Baker Petrolite Corp. Midland - Executive Summary |
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General Executive Summary for Baker Petrolite Corporation Midland, Texas 1. Accidental Release Prevention and Emergency Response Policies We at Baker Petrolite Corporation in Midland, Texas are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with Midland Fire Department which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Distribution center for oil service chemicals. We have one (1) regulated substances present at our facility. This substance is Acrolein [2-Propenal]. Acrolein [2-Propenal] is used for H2S Scavenger & FeS Scavenger. The maximum possible inventory of Acrolein [2-Propenal] at our facility is 18,000 lb. The daily average is generally much less. 3. 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 To perform the required offsite consequence analysis for our facility, we have used the ALOHA model purchased from the National Safety Counsel. Local emergency planners, including LEPCs and fire department use this program. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from Acrolein Storage. The scenario involves the release of 370 lb. of Acrolein [2-Propenal]. Toxic liquid is ass umed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The alternative release scenario for Acrolein [2-Propenal] involves a release from dedicated acrolein cylinder in the Acrolein Storage process. The scenario involves the release of 370 lb. of Acrolein [2-Propenal]. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility in Midland, Texas has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stati onary source. Process Safety Information Baker Petrolite Corporation in Midland, Texas maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is HAZOP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of at least 1 year or anytime there is a change in the process. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Baker Petrolite Corporation in Midland, Texas maintains written operating procedures. The facility in Midland, Texas has train ing on loading and unloading of cylinders every year. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Baker Petrolite in Midland, Texas has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 2 years and more frequently as needed. Mechanical Integrity Baker Petrolite in Midland, Texas carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, piping systems, relief and vent systems. Qualified personnel carry out maintenance operations with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Baker Petrolite in Midland, to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Baker Petrolite Corporation. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Baker Petrolite located in Midland, Texas conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Baker Petrolite Corporation promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Baker Petrolite Corporation located in Midland, TX., truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Baker Petrolite Corporation has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Baker Petrolite Corporation in Midland 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 at our location. 6. Emergency Response Plan Baker Petrolite in Midland, TX. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Will store more neutralizer, coordinate more with our neighbors, LEPC, Midland Fire Department and local neighbors. These changes are expected to be implemented by 01/2000. |