Baker Petrolite - Bayport Facility - Executive Summary |
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Baker Petrolite Corporation is committed to operating the Bayport manufacturing facility and all associated processes in a safe manner for protection of the environment, the public population, and its' employees. Baker Petrolite Corporation has established a system to help ensure safe operation of the processes at this facility as part of this commitment. One part of this system is a risk management program (RMP) that helps manage the risks at Baker Petrolite and also compiles with the requirements of the Environmental Protection Agency's (EPA) regulation 40 CFR part 68, "Accidental Release Prevention Requirements: Risk Management Programs (RMP rule). A requirement of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management prepared for the Baker Petrolite Bayport facility. The purpose of this document is to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of the risk managment program at Baker Petroli te. Through the prevention of accidental releases of hazardous substances, Baker Petrolite is committed to the safety of its' employees, the public population, and the preservation of the environment. Baker Petrolite implements reasonable controls to prevent identifiable releases of hazardous substances. In the event of a significant accidental release, our trained personnel will respond to control and contain these releases. If a release event occurred, Baker Petrolite would evaluate the release, evacuate workers as required, contact the LaPorte police department (LEPC) dispatcher to inform them of the release, and prevent or reduce the consequences of the release. Baker Petrolite has established a program with the LaPorte local emergency planning committee (LEPC), LaPorte fire department, and the Channel Industries Mutual Aid (CIMA) to warn the community if an release occurs that could affect the community. Baker Petrolite is a specialty chemical manufacturer of chemi cal products for use in oil field production, refinery industrial chemicals, and chemicals used as additives for various end uses. With the production of many various types of chemical products, Baker Petrolite uses seven chemicals which are above the RMP threshold quantities. They include anhydrous ammonia, aqueous ammonia, ethylene oxide, propylene oxide, formaldehyde, ethylenediamine, and methyl chloride. All of the covered processes involving these chemicals are Program 3 processes for RMP rule compliance purposes. The following is a summary of the individual chemicals and the covered processes: 1. Anhydrous ammonia is stored in an anhydrous ammonia railroad tankcar designed for the storage of anhydrous ammonia and is used as a neutralization chemical agent in the production of chemical intermediates. The process inventory is 63,000 pounds. 2. Aqueous ammonia is stored in a pressure vessel type storage tank within dike containment. Aqueous ammonia is used as a neutraliz ation chemical agent in the production of chemical intermediates. The process inventory is 75,000 pounds of aqueous ammonia (22,000 pounds of ammonia). 3. Ethylene oxide is stored in two pressure vessel type storage tanks, each with individual dike containment. Ethylene oxide is used in the ethoxylation of chemical intermediates. The process inventory is 370,000 pounds. 4. Propylene oxide is stored in two pressure vessel type storage tanks, each with individual dike containment. Propylene oxide is used in the propyloxylation of chemical intermediates. The process inventory is 350,000 pounds. 5. Formaldehyde is stored in an aboveground vertical fixed roof storage tank. Formaldehyde is used in the production of chemical resin type intermediates. The process inventory is 140,000 pounds of formaldehyde solution. 6. Ethylenediamine is stored in an aboveground vertical fixed roof storage tank. Ethylenediamine is used in the production of chemical intermediates. The process inventory is 39,000 pounds. 7. Methyl Chloride is stored in a methyl chloride railroad tank designed for the storage of methyl chloride. Methyl chloride is used in the production of quaternary ammonium chemical intermediates. The process inventory is 64,000 pounds. Baker Petrolite has performed an offsite consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance to effect the public or the environment. The OCA consists of evaluating both worst-case scenarios (WCS) and alternative release scenarios (ARS). Baker Petrolite does not expect a WCS to ever occur. An ARS is a more realistic scenario that is more likely to occur than the WCS at a facility such as Baker Petrolite. The ARSs will help the LEPC to improve the community emergency response plan. We have shared this information with the LEPC and the general public through industry association roll-out events. If you are interested in this information, please contact our R MP coordinator at (281) 291-3286. The WCS for toxic substances is the failure of the anhydrous ammonia railroad storage vessel in the anhydrous ammonia process, resulting in a release of anhydrous ammonia over a 10-minute period. Because the Bayport facility is located in a populated area, the toxic cloud formed by the release will reach the offsite public receptors. The ARS for anhydrous ammonia is the rupture of a 2-inch diameter liquid unloading hose from the ammonia tank trailer to the anhydrous ammonia railroad storage car. This scenario assumes the anhydrous ammonia is released through the hole in the hose for 5 minutes. Because the Bayport facility is located in a populated area, the toxic cloud formed by the release will reach the offsite public receptors. Several industries and a residential subdivision exist within the range of the vapor cloud. The ARS for aqueous ammonia is the overfilling of the storage tank for a period of 30 minutes. This scenario a ssumes it will require this length of time for the plant personnel to stop the aqueous ammonia release. Because the Bayport facility is located in a populated area, the toxic cloud formed by the release will reach offsite public receptors. The ARS for ethylene oxide is the failure of an unloading hose resulting in a 1-inch diameter hole leak during unloading operations between the ethylene oxide railroad storage car and the storage tank. This scenario assumes it will require 30 minutes for the plant personnel to stop the ethylene oxide release. Because the Bayport facility is located in a populated area, the toxic cloud formed by the release will reach offsite public receptors. The ARS for propylene oxide is the failure of an unloading hose resulting in a 1-inch diameter hole leak during unloading operations between the propylene oxide railroad storage car and the storage tank. This scenario assumes it will require 30 minutes for the plant personnel to stop the propylene oxide release. Because the Bayport facility is located in a populated area, the toxic cloud formed by the release will reach offsite public receptors. The ARS for formaldehyde solution is the failure of an unloading hose resulting in a 1-inch diameter hole leak during unloading operations between the formaldehyde solution tank trailer and the storage tank. This scenario assumes it will require 30 minutes for the plant personnel to stop the formaldehyde solution release. Because the Bayport facility is located in a populated area, the toxic cloud formed by the release will reach offsite public receptors. The ARS for ethylenediamine is the failure of an unloading hose resulting in a 2-inch diameter hole leak during unloading operations between the ethylenediamine tank trailer and the storage tank. This scenario assumes it will require 30 minutes for the plant personnel to stop the ethylenediamine release. Due to the location of the ethylenediamine storage tank, the resulting vapor cloud will not leave the plant site even with the loss of the entire tank trailer load. The potentially effected population would be the individuals who work at the plant site. The ARS for methyl chloride is the rupture of a 2-inch diameter liquid unloading hose from the methyl chloride tank trailer to the methyl chloride railroad storage car. This scenario assumes the methyl chloride is released through the hole in the hose for 30 minutes. This scenario assumes it will require 30 minutes for the plant personnel to stop the methyl chloride release. Because the Bayport facility is located in a populated area, the toxic cloud formed by the release will reach the offsite public receptors. Several industries and a residential subdivision exist within the range of the vapor cloud. The following is a summary of the general accident prevention program in place at Baker Petrolite Bayport manufacturing facility. Because the processes at the B aker Petrolite Bayport plant regulated by the EPA RMP regulation are also subject to the Occuptional Safety and Health Administration (OSHA) process safety managment (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Baker Petrolite encourages plant employees to participate in all areas of process safety management and accident prevention. Employee participation ranges from updating technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. The employees have access to all information contained in the Baker Petrolite plant accident prevention program. One of the ways to address process safety and employee safety issues is in the monthly plant safety committee meetings. The committee consists of plant operators and management personnel. Baker Petrolite keeps a variety of technical documents that used to help maintain safe operation of the processes. Chemical specific information is provided in material safety data sheets (MSDS). The MSDS are maintained and located in the QC Laboratory building. Block diagrams on PSM covered processes are included in the Bayport PSM manual. Maximum intended inventories of PSM covered chemicals are included in the Bayport PSM manual. Safe designed upper and lower limits of pressure, flow, composition, and temperature for PSM covered processes are included in the Bayport PSM manual. The Baker Petrolite Bayport plant ensures the processes are maintained within these limits by using process controls and monitoring equipment, trained personnel, and protective instrument systems. An evaluation of consequences of deviation is included in Bayport PSM manual. The following information is maintained by the plant engineering department: materials of construction, piping and instrument diagrams, electrical classifications, relief valve design, ventilation system design, design codes and engineering standards employed in the plant, and safety system interlocks/suppression systems. A program is in place forr all process equipment to comply with recognized and generally accepted good engineering practices. Baker Petrolite has a comprehensive program to identify and control hazards associated with various processes. Each process is systematically examined to identify process hazards and ensure that adequate controls are in place to manage these hazards. Baker Petrolite uses the hazard and operability (HAZOP) analysis method to preform these systematic reviews. The HAZOP team consists of people who have operating, maintenance, and engineering expertise. The team identifies and evaluates hazards of the processes as well as accident prevention and makes suggestions for additional measures as needed. The team findings are then documented and all approved changes are implemented for corrective action. These periodic reviews are conducted on a 5 year cycle and will continue until the covered process is no longer operating. Again, the team findings are documented and retained. Baker Petrolite maintains written procedures for the manufacture of specialty chemicals. Each specialty chemical requires a specific "batch ticket" for the manufacture of that chemical intermediate or finished product. These "batch tickets" contain specific information on; reaction raw materials, quantities of raw materials, reaction conditions, and any chemical specific conditions for that chemical reaction. In addition to the "batch tickets", there are written plant standard operating procedures (SOP) which cover activities that are general in nature to a large number of common tasks. These SOPs cover general tasks such as; forklift operations, chemical storage tank filling, container storage, sampling procedures, housekeeping, and other activities common to many of the specialty chemical processes. Emergency shutdown instructions a re contained in the Bayport Production Standard Operating Procedure Manual. The "batch tickets" are reviewed after each batch to ensure they reflect current operating practices. Baker Petrolite has a company training program for all plant operations employees. New employees receive basic orientation training in plant operations regardless of their previous experience level. After successfully completing this training, the new operator is then assigned to a more experienced operator with job experience to perform the duties and tasks in the new job assignment. After the new operator can demonstrate the ability and knowledge (through oral and written testing) to perform the job in a safe manner on his own, he will begin to work alone. In addition, all operators periodically receive refresher training. Baker Petrolite uses a contractor who specializes in contract maintenance and other outside contractors for construction activities as required. Because the contractors w ork or near process equipment, there are procedures in place to ensure that contractors; perform their work safety, have sufficient knowledge and skills, are aware of the hazards in their work area, understand emergency procedures, follow site specific safety rules, and inform Baker Petrolite personnel of any hazards they find in the area. Baker Petrolite has written procedures both for the contract maintenance contractor and the other contractors performing construction projects. The contractor maintenance contractor employees must attend orientation sessions for plant specific procedures, chemicals used in the plant, and Baker Petrolite policies. There is a separate procedure for the construction contractors that covers plant procedures, safety rules, and emergency procedures pertaining to their work. In addition, Baker Petrolite evaluates prospective contractor safety programs and performance during the selection of a contractor. Baker Petrolite conducts Pre-startup safet y reviews for a new facility or facility modification that requires a change in the process safety information. This review provides an additional check to ensure construction is in accordance with design specifications to maintain process safety. Baker Petrolite has practices and procedures to maintain mechanical integrity of the process equipment at the Bayport plant. These procedures for inspections and maintenance are found in the several of the Bayport SOP manuals, namely; Maintenance SOP manual, Safety and Environmental SOP manual, and the Bayport Production SOP manual. Records for equipment inspections and testing are maintained by the Maintenance Department Supervisor. "Safety Priority" work orders are issued to correct problems or process defects. Baker Petrolite uses the following safe work practices to ensure worker and process safety: control of entry/presence/exit of support personnel, lockout/tagout procedures, procedure for safe removal of hazardous mater ials from process piping or equipment, hot work permit system, and confined space entry program. These procedures form a system to help ensure that operations and maintenance activities are performed safety. Baker Petrolite has a management of change (MOC) plan for handling changes to chemical processes in the plant. This system is describled in the Bayport Safety and Environmental and SOP manual. The approved MOC files are maintained in the plant engineering department. The MOC changes are communicated to the process operators on the production "batch tickets". Baker Petrolite provides training for the plant employees involved in processes where significant process hazards exist. The chemical processes at the Baker Petrolite Bayport plant have hazards that must be controlled to maintain safe operation. The prevention program previously summarized applies to all the Program 3 EPA RMP covered processes at the Bayport plant. These prevention program procedures help to prevent potential accident scenarios that could be caused by human or equipment failures. Baker Petrolite has safety equipment and features on all units to help contain or control a release and reduce the consequences of a release. The types of safety features used on various chemical process equipment for release detection are: hydrocarbon detectors with alarms, process alarms, and video monitors. The types of equipment features used for containment or control of releases are: porcess relief valves, tank scrubbers to control vessel or storage tank emissions, valves to permit isolation of process equipment, automated shutdown systems (high level, high temperature, no agitation) for specific process parameters, dike walls, backup electrical power generator for certain critical equipment, and backup firewater pumps. Baker Petrolite uses the following types of equipment for release mitigation: Fire suppression and extinguishing systems, firewater deluge system for specific processe s, trained emergency response personnel, and personal protective equipment. Baker Petrolite investigates all incidents that result in or could have resulted in a fire/explosion, toxic gas release, major property damage, personal injury, or environmental loss. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident. Corrective actions are taken in response to the team's findings. Incident investigation reports are retained for 5 years. To help ensure that an accident prevention programs is functioning properly, Baker Petrolite periodically conducts audits to determine whether accident prevention procedures and practices are working properly. Safety audits are conducted on an annual basis by the Baker Petrolite corporate Industrial Health, Environmental, and Safety (HS&E) department . Corrective actions are taken in response to the audit's team findings. No releases of the seven RMP covered ch emicals at the Baker Petrolite Bayport facility has occurred in the last 5 years that has resulted in any deaths, injuries, or significant damage on site or any known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site. Baker Petrolite maintains a written emergency response program for the protection of the plant employees, the public, and the environment. This program consists of procedures for responding to all types of releases including flammable and toxic chemicals. The emergency response plan covers all ascepts including first aid, medical treatment for exposures, evacuation plans, accounting for personnel after an evacuation, notification of local emergency response organizations, and the public in the event of a significant release. There are procedures for maintenance, inspection, testing, and use of emergency response equipment. Plant employees receive annual training in these procedures to maintain their specific em ergency response duties. The program is updated when necessary, based on personnel changes and plant process changes. The overall emergency response program is coordinated with the LaPorte LEPC. Baker Petrolite has 24-hour communications capability with appropriate LEPC and CIMA emergency response organizations. This also provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response. In addition to regular meetings (LEPC and CIMA), Baker Petrolite conducts periodic emergency drills that involve the emergency response organizations. Baker Petrolite constantly strives to improve the safety of the plant processes through periodic safety reviews, incident investigations, and by soliciting safety suggestions from the plant employees. The following types of changes are planned during the next 5 years: completion of installing concrete floors in the storage tank farm areas, adding spill control to the storm water ditch system, contin ued review and updating of personnel training and written operating procedures. |