Baker Petrolite Corporation - Sand Springs Plant - Executive Summary |
|
1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES We at Baker Petrolite Corporation 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. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeable, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. 2. THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED Our facility's primary activities encompass the manufacturing of oil field chemicals. We have eight regulated substances present at our facility that are over the threshold amount. The toxic substances include Anhydrous Ammonia, Aqueous Ammonia, Ethylene Oxide, Formaldehyde 50% solution, and Prop ylene Oxide. The flammable substances include 1-Butene, Isopentane, and Isopropylamine. The regulated substances are involved in several uses. Ammonia and Isopropylamine are used in acid neutralization reactions. Ethylene Oxide and Propylene Oxide are used in alkyloxylation reactions. Formaldehyde solution is used in the production of resins. 1-Butene and Isopentane are used in the production of a pipeline drag reducing agent. 3. THE WORST CASE RELEASE SCENARIOS AND THE ALTERNATIVE RELEASE SCENARIOS, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO To evaluate the worst case and alternative release scenarios, we have used the look-up tables and equations provided by the EPA in the Risk Management Program Guidance for Offsite Consequence Analysis. All of the scenarios used urban site topography. The Worst Case Scenarios assume Class F atmospheric stability and a wind speed of 1.5 m/s. The Alternate Release Scenarios assume Class D atmospheric stability and a wind speed of 3 m/s. The worst case scenario submitted for toxic substances as a class involves a catastrophic release of Ethylene Oxide. The scenario involves the release of 128,775 pounds of Ethylene Oxide in a gaseous form over 10 minutes. Passive mitigation controls such as dikes were not used, as this feature would be ineffective for the gas release. One alternative release scenario will be submitted for each of the five toxic substances present. The alternative release scenario for Ethylene Oxide involves a release from a relief valve on one of the oxide reactors. The Ethylene Oxide storage tanks were not used for the ARS since the tanks have gas detectors and an automatic deluge system and there would be minimal release of Ethylene Oxide to the atmosphere. Assume 10 minutes for the release time, as plant personnel should be able to identify the cause of the relief valve opening very quickly and stop the Ethylene Oxide flow to the reactor from either the pump itself or from inside the control room. The release rate would be 80 pounds/min. This is the typical maximum flow rate of Ethylene Oxide from the charge pumps. The alternative release scenario for Anhydrous Ammonia assumes that a 2" transfer hose breaks during unloading. Assume 30 minutes for responders to identify leak, change into appropriate PPE, and isolate the leak. The release rate would be 7,500 pounds/min. The alternative release scenario for Aqueous Ammonia also assumes that a 2" transfer hose breaks during unloading. Assume 10 minutes for responders to identify and isolate leak. The liquid release rate would be 1,377 pounds/min., with the total quantity of liquid released being 13,770 pounds. Using a maximum pool area of 7,574 sq. ft., the release rate from the pool is estimated to be 345 pounds/min. The alternate release scenario for Formaldehyde, 50% solution assumes a leak off a line of the storage tank. Assume the hole is 1/2" in diameter, the liquid level in the tank is 157", and that the response time is 30 minutes for the leak to be discovered and stopped. The liquid release rate would be 136 pounds/min, with the total quantity of liquid released being 4,077 pounds. Using a maximum pool area of 1,794 sq.ft., and the LFB for the pure substance, the release rate from the pool is 126 pounds/min. Only the first 10 minutes of evaporation were considered as the release rate would decrease rapidly as the substance evaporates and the concentration decreases. The alternate release scenario for Propylene Oxide assumes a leak off a line of the storage tank. The largest storage tank, T-255, is not in a diked area, nor does it have gas detection or a deluge system. The Propylene Oxide is stored at 65 psig. Assume the hole is 1/2" in diameter. The highest level in the tank is 100". Assume a release time of 10 minutes for the leak to be discovered and stopped. The liquid release rate would be 381 pounds/min, with the total quantity of liquid released being 3,810 pounds. The evaporation rate from the maximum pool area is 502 lb/min. Since that rate is higher than the actual liquid release rate, use the liquid release rate of 381 lb/min. The worst case scenario for flammable substances as a class involves a catastrophic release of Isopentane from a railcar. The amount of Isopentane released is 156,900 lbs. The alternate release scenario for flammable substances as a class involves a release of Isopentane during unloading operations. Isopentane is transferred from a railcar to a storage tank by pressuring the railcar to 45 psig, and is then sent through chemical hoses and hard piping to the storage tank. Assume it would take 10 minutes for responders to discover the release and shut off the flow. The liquid release rate would be 67 lb/min, with a total liquid quantity of 670 lbs. The release would take place in an undiked area. The release rate from the pool is calculated to be 1 78 lb/min. Since this is larger than the liquid release rate, use the liquid release rate to estimate the endpoint. 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. A number of processes at our facility are subject to 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 for the release prevention program that is in place at our stationary source. PROCESS SAFETY INFORMATION - Baker Petrolite Corporation maintains a detailed record of safety information that describes chemical hazards, operating parameters, and equipment designs associated with all processes. PROCESS HAZARD ANALYSES - 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 the HAZOP method. The studies are undertaken by a team of qualified personnel with expertise in engineering, plant operations, and maintenance. Employees get to make suggestions to improve the safety and environmental operation of their work environment. The analyses are reviewed and revalidated 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, Baker Petrolite Corporation maintains written operating procedures. These procedures address normal operations, including startup, shutdown, and emergency operations. The information is regularly reviewed and is readily accessible to operators involved in the process. Baker Petrolite Corporation is an ISO 9001 certified facility. This requires the facility to keep up-to-date proced ures on all of our operating procedures. There are regular audits from both internal and external auditors. TRAINING - Baker Petrolite Corporation 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. Also, in excess of 150 hours per year are spent in operational, safety, and environmental training by every plant employee. This includes offsite fire training where simulations are real and the employee must learn to react quickly to protect himself, his fellow employee, and property from harm. In addition, Baker Petrolite Corporation has supported and sponsored training for members of the local fire department for many years. MECHANICAL INTEGRITY - Baker Petrolite Corporation carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes pressure vessels, storage tanks, pipin g systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Baker Petrolite Corporation also participates in a quarterly leak detection and repair program. Maintenance operations are carried out by qualified personnel with training and experience in maintenance practices. Furthermore, these personnel are provided specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Baker Petrolite Corporation also has a vessel inspection program that checks the vessel thickness of our reactors on a regular basis. This program was started in September 1998. MANAGEMENT OF CHANGE - Written procedures are in place at Baker Petrolite Corporation 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 provide d training to deal with the modification. PRE-STARTUP SAFETY REVIEWS - Pre-startup 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 Corporation conducts internal 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 three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. INCIDENT INVESTIGATIONS - Baker Petrolite Corporation promptly investigates any incident that has resulted in, or could have resulted 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 action to prevent the release from reoccurring. All reports are maintained 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 encourage to express their vies 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. There is an on-site Safety Committee composed of employee representatives from each plant operating area and chaired by the Site Safety and Health Manager. The committee meets monthly and conducts an audit of a different operations area as part of its activities. Recommended improvements are submitted to the plant manager and monitored by the committee for implementatio n. 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 to 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. Contractors are required to provide a written safety program which contains specific safety policies for the type of work they will perform. They must also certify that their employees have been trained and equipped as required by applicable federal, state, and local regulations. Contractors are required to advise plant personnel of specific hazardous processes or materials involved in their work. 5. FIVE-YEAR ACCIDENT HISTORY Baker Petrolite Corporation has had an excellent record of preventing accidental releases of RMP regulated substances over the past five years. Due to our stringent release prevention policies, there have been no accidental releases which have resulted in injury requiring off-site medical care to an employee or area resident or significant damage to property over this period. 6. EMERGENCY RESPONSE PLAN Baker Petrolite Corporation 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. Closer cooperation with area municipal and county emergency management authorities and other regulated firms in the community to develop mutual support procedures, purchase of new industrial hygiene monitoring equipment, expanded employee safety and health training, and participation in community outreach activities are some of the major steps we are taking to improve safety at our facility. These changes are being implemented during 1999. |