Infineum USA L.P. Bayway Chemical Plant - Executive Summary

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Executive Summary 
Risk Management Plan 
Infineum USA L.P. Bayway Chemical Plant 
Accidental Release Prevention and Response Policies 
The Infineum USA L.P.Bayway Chemical Plant has had a long-standing commitment to protecting their employees, the public, and the environment. This commitment is demonstrated by the resources invested in accident prevention such as: providing comprehensive initial and refresher personnel training, considering safety in the design, installation, operation, inspection, and maintenance of our processes, and conducting drills to respond to simulated emergencies. Our objective is to implement controls to minimize the potential for releases. However, if a release occurs, our trained personnel will respond to control, contain, and mitigate the leak. 
We prevent accidents using a structured safety management system entitled OIMPS, Operations Integrity Management PracticeS, and a Total Safety Culture in which all employees play a role in the prevention of incidents 
. Our Operations Integrity Management Systems are 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 recommendations from our hazard reviews and any incident investigations. 
The Bayway Chemical Plant has been recognized by the Occupational Safety and Health Administration (OSHA) as a VPP STAR Facility (Voluntary Protection Program - Safety Through Accountability and Recognition) for its effective safety and health management programs. Our plant has also mentored four other Linden businesses in achieving this select status. 
Description of the Stationary Source and Regulated Substances 
The Infineum Bayway Chemical Plant, located in Linden, N. J., operates several processes to produce additives for engine oils and transmission fluids. While the additive products are not regulated as hazardous by the EPA, some of our start 
ing materials are regulated as flammable or toxic. Our flammable materials are: ethane, propylene, 3-methylpropene, and mixed butane and butenes. Our regulated toxic materials are: ammonia, chlorine, hydrogen chloride, and vinyl acetate. In addition we have hydrogen sulfide and sulfur monochloride that are regulated substances under the New Jersey Toxic Catastrophe Prevention Act. 
Hazard Assessment Results 
The worst case scenario defined by the EPA for the toxic substances used at the plant is a release of a 90 ton railroad tank car of chlorine. Using the EPA modeling tool RMP Comp, this scenario would have offsite impacts. Although we have numerous layers of protection to prevent and mitigate such a release, no credit was taken for them in evaluating this scenario. 
The alternative release scenario for chlorine is a leak from the railroad tank car unloading pipe. Using the EPA modeling tool RMP Comp, this would have an offsite impact. We have automatic valves that close to stop an u 
nloading pipe leak when area leak detectors alarm or when operators signal them to close. Although these valves will limit the impact distance of a leak, the offsite distances reported in the submission take no credit for limiting the release in order to be conservative. 
The worst case scenario defined by the EPA for the flammable substances used at the plant is a vapor cloud explosion (VCE) of the largest process vessel, 5100 ft3, with a 60% level of mixed butanes/butenes. The full inventory is assumed to release, completely vaporize, ignite, and cause an explosion that would have an offsite impact, using the EPA modeling tool RMP Comp. Although we have numerous controls to prevent such a release and mitigate its potential consequences, no credit was taken for them in evaluating this scenario. 
The alternative flammable release scenario is a leak of mixed butanes/butenes from process piping which vaporizes, ignites, and explodes. This smaller explosion would not have an offsite impac 
t, using the EPA modeling tool RMP Comp. 
General Accidental Release Prevention Program 
The plant uses a structured system of Operations Integrity Management Practices (OIMP), which cover all aspects of our operations that could affect the safety or health of our employees or public neighbors. This system was developed by Exxon Chemical Company in 1992. Although the plant became part of a new company, Infineum, in 1999, OIMP continues to be the formal Operations integrity Program at the Bayway Chemical Plant. In 1997, Lloyd's Register Quality Assurance reviewed OIMP and evaluated it against the international standard for Environmental Management Systems (ISO 14001). After an extensive review, which included a number of Exxon facility audits, Lloyd's concluded that the "environmental components of OIMP 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 indus 
try leaders in the extent to which environmental management considerations have been integrated into the ongoing business process."  
The OIMP system meets all the requirements of OSHA Process Safety Management, The EPA Risk Management Program, and the New Jersey Toxic Catastrophe Prevention Act. The system also exceeds all regulatory requirements by incorporating periodic management review of performance measurements for each practice to evaluate whether each practice is working as planned and what improvements might be made. Our plant has received OSHA VPP STAR status in 1994. This coveted recognition is given to those plants who go through a rigorous OSHA audit and demonstrate that they both meet and go beyond the regulations. OSHA has awarded VPP Star status to only 300 facilities out of over 3 million that are subject to regulation. 
Each of the EPA RMP areas is described in greater detail below and in the Data Element Section. Due to the ongoing nature of our safety program, the  
dates associated with the various activities in our accident prevention program are constantly being updated. We selected May 1, 1999 as the date to begin collecting data. Consequently, most of the reviews conducted after this date are not reflected in the Data Element information. 
Employee Participation 
Infineum encourages employees to participate in all facets of process safety management and accident prevention. An annual plan is developed for employee participation. This includes weekly safety meetings for operations and maintenance personnel, weekly safety audits, and meetings of the Operations Integrity Committee (OIC). Employees also participate in the development and updating of operating and maintenance procedures and conducting Process Hazard Analyses (PHA). PHA's are also reviewed by the OIC, the results are available to employees, and follow-up is stewarded by the OIC. 
The OIC reports directly to the plant manager and is the final review on "safety" matters relating to f 
acilities and operations.  "Safety," in the current environment, encompasses a broad range of issues.  Not only is it necessary to provide for the well-being of the plant workers and equipment, but also to protect the community from any harm resulting from an in-plant incident.  The role and objectives of the OIC recognize this broader involvement.  The chairman of the OIC is the Manager of the Safety, Environmental and Risk Management (SERM) Department. OIC membership consists of representation from senior process design and technical personnel, industrial hygiene, environmental compliance, maintenance, plant operations, inspection and the plant safety coordinator. 
The general objectives of the OIC are as follows:   
Help anticipate hazards and work with operations to avoid them.  
Promote improvements in "safety" matters throughout the plant.   
Help develop and maintain a realistic and credible plant-wide Safety, Health and Environmental policy that reflects this broader definition.   
Monitor and provide continuity for Safety, Health and Environmental standards in facilities and procedures, and monitor progress in plant programs aimed at a more secure workplace.  These standards consist of the applicable codes and industry standards (e.g., Chlorine Institute) as well as Exxon's Design Practices and Mechanical Standards. 
Process Safety Information 
The Infineum Bayway Chemical Plant 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, specific chemical inventories, equipment design basis, and equipment configuration information. Specific groups within the plant are assigned responsibility for maintaining the information up-to-date. 
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS). 
The plant also ma 
intains 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, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities. This information is also used in evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. 
Process Hazard Analysis 
The Infineum Bayway Chemical Plant has a comprehensive program of Process Hazard Analysis (PHA). Within this program each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage the hazards. 
Infineum primarily uses a knowledge-based Hazard and Operability (HAZOP) analysis technique to perform PHA's. HAZOP analysis is widely 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. The team also makes suggestions for additional prevention and/or mitigation measures when they might be appropriate. 
The PHA team findings are provided to local management for resolution. Implementation of prevention/mitigation steps in response to PHA findings is based on the relative risk evaluation done by the PHA team. Potential accident scenarios with the greater assigned risk receive attention first. All PHA findings are tracked until they are resolved. The resolution of each finding is documented and retained. 
The plant updates and revalidates the hazard analysis for each unit every five years. 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. All units have had at least one PHA and most have already had a second. 
Operating Procedures 
The Bayway Chemical Plant maintains written procedures that address various modes of process operations, such as startup, shutdown, normal, and emergency operations. These procedures can be used as a reference by experienced operators, and they provide a consistent basis for training new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change system. 
The Bayway Chemical Plant has identified critical safe operating limits for process parameters such as temperature, pressure, levels, and compositions. This information along with written operating procedures is readily available to operators in the process an 
d to other personnel to use as necessary to safely perform their job tasks. 
Hot Work and Safe Work Practices 
The Bayway Chemical Plant has long-standing safe work practices in place to help ensure worker and process safety. All safe work practices are contained in the site Safety, Health, and Environmental Manual that is available electronically on every desktop personal computer. Examples of safe work practices include:  orientations for visitors, control of access of support personnel, energy isolation for equipment being worked on (lockout/tagout), procedures for the safe removal of hazardous materials before opening process piping/equipment (work permit), hot work permit/procedure to safely manage spark-producing activities, vehicle entry into process areas, confined space entry permit/procedure, and job safety analyses to identify and mitigate hazards associated with maintenance tasks. These practices (and others), along with training, form a system to help ensure that operation 
s and maintenance activities are performed safely. 
To compliment the written procedures for process operations, the Bayway Chemical Plant has implemented comprehensive training for all employees involved in operating a process. The process technician training program includes initial, classroom and on-the-job training for new hire and newly assigned technicians. Phase 1 of the program covers orientation and initial process training in a classroom setting.  Phase 2 relies on unit training manuals and provides a combination of classroom and field training.  Phase 3 is on-the-job training with a qualified technician. Final evaluation of the trainee includes a written test and an oral field walk-through.  Both are conducted by unit supervision.  New hires must complete all three phases of the program while newly assigned process technicians begin their training at Phase 2. 
Refresher training is provided through Safety Day, unit-specific refresher training, and weekly safety mee 
tings.  Safety Day serves as the annual 8 hour Hazmat technician refresher training for process technicians and general safety training, including:  Hands-on Fire Training, TCPA, DPCC and RCRA Refresher.  Unit-specific Refresher Training covers standard and emergency procedures, simulated emergencies, and a review of the MSDS EHS on the unit, and is conducted at least every three years. Respirator Fit and SCBA refresher training are done on an annual basis in the field in separate training sessions. All of this training is documented for each process technician, including the means to verify that technician understood the training. 
Work performed by contractors at Bayway is managed consistent with and is a part of the overall Operations Integrity Management Practices (OIMP).  Contractors are required to utilize the same procedures to perform work as Infineum employees. These procedures are documented in the Safety, Health and Environmental (SHE) manual.  Contractor admini 
stration procedures are developed, coordinated, and implemented by the Plant's Contractor Administration Team (CAT) made up of representatives from Safety, Training, Maintenance, Projects, Operations, Purchasing, and representatives from the contractor's workforce. 
Contractor Administration begins with the Contractor Selection Procedure. The procedure includes an annual qualification of contractors by the CAT that allows specific contractors to be considered for work.  This process includes a review of the Contractor's Safety Program as well as the Contractor's safety performance.  The review team also evaluates the Contractor's past performance in meeting training requirements, the effectiveness of their ongoing program to promote SHE awareness, and general feedback on work performance including input from the Bayway Safety Survey system. 
It has been the practice at Bayway to use union trained labor where craft skills are required.  Selected Contractors must then have agreements to  
utilize trained and qualified union labor that have received their craft training in state certified union craft training programs. 
Specific training for the individual contract worker is accomplished by a twofold approach of Contractor training and Owner Orientation. 
The Contractor, utilizing information provided by Bayway via the contract exhibit "Safety and Health Instructions for Contractors" and the SHE manual, inform, train, and evaluate each employee.  This training information includes familiarization with the hazards of regulated substances found at the Bayway Chemical Plant and the Emergency Response Plan.  Work procedures as prescribed by the SHE manual (e.g. Work Permit System) are also covered.  The contract employees are also requested to advise the appropriate Infineum associate of any unique hazards provided by their work or any hazards that they find while working.  The expected method for this communication is the Work Permit System.  In the [rare] occasions that a  
Contractor will perform work within the Preventive Maintenance Program, the Contractor is also required to train, inform, and evaluate the employee on this system. 
A record of this training and a certification that the Contractor has evaluated their employee is documented using the "Pre SHAIC Contractor Training Report". To gain admittance to the SHAIC training session, the Contractor employee must present the trainer with a completed "Pre SHAIC Contractor Training Report 
Prior to beginning work in the plant the Contractor employee must successfully complete the Bayway Safety Health Administrative Instruction for Contractors (SHAIC) training, which is the Owner's safety orientation session.  The SHAIC training is administered by the Plant contract coordinators.  
SHAIC training includes but is not limited to: 
Information on EHS and other plant hazards 
Plant Emergency Response and evacuation plan 
Work Permit System 
Alcohol and Drug Policy 
Other Infineum Chemical rules and regulations 
Pre-startup Safety Reviews (PSSR) 
The Bayway Chemical Plant conducts a PSSR for any project which introduces a new facility or substantially modifies an existing one. The purpose of the PSSR is to ensure that safety features, procedures, and the equipment are appropriately prepared for startup and personnel are trained prior to placing the equipment in service. This review procedure provides one additional check to make sure construction is in accordance with design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. 
Mechanical Integrity/Preventative Maintenance 
The Bayway Preventive Maintenance and Inspection Program is centered around a computer data base and software called Teroman.  The computer contains technical data on piping, fixed equipment, machinery, pressure relief devices, and instrumentation and specifies the preventive maintenance frequencies and procedures required for each 
individual piece of equipment.  Equipment breakdown and repair history are also recorded.  Some older historical records will remain in a paper-based file. 
Fixed equipment inspection intervals for all equipment are developed on a systematic basis that includes historical data and current non-destructive inspection results.  A quarterly inspection planning report is generated showing the equipment that is scheduled for inspection during the current year and what has not been completed yet. 
The fixed equipment inspection techniques in use are in compliance with our own and applicable industry standards. Inspectors are API 510 and 653 certified, while they also attend outside training courses to facilitate the implementation of new technology. Bayway holds an ASME Certificate of Authorization for use of stamp "U" and an "R" from the National Board of Boiler and Pressure Vessel Inspection. The inspection program ensures that all of the requirements necessary for approvals by the various 
code agencies and the National Board are maintained. 
Safety valves, rupture disks, pressure/vacuum vents and instrumentation systems designated as critical for either safety or environmental purposes are handled similarly in the Teroman system.  The intervals between inspection of these devices are set on the basis of criticality of service and analysis of the historical data.  The list of safety and environmentally critical instrumentation is periodically reviewed to ensure effective coverage.  Monthly reports are generated showing the status of equipment that is scheduled for inspection that month and year-to-date, and any equipment whose inspection may be overdue. 
Quarterly, S/H/E metrics are reviewed with the Operations Integrity Committee (OIC) in each operating area. Included is a review of the status of PM completion and fixed equipment inspection. 
A procedure is in place, which requires a Management of Change review Plant Manager's approval, in order to defer an inspection  
beyond the scheduled date. 
Another integral part of the mechanical integrity program is quality assurance. The Bayway Chemical Plant 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 repairs are made. 
Management of Change 
The Bayway Chemical Plant has a comprehensive system to manage changes to processes. This system requires that changes to process equipment, chemicals, technology (including process operating conditions), procedures and other facilities be properly authorized and reviewed. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and/or to verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, equipment information, procedures are updated to incorporate these changes. In addition, operating and mainte 
nance personnel are provided any necessary training before the change is implemented. 
Incident Investigation 
The Bayway Chemical Plant investigates all Safety and Environmental accidents and incidents.  Accidents are events that resulted in personnel injury, a reportable release/discharge or equipment damage.  Incidents are events that had the potential to be an accident (near miss). The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident, or a similar one. All accident and incident reports are documented and provided to the chemical plant management for resolution. All incident and accident reports, minor or major, are reviewed by the OIC. Corrective actions taken in response to an investigation are tracked until complete. Investigation results are reviewed with employees and contractors who could be affected by the findings. Reports are retained for at least five years to be reviewed during future PHAs and PHA  
Compliance Audits 
The Bayway Chemical Plant periodically conducts an audit of their accident prevention program, the Operations Integrity Management Practices (OIMP), to determine whether the procedures and practices of the program are being utilized. Audits are conducted at least every three years. Audit team findings are provided to the chemical plant management for resolution. Corrective actions taken in response to the findings are tracked until they are complete. The resolution of each finding is documented and at least the two most recent audit reports are retained. 
Chemical Specific Prevention Steps 
The above accidental release prevention program applies to all facilities at our plant, not just those covered by the EPA RPM. Collectively these prevention programs help prevent accident scenarios that could be caused by either equipment failures or human errors. 
In addition, specific features are incorporated in each process to prevent the release of regulated f 
lammable or toxic substances. The following features are among those used for specific processes. 
Process relief valves and rupture disks that vent to a flare system or a scrubber 
Check valves 
Scrubber to neutralize byproducts such as HCl. 
Flammable gas detectors with alarms for ethane and butanes/butenes. 
Toxic gas detectors with alarms for hydrogen sulfide, chlorine, hydrogen chloride, ammonia, and sulfur dichloride 
Automatically operated and manual valves to isolate and stop a leak. 
Computer control that automatically stops the process when high temperatures or pressures are detected. 
Curbing and diking to contain liquid leaks. 
Procedures to check for leaks before returning equipment to service after maintenance. 
Deluge system for butane/butene 
Emergency response procedures for specific chemicals. 
TV surveillance cameras 
Five Year Accident History 
The Infineum Bayway Chemical Plant has had no releases during the past five years that are reportable under this regulation. 
y Response Program 
Emergency response at the Bayway site is shared with our neighbor the Tosco Refinery.  The site maintains extensive fire-fighting equipment, a command post vehicle, two ambulances, numerous self-contained breathing systems and back-up air supplies, acid suits, rescue equipment, medical supplies, etc.  A well-equipped Chemical Plant team is trained to respond to site emergencies as well as transportation emergencies in the community as part of the CMA Chemnet/Chemtrec Programs.  The site Emergency Manual is very comprehensive.  It includes very specific procedures to deal with site-wide emergencies.  It also includes specific external notification instructions. 
Members of both staffs are trained in various phases of emergency response procedures and take part in competitions to test their skills against the best in the country.  A separate staff of trained emergency medical technicians are available 24 hours/day and trained medical resources is the Medical Departmen 
t is staffed about 50 hours/week and available on call 24 hrs/day.  Arrangements are in force with Elizabeth General Hospital to provide medical services at other hours. 
Periodic meetings are held with the Linden Fire Department to coordinate procedures and educate LFD officers about the site.  The LFD Commander who arrives at the site for any emergency will be escorted to the scene to communicate with the Bayway Commander, give advice and render an independent judgment of the situation. 
The Chem Plant Component I/Blending Shift Team Leader is in charge of any Chemical plant emergency until operations management arrives.  He has been trained to identify incidents that require agency notifications and has the authority to call out the Chem Plant Emergency Response Organization (ERO).  Assistance is available on-site from the Refinery Shift Superintendent and Refinery emergency resources, if needed. 
The ERO consists of the plant management and senior staff people in Risk Management, En 
vironmental, Technical, Medical, Industrial Hygiene, Public Affairs, Human Resources, Legal and Personnel Safety.  A manual is available to guide this group to the proper agency contacts.  It supplements the material in the site-wide Emergency Manual with additional information specific to chemical accidents.  Infineum is a member of the Linden Industrial Mutual Aid Council (LIMAC) through which it can obtain backup material in a major incident. 
An on-site meteorological station is available to provide data to help evaluate the consequences of any release of a regulated substance. 
Special communication systems and procedures are in place and are periodically updated to ensure that accurate information is available to both decision-makers and the public. 
Emergency response teams are exercised often.  Drills, involving outside agencies, are carried out to test coordination with public response groups. For example, in 1997 Infineum/Tosco hosted a combined CMA-sponsored site/community d 
rill and utilized of Dupont's specially designed rail car for the drill. Sixty-five guest observers and local responders attended. In addition, the plant participates in local emergency response planning activities, such as Hazardous Materials Advisory Council (HMAC) and the Linden LEPC.  Drills and actual emergency call outs are critiqued to further improve our system. 
Planned Changes To Improve Safety 
Changes that improve safety result from a variety of activities including: Process Hazard Analyses, risk assessments, safety tours, near miss reports, and employee suggestions. Recently completed and planned upcoming changes include: 
Remotely operated isolation valves on the ethane and ammonia compressors 
Hydrogen chloride area leak detector system 
New generation process control computers including increased redundancy for safety. 
Automatic shutdown of an H2S compressor due to high vibration.
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