Shell Martinez Catalyst Plant - Executive Summary |
|
SHELL MARTINEZ CATALYST PLANT (SMCP) Risk Management Plan 1. EXECUTIVE SUMMARY The Shell Martinez Catalyst Plant (SMCP) is committed to operating in a manner that is safe for its workers, the public, and the environment. As part of this commitment, Shell has established a system to help ensure safe operation of the processes at this facility. One part of this system is a risk management program (RMP) that helps manage the risks at the Shell Martinez Catalyst Plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at SMCP. This document is intended to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of the risk management program at SMCP. 1.1 Accidental Release Pr evention and Emergency Response Policies SMCP is committed to the safety of its workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. SMCP implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, trained personnel from SMCP and the Martinez Refining Company (MRC) will respond to control and contain such releases. SMCP evaluates each situation, evacuates workers as necessary, and contacts MRC and applicable local agencies (including the Contra Costa County Fire Department) to control and contain the release and to prevent and/or reduce the consequences of the release. SMCP, the Contra Costa County Health Services Department, and the Contra Costa County Fire Department have established a program to warn the community if an accident occurs that could threaten the community. 1.2 The Shell Martinez Catalyst Plant and Regu lated Substances The Shell Martinez Catalyst Plant has been in operation at its present location since 1930. It is located within the City Of Martinez (north of Marina Vista Avenue and the Martinez Refining Company) on approximately 11 acres of land. About 70 people work here making specialty liquid and solid catalyst products (using small batch processes). Our products are sold world-wide to a variety of industrial customers. They in turn make many products including ethylene glycol, polyesters, and detergents. Ethylenediamine (EDA), which is used in our EO Catalyst Process, is the only substance regulated by the RMP rule that is present above the EPA threshold quantity. The total potential EDA inventory is 87,000 pounds. Of this amount, 83,250 pounds could be present in a single tank. The EO Catalyst Process is a Program 3 process for RMP rule compliance purposes. It is the only substance regulated by the RMP rule that is present above the EPA threshold quantity. 1.3 O ffsite Consequence Analysis The Shell Martinez Catalyst Plant performed an offsite consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance (EDA) to affect the public or the environment. The OCA consists of evaluating both worst-case scenarios (WCSs) and alternative release scenarios (ARSs). SMCP does not expect a worst-case release scenario to ever occur. An ARS represents a release that might occur during the lifetime of a facility like SMCP. ARSs help the local emergency response agencies improve the community emergency response plan. We have shared that information with these and other organizations involved in emergency response activities. It is also available to the public. If you are interested in this information, please contact our RMP coordinator at 925-313-8687. The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public because of an accidental release (call ed the endpoint distance). The following effects could occur at the endpoint distance. At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effects would be less. o When considering the release of a toxic substance, most people at the endpoint distance would not experience any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely. Some people who are particularly susceptible to the substance released could be incapacitated. Worst-case Release Scenarios The worst-case release scenario for toxic substances is the complete failure of Tank 250 . This is our main 10,000 gallon storage tank for EDA and is located within a diked tank farm. This diked area contains the released EDA, which evaporates, forming a vapor cloud. The maximum distance to the toxic endpoint concentration (199 parts per million) is 695 feet or 0.13 miles. Various ind ustrial neighbors would potentially be affected. These neighbors include Tosco (Amorco Wharf), the Martinez Refining Company, Union Pacific Railroad, and the National Tree And Garden Company. No residential or environmental receptors are within this distance. Alternative Release Scenarios The ARS for EDA is rupture of a 2-inch diameter liquid process line from the EDA storage tank to the Solution Vessel. This scenario assumes that the EDA is completely released from the line for 10 minutes before workers detect the release and isolate the line. The released EDA forms a pool and the EDA evaporates from the pool, forming a vapor cloud. The maximum distance to the toxic endpoint concentration (199 ppm) 317 feet or 0.06 miles. The Union Pacific Railroad and National Tree and Garden would be impacted from this cloud. No residential or environmental receptors are within this distance. 1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps The following i s a summary of the general accident prevention program in place at the Shell Martinez Catalyst Plant. These elements are consistent with those required under the Occupational Safety And Health Administration (OSHA) Process Safety Management (PSM) standard. Employee Participation The Shell Martienz Catalyst Plant (SMCP) encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from 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 SMCP plant accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in a written employee participation plan that is maintained at SMCP and addresses each accident prevention program element. In addition, SMCP has a number of initiatives under way that address 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 The Shell Martinez Catalyst Plant (SMCP) 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, and equipment design basis/configuration information. Specific diciplines within SMCP 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 written SMCP PSM Compliance 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). 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, SMCP has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in a Key Process Parameter List (KPPL) Document. SMCP ensures that the process is maintained within these limits by using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). SMCP 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 The Shell Martinez Catalyst Plant (SMCP) 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. SMCP 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. The PHA team findings are forwarded to management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. They ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, SMCP 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 l onger 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 The Shell Martinez Catalyst Plant (SMCP) 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 reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and annually certified as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made through the management of change process. In addition, SMCP maintains a Key Process Parameter List (KPPL) Document that provides guidance on how to r espond 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, the Shell Martinez Catalyst Plant (SMCP) has implemented a company training program for all employees involved in operating a process. New employees receive basic training in SMCP plant operations if they are not already familiar 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) 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 traini ng 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. Contractors The Shell Martinez Catalyst Plant (SMCP) uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, SMCP 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 SMCP personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) in formation about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, SMCP evaluates contractor safety programs and performance during the selection of a contractor. SMCP plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) The Shell Martinez Catalyst Plant (SMCP) conducts a PSSR for any new facility or facility modification that requires a significant change in the process safety information. The purpose of the PSSR is to ensure 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 sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to ver ify 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 Shell Martinez Catalyst Plant (SMCP) 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 an MOC 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. SMCP 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 rep airs are made. Safe Work Practices The Shell Martinez Catalyst Plant (SMCP) 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 equipment 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 help ensure that operations and maintenance activities are performed safely. Management of Change The Shell Martinez Catalyst Plant (SMCP) 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 with any necessary training on the change. Incident Investigation The Shell Martinez Catalyst Plant (SMCP) 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 recurren ce of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to SMCP plant 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 reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Shell Martinez Catalyst Plant (SMCP) 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. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to SMCP plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. Chemical-specific Prevention Steps The processes at the Shell Martinez Catalyst Plant (SMCP) have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all Program 3 EPA RMP-covered processes at SMCP. 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, SMCP has safety features to help (1) contain/control a release, (2) quickly detect a release, and (3) reduc e the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release Detection o Process alarms Release Containment/Control o Valves to permit isolation of the process (manual or automated) o Automated shutdown systems for specific process parameters (e.g., high level, high temperature) o Curbing or diking to contain liquid releases o Redundant equipment and instrumentation (e.g., backup firewater pump, etc.) o Atmospheric relief devices Release Mitigation o Fire suppression and extinguishing systems o Deluge system for specific equipment o Trained emergency response personnel o Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 1.5 Five-Year Accident History No releases of EDA have occurred from the Shell Martinez Catalyst Plant (SMCP) in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, shelt ering-in-place, property damage, or environmental damage off site. 1.6 Emergency Response Program The Shell Martinez Catalyst Plant (SMCP) Company maintains a written emergency response program in conjunction with the Martinez Refining Company (MRC). This program 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 postincident cleanup and decontamination requirements. In addition, SMCP has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as in structions 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 SMCP and MRC plant processes or other SMCP/MRC facilities. The emergency response program changes are administered through the management of change process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for SMCP is coordinated with local agencies such as the Contra Costa County Health Services Department and the Contra Costa Fire Department. This coordination includes periodic meetings with industry, agency, and community representatives (coordinated through the Contra Costa CAER Group). SMCP/MRC has around-the-clock communications capability with appropriate emergency response organizations (e.g., Contra Costa County Health Services, Contra Costa Coun ty Fire Department, etc.). 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 CAER meetings, MRC conducts periodic emergency drills (with SMCP participation) that involve the various emergency response organizations in the area. In addition, SMCP provides annual refresher training to local emergency responders regarding the hazards of regulated substances at SMCP. 1.7 Planned Changes to Improve Safety The Shell Martinez Catalyst Plant (SMCP) constantly strives to improve the safety of SMCP processes through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers. SMCP resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned during the next 5 years: o Revised process instrumentation and/or controls in the EO Catalyst process area o Repla cement of one process furnace. o Revisions to personnel training programs. o Revised written operating and maintenance procedures. |