane, ethane, N-butane, isobutane, isopentane, N-pentane, heptanes plus, hexanes, methane, and n-hexane) which may be caused by yielding the NGL pipeline flow (feed to Unit 10.2) through the flare stack to the atmosphere while the flare is unlit. The modeling was based upon a relea se of 38,950 lbs. of NGL. Credit for active mitigation was taken into account in evaluating this scenario which was operator intervention. The maximum distance to the 1 psi (or lower flammable level) endpoint for this ACS is 0.3 miles (calculated using EPA's RMPComp). This scenario has offsite impacts. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the General Accidenal Releaset Prevention Program in place at the Chevron Phillips Chemical Company LP Sweeny Complex. Because processes at the plant regulated by the EPA RMP regulation are also subject to the OSHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the Accidental Release Prevention Program. EMPLOYEE PARTICIPATION Sweeny Complex management encourages employees to participate in all facets of risk management and accident prevention. Examples of employee participation range f rom updating and compiling technical documents and chemical information to participating as a member of a Process Hazard Analysis (PHA) team. Employees have access to all information created as part of the Sweeny Complex?s Accidental Release Prevention Program. Specific ways that employees can be involved in the Accidental Release Prevention Program are documented in the Employee Participation Element of the Sweeny Complex Process Safety Management System and in addition, Sweeny Complex has a number of teams to promote both process safety and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering and plant management. Three key areas for employee participation include the Employee Behavioral Safety Process (VIPER), Employee Safety Committee (ESC), and the Voluntary Protection Program (VPP) recertification committee. PROCESS SAFETY INFORMATION Sweeny Complex maintains a variety of technical docume nts that are used in the 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 the complex are assigned responsibility for maintaining up-to-date Process Safety Information. Process Safety Information reference documents are readily available as part of the written Employee Participation Plan 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). For specific process areas, the complex has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the unit-specific Process Safety Information (PSI) document. The teams verify the process is maintained w ithin these limits using process controls and monitoring instruments, highly trained personnel and protective instrument systems (e.g., automated shutdown systems). Sweeny Complex 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 confirm that safety features in the process are not compromised. PROCESS HAZARD ANALYSIS Sweeny Complex 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 verify that adequate controls are in place to manage these hazards. Sweeny Complex 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 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 being implemented in response to PHA team findings a re tracked until they are complete. The final resolution of each finding is documented and retained. To confirm that process controls and/or process hazards do not deviate significantly from the original design safety features, Sweeny Complex 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 Sweeny Complex 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 refe rence 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. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the Management of Change process. In addition, Sweeny Complex maintains a Process Safety Information document that provides 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, Sweeny Complex has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations if they are not already f amiliar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) that they have adequate knowledge to perform the duties and tasks in a safe manner, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to confirm their skills and knowledge are maintained at an acceptable level. All of this training is documented for each operator, including the means used to verify that the operator understood the training. CONTRACTORS Sweeny Complex uses contractors as part of its regular work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the plant has procedures in place to verify that contractors (1) perform their work in a safe manner, (2) have the appropriate kn owledge 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 their beginning work. In addition, Sweeny Complex evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to help ensure that contractors are fulfilling their safety obligations. Contractors regularly participate in facility emergency drills. PRE-STARTUP SAFETY REVIEWS (PSSRs) Sweeny Complex conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to confirm 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 certain 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 Accidental Release Prevention Program requirements are properly implemented. MECHANICAL INTEGRITY Sweeny Complex 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 ins pections 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 they can perform their job in a safe manner. Written procedures confirm work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to verify 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 an MOC Team will review the use of the equipment and determine what acti ons are necessary to verify the safe operation of the equipment. Another integral part of the Mechanical Integrity Program is quality assurance. Sweeny Complex 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. Sweeny Complex has developed a team-based defect elimination process known as TPM (Team Perfected Manufacturing). The objective of this employee-driven process is to eliminate equipment failures through predictive and preventive maintenance. As this process continues to mature, continuous and substantial improvement in operating reliability and safety is anticipated. SAFE WORK PRACTICES Sweeny Complex 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 Pr ocedure to verify isolation of energy sources for equipment undergoing maintenance, (3) procedures 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), (5) a permit and procedure to confirm adequate precautions are in place before entry into a confined space, and (6) a Safety and Emergency Systems Bypass Permit procedure. 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 Sweeny Complex has a comprehensive system to manage change. 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) verify 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 Sweeny Complex 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 Root Cause 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 plant management and respective Teams for resolution. Corrective actions taken in response to the investigation team ?s findings and recommendations are tracked until these actions have been resolved. 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 five years in order for these reports to be available for review during future PHAs and PHA revalidations. COMPLIANCE AUDITS Sweeny Complex periodically conducts compliance audits that include the following: Internal PSM and RMP Audits; Designated Self Audits (Safety and Health); and Process for Safety and Environmental Excellence (PSEE) Evaluations. Audit teams comprised of both hourly and management personnel conduct these audits. Audit findings are developed and presented to management for resolution. All responses to audit findings are tracked until resolution. All audits are retained for at least five years. RISK MANAGEMENT PROCESS In addit ion to the OSHA PSM elements described above, Sweeny Complex incorporates the elements of Chevron Phillips' Process for Safety & Environmental Excellence and OSHA?s Voluntary Protection Program in the Safety and Health process of the facility. The elements of these two management processes include the following: OSHA VPP ELEMENTS (VOLUNTARY PROTECTION PROGRAM) PSEE ELEMENTS (PROCESS FOR S/E EXCELLENCE) VPP (1) MANAGEMENT COMMITMENT AND PLANNING PSEE (1) ROLES AND RESPONSIBILITIES VPP (2) ACCOUNTABILITY SYSTEMS PSEE (2) TRAINING VPP (3) DISCIPLINARY PROGRAM PSEE (3) INDUSTRIAL HYGIENE & HEALTH VPP (4) INJURY RATES PSEE (4) EMPLOYEE OWNERSHIP VPP (5) EMPLOYEE PARTICIPATION PSEE (5) BEHAVIOR MODIFICATION VPP (6) SELF INSPECTIONS PSEE (6) STANDARDS & PROCEDURES VPP (7) EMPLOYEE HAZARD REPORTING SYSTEMS PSEE (7) ENGINEERING DESIGN VPP (8) ACCIDENT/INCIDENT INVESTIGATION PSEE (8) MEASUREMENT VPP (9) JSA/PROCESS REVIEW PSEE (9) AUDITS VPP (10) SAFETY & HEALTH TRAINING PSEE (10) CONTRACTOR PERFORMANCE VPP (11) PREVENTATIVE MAINTENANCE PSEE (11) INCIDENT INVESTIGATION VPP (12) EMERGENCY PROGRAMS/DRILLS PSEE (12) RISK MANAGEMENT VPP (13) PERSONAL PROTECTIVE EQUIPMENT PSEE (13) MECHANICAL & OPERATING INTEGRITY VPP (14) HEALTH PROGRAMS PSEE (14) COMMUNITY INVOLVEMENT VPP (15) SAFETY & HEALTH STAFF INVOLVED WITH CHANGES PSEE (15) REGULATORY ASSESSMENT AND ADVOCACY VPP (16) CONTRACTOR SAFETY PSEE (16) PRODUCT STEWARDSHIP VPP (17) MEDICAL PROGRAM PSEE (17) POLLUTION PREVENTION VPP (18) SAFETY AND HEALTH STAFF RESOURCES VPP (19) ANNUAL EVALUATION CHEMICAL-SPECIFIC PREVENTION STEPS The processes at Sweeny Complex have hazards that must be managed to help ensure continued safe operation. The Accidental Release Prevention Program summarized previously is applicable to all EPA RMP covered processes at the facility. Collectively, these prevention program activities help prevent potential accident scenarios that co uld be caused by (1) equipment failures and (2) human errors. In addition to the Accidental Release Prevention Program activities, Sweeny Complex has safety features on many processes to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release Detection Gas Detectors (Hydrocarbon) with Alarms Release Containment/Control Process Relief Valves that discharge to a flare to capture and incinerate episodic releases Valves to permit isolation of the process (manual or automated) Automated Shutdown Systems for specific process parameters (e.g., high level, high temperature, release detection) Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) Atmospheric Relief Devices Structural/Equipment Fire Proofing Relief Valve Maintenance Procedures RELEASE MITIGATION Fire Su ppression and Extinguishing Systems Deluge System for specific equipment Trained Emergency Response Personnel Personal Protective Equipment (e.g., protective clothing, self-contained breathing apparatus) Control Building is located outside of potential release areas Water curtains for specific equipment Siting and Spacing Initiative Emergency Isolation Valves Emergency Activation System Risk Based Inspection FIVE-YEAR ACCIDENT HISTORY During the past five years there has been one release of a regulated substance that required sheltering in place. And one accident which had property damage impacts. Every incident is carefully investigated to determine ways to prevent similar incidents from recurring. EMERGENCY RESPONSE PROGRAM INFORMATION Sweeny Complex 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 the following: 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, Sweeny Complex 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 inform ing and/or training affected personnel in these changes. The overall Emergency Response Program for Sweeny Complex is coordinated with the Brazoria 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. Sweeny Complex has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, Sweeny Complex conducts periodic emergency drills that involve the LEPC and emergency response organizations. In addition to the LEPC, the Sweeny Complex also has a Mutual Aid System in place. The Emergency Assistance Agreement Committee (EAAC) is a sub-committee of the Industrial CAER org anization in the Brazosport area. This system provides Mutual Aid from other industry members in the Brazosport area. In addition, the Brazoria Volunteer Fire Department and West Brazos Emergency Medical Service would provide assistance in the event of an emergency at the Sweeny Complex. The EAAC conducts emergency drills quarterly each year, hosted by a facility with the other member facilities participating. PLANNED CHANGES TO IMPROVE SAFETY Ongoing Facility Siting and Spacing Analysis Area Process and Perimeter Detection Analysis and installation Relief Valve and Relief Header Analysis and re-engineering Foundation of the HES employee excellence team VPP recertification Alarm management Work permit training Environmental awareness training PERMITS, EXEMPTIONS AND GENERAL DOCUMENTATION UNIT 10ABC Exemption No. X-3978 11-24-82 TACB Exemption for Debutanizer UNIT 10D Permit No. R-3073 1-18-77 TACB Operating Permit for Amine Regeneration Unit No. 3 UNIT 12 Permit No. 226 90 4-12-96 TNRCC Permit Alteration Ethylene Area Revisions Permit No. 22690 4-19-95 TNRCC Ethylene Area Permit Amendment UNIT 18 Permit No. 3040A 4-3-92 TACB permit No. 3040A Revision MAERT Correction Permit No. R-3040A 3-9-92 TACB Permit No. R-3040 Renewal for Polymer Grade Propylene Production and MA ERT Corrections Permit No. R-3040 1-4-77 TACB Operating Permit for Polymer Grade Propylene Production Permit No. C-3040 2-27-75 TACB Permit No. C-3040 Polymer Grade Propylene Production Facility UNIT 22 Permit No. 22690 4-12-96 Permit Alteration Permit No. 22690 4-19-95 TNRCC Ethylene Area Permit Amendment Permit No. 22690 3-8-94 TNRCC Operating Permit for Ethylene Unit 22 Permit Requirements 12-8-82 TACB Construction Renovation for Eight Furnaces UNIT 24 Exempt. No. 39026 8-27-98 Exemption Registration No. 39026 DAC Hydrotreater Revamp Permit No. 22690 4-12-96 TNRCC Permit Alteration Ethylene Area Revisions Permit No. 22690 4-19-95 TNRCC Ethylene Area Pe rmit Amendment (See Unit 22) UNIT 33 Permit No. 22690 4-12-96 TNRCC Permit Alteration Ethylene Area Revisions Permit No. 22690 4-19-95 TNRCC Ethylene Area Permit Amendment (See Unit 22) Permit No. PSD-TX-751M1 3-28-91 TACB Permit No. PSD-TX-751 Modification for Ethylene Unit |