Exxon Chemical Co. (Mont Belvieu Plastics Plant) - Executive Summary
EXXON Mont Belvieu Plastics Plant |
Risk Management Plan: Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
Exxon modified its safety programs in 1991 by implementing structured 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 Exxon to be among the industry leaders in the extent to which environmental management considerations have been integrated into its ongoing business processes."
The Exxon Mont Belvieu Plastics Plant (MB
PP) 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, such as personnel training and considering safety in the design, installation, operation, and maintenance of our processes. Our objective 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, contain and mitigate the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Exxon Mont Belvieu Plastics Plant, located in Mont Belvieu, Texas, U.S.A., operates a Low Density and a High Density polyethylene train. These two trains operate separately but share utilities and raw materials. MBPP has several regulated flammables, such as ethylene, butene-1, and isopentane. MBPP does not have any RMP regulated toxics on site. MBPP has two covered processes within the Low Density tra
in for the purposes of this plan. The HDPE Polyethylene train does not meet the minimum inventories for RMP covered flammables and is not part of this submission.
HAZARD ASSESSMENT RESULTS
The hazard assessments were done using the EPA supplied "look up tables" which have been incorporated into the computer program supplied by NOAA. This program is called RMPComp. This program uses all the parameters required by the RMP rule for both worst case (WCS) and alternate case (ACS) scenarios.
One of two WCS associated with a release of a flammable substance in Program 3 processes at MBPP is a vapor cloud explosion (VCE) involving the full inventory of the largest storage vessel containing butene-1. The full inventory is assumed to release, completely vaporize and ignite.
The second WCS assumes the entire contents of the ethylene pipeline releases and ignites resulting in a VCE. Although we have numerous controls to prevent such releases and manage their consequences, should one occur
, no credit for passive mitigation measures were taken into account in evaluating these WCS. These WCS both have an off-site impact.
One of 2 ARSs' for flammable substances at MBPP is a failure of a pipe on a butene-1 vessel followed by a VCE. This ARS has off-site impacts.
The other ARS for flammable substances at MBPP is a release of ethylene from a cut on an ethylene line followed by a VCE. This ARS also has an off-site impact.
EXTERNAL EVENTS ANALYSIS (Texas Gulf Coast)
MBPP is subject to external events, which may cause the release of hazardous materials. MBPP is designed and operated in such a way as to minimize the probability and the impact of such events. External events considered in the design and operation of the plant include, but are not limited to: security; temperature extremes; hurricanes; tornadoes; winds; precipitation & flooding; utility disruption; and year 2000 comp
Of particular interest is the hurricane susceptibility. MBPP was built in early 1980's and designed to the best wind technology available at the time. MBPP utilizes an Emergency Preparedness Plan with the latest weather tracking services to identify potential weather threats and take action to secure the plant days in advance of approaching storms.
Exxon has had a program in place for the past 18 months to identify and resolve Y2K related problems. This work is scheduled to be completed well before December 31, 1999 and we do not expect to have any significant Y2K related problems.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following is a summary of the general accident prevention program in place at MBPP. EPA's Program 3 prevention requirements were implemented because processes at MBPP meet Program 3 criteria and are also subject to the OSHA Process Safety Management (PSM) standard. In addition, Exxon Corporation has implemented Operatio
ns Integrity Management Systems (OIMS) at each of its operations worldwide that includes the aspects of EPA's prevention program and this summary describes OIMS. Further, 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 this RMP plan. Due to the ongoing nature of our safety programs, the dates associated with the various activities in our accident prevention program are constantly changing. We selected June 10, 1999 as the cutoff date for this information. Consequently, any of the reviews/updates conducted after that date are not reflected in the Data Element information.
MBPP 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 proc
edures to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the MBPP accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at MBPP and addresses each accident prevention program element. In addition, MBPP has a number of initiatives under way addressing 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
MBPP 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, an
d equipment design basis/configuration information. Specific groups within MBPP 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 OIMS documentation 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, MBPP has identified Operating Envelopes (Operating Directives); i.e. documented safety-related limits for specific process parameters such as temperature, level, and compositions. MBPP ensures that the process is maintained within these limits using computerized process control
s and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems, alarm systems).
MBPP 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 ensure that safety features in the process are not compromised.
Process Hazard Analysis
MBPP 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.
MBPP primarily uses the Knowledge Based Hazard and Operability (HAZOP) study that is an adaptation by Exxon Research and Engineering and Exxon 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 experience 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 necessary.
The PHA team findings are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk evaluation done by the PHA team. This evaluation helps ensure that potential accident scenarios assigned greater ri
sk receive attention first. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The resolution of each finding is documented and retained.
To ensure that the process controls and/or process hazards do not deviate significantly from the original design safety features, MBPP periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years for the life of the process. The results and findings from these updates are documented and retained. The team findings are forwarded to management for consideration, and resolution of the findings is documented and retained.
Operating Procedures and Safe Work Practices
MBPP maintains written procedures that address 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 of new operators. The procedures are kept 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.
MBPP 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.
MBPP 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 materials before process piping or equipme
nt 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 ensure that operations and maintenance activities are performed safely.
To complement the written procedures for process operations, MBPP 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 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) having 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. All of this training is documented for each operator, including the means used to verify that the operator understood the training.
MBPP uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, MBPP 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 MBPP personnel of any hazards they find during their work. This is accomplished by providing contract
ors 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, MBPP evaluates contractor safety programs and performance during the selection of a contractor. MBPP personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Reviews (PSSRs)
MBPP conducts a PSSR and or uses a Safety Close-out Checklist for any new facility or facility modification that requires a change in the process safety information that is controlled by management of change (MOC). The purpose of the PSSR is to ensure 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 sure construction is in accordance with the design specifications and that all supporting system
s 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.
MBPP 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 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 (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 the Safe Operating Committee 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. MBPP incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and
proper materials and spare parts are used when repairs are made.
Hot Work & Other Safe Work Practices
MBPP has long-standing safe work practices in place to help 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
MBPP has a comprehensive system to manage c
hanges 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 before the change is implemented.
MBPP promptly investigates all incidents that resulted in, or reasonably could have resulted in, a personal injury, gas release, fire/explosion, major property damage, or environmental loss. The goal of each investigation is to determine the facts and develop corr
ective 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 MBPP 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, MBPP 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 e
very 3 years. The audit team develops findings that are forwarded to MBPP 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 are retained.
CHEMICAL SPECIFIC PREVENTION STEPS
The processes at MBPP have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all covered processes at MBPP. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors.
In addition to the accident prevention program activities, MBPP 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. TV surveillance cameras
3. Operator rounds / surveillance
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. Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
4. Curbing or diking to contain liquid releases
5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)
6. Atmospheric relief devices
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
MBPP has an excellent record of
accident prevention over the life of the plant. There have been no accidents for the past 5 years, which are reportable under this regulation.
EMERGENCY RESPONSE PROGRAM INFORMATION
MBPP 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, MBPP 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 by the Risk Management Section and includes informing and/or training of affected personnel.
The overall emergency response program for MBPP is coordinated with the Mutual Aid Mont Belvieu (MAMB) and Chambers County Local Emergency Planning Committee. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. MBPP has around-the-clock communications capability with appropriate officials and emergency response organizations (e.g., City of Mont Belvieu Police Dept).
This provides a means of notifying the public of an incident as well
as facilitating quick response to an incident. In addition to periodic MAMB meetings, MBPP conducts periodic emergency drills that involve the MAMB organization.
PLANNED CHANGES TO IMPROVE SAFETY
MBPPs Operations Integrity Management Systems form 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 our reviews of operating and mechanical procedures systems, which are tightly integrated with our training programs.
CAA Title V COMPLIANCE
MBPP is covered under CAA Title V but will not file an application until 2000. For the RMP submittal MBPP has checked "yes" for "covered by Title V" and used the temporary Air Permit number given to MBPP by the TNRCC.
RMP COMMUNICATIONS AND CO
MBPP views RMP as an opportunity to build onto existing community outreach programs and open new and continuing dialogue with our neighbors. Our communications goal is to go beyond the requirements defined in the RMP rule. The RMP rule enabled us to educate and inform the Mont Belvieu community about the safety measures in place and the close working relationship we have with the local mutual aid infrastructure (MAMB), Mont Belvieu Police, and the Local Emergency Planning Committee (LEPC).
MBPP has committed to participating with 14 other local member companies of MAMB to communicate RMP broadly and openly. Through several MAMB RMP work groups, industry and citizen volunteers worked to develop a communication plan, which would provide industry an opportunity to communicate RMP throughout the community.
In Mont Belvieu, MBPP took the lead in coordinating a joint effort with other local chemical plants, citizen volunteers, the Mont Belvieu Mayor, and the Chambers Coun
ty LEPC to develop a program to communicate RMP to local citizens interested in RMP. Through the citizen volunteers, a communications plan was developed to conduct seven RMP briefings. MBPP participated in ten of eleven RMP briefings with the community and has been lead presenter during several. Feedback from the community has been positive.
For the 200+ employees on site at MBPP, the Risk Management Section Supervisor gave seven RMP presentations to employees so they could be informed and knowledgeable on the RMP rule.