Baker Petrolite - Rayne Facility - Executive Summary |
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General Executive Summary for Baker Petrolite Corporation Rayne, Louisiana 27833 LADEQ Facility ID Number 1.Accidental Release Prevention and Emergency Response Policies As employees of Baker Petrolite Corporation, we are strongly committed to safety, for ourselves, our neighbors, and the environment. We strive daily to operate our facility and handle our products in the safest manner possible, consistent with prudent environmental, health, and safety practices. It is our policy to implement appropriate controls wherever possible, to prevent the unwanted release of any regulated substance. We have a comprehensive accidental release prevention program in place that covers the key elements of design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. In the unlikely event that a release ever does occur, we have our own fully equipped HAZMAT team which is trained in emergency response. This HAZMAT team will work d iligently with the Rayne fire department and other emergency response personnel to control and minimize the effects of any release. As members of CMA and SOCMA, we believe in Responsible Care, which includes the CAER code, Community Awareness and Emergency Response. So, even though not required by any regulation, we installed a state of the art emergency response system to protect our community in the event of a release. This emergency response system guards the acrolein storage area, and includes a containment wall, chemical detectors, a deluge system, plus foam and neutralizer which would deactivate or minimize any release. 2.The Stationary Source and the Regulated Substances Handled Our facility is a small blend plant, which produces and distributes oilfield production chemicals. We store one (1) regulated substance at our facility. This substance is Acrolein [2-Propenal], which is used as a biocide, or as a hydrogen sulfide scavenger/antifoulant in the treatment of prod uced oil field water. Our average daily inventory of Acrolein is 25,000 lbs and the maximum is 30,000 lbs at the Rayne facility. 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 TRACE modeling program developed by SAFERb. The following information provides 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. Specifically, the scenario involves the release of 2,450 lb. of Acrolein [2-Propenal]. Toxic liquid is assumed to be immediately released to form a pool 1 cm in height, from which evaporation takes place. The alternative release scenario for Acrolein [2-Propenal] involves a release from a dedicated acrolein skid in the Acrolein Storag e process. The scenario involves the release of 2,450 lb. of Acrolein [2-Propenal]. Toxic liquid is assumed to be immediately released to form a pool 1 cm in height, from which evaporation takes place. Since acrolein is water soluble, the acrolein storage area is equipped with a deluge system to solubilize and dilute a release, and thus reduce evaporation. This alone will minimize the extent of the plume. In addition, foam is available for vapor suppression. Plus, an adequate supply of neutralizer is stored in the area, which can be released to deactivate the acrolein. 4.The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. Our facility is subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sect ions briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information The safety coordinator at the plant 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 primary 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 least every five years. 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, we maintain written operating procedures. These procedures address unloading, transport, storage, and loading of acrolein cylinders and skids. The information is reviewed regularly and is readily accessible to operators involved in the processes. Training Baker Petrolite Corporation has a comprehensive training program in place to ensure that employees are competent in the operating procedures associated with various plant processes. Refresher training is provided at least every year and more frequently as needed. Training provided to employees at the Rayne facility includes required core safety training as defined by OSHA, plus additional training such as Environmental Awareness. Plant employees also attend defensive driving classes taught by a certified instructor from Acadiana Safety Association bi-annually, plus Driving Safety. First Aid/CPR training is provided annually by qualified Emergency Medical Technicians from the Crowley Fire Department. HAZMAT training is provided annually to designated employees by our contracted emergency responders, Boots and Coot s Code 3. This training includes classroom instruction plus a simulated emergency response scenario. Mechanical Integrity Baker Petrolites employees perform 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, excess flow valves and lifting devices. Maintenance operations are conducted by qualified personnel who have received previous training in safe and effective 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 our facility 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 all Baker Petrolite locations. These reviews are conducted at each site to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Baker Petrolites corporate safety group conducts audits on a regular basis to determine whether the provisions set out under the PSM and 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 addressed in a safe and prompt manner. Incident Investigation Qualified Baker Petrolite employees promptly investigate any incident that has resulted in, or could reasonably result in a catastrophic release of a regula ted substance. These investigations are conducted by teams at several levels of the organization as directed by the Vice President of Oilfield operations. The investigations are designed to identify the root causes of incidents, and identify corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Baker Petrolite Corporation 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 facilitys implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors If necessary, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, we conduct a thorough evaluation of their safety performance. Only those who meet strict acceptance criteria are authorized to enter the facility. The Rayne facility routinely informs the contractors of known potential hazards related the contractors work and plant processes. Contractors are also informed of the procedures for emergency response should an accidental release of a regulated substance occur. 5.Five-year Accident History The Rayne blending facility has an excellent safety record over the last 5 years, with no accidental releases occurring during this period. In fact, because our employees use safe work practices in their day to day work, no accidental release of acrolein has occurred at the Rayne plant since the material was first stored on site in 1983. It is our policy to strive for continous improvement in our operations, and this has led to more stringent release prevention policies, and more elaborate emergency response plans. Because of this, we hope to prevent a releas e from ever occurring. However, we are realistic enough to plan our emergency response for even the most unexpected release scenario. Therefore, we expect to be able to control and minimize a release, should one ever occur. 6.Emergency Response Plan Baker Petrolites Rayne facility has 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 opportunities for improvement have been identified during our impleme ntation of the accidental release prevention program. We plan to upgrade our existing emergency response system to include a contingency plan for after hours notification of the plant Emergency Coordinator, Plant Manager, and/or the fire department. In addition, an emergency bypass for the neutralizer application system will be installed, to eliminate potential problems due to a power outage. We also plan to strengthen our relationships with the local Fire Department and the LEPC. These changes are expected to be implemented by August 1999. Our systems are focused on continual improvement in the prevention of accidents and pollution, effective communications and training, and accountability throughout the organization. In line with our goal of continuous improvement, we plan to build on our existing good relationships with our close industrial neighbors, and the community. |