BP Amoco Chemical Company - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The BP Amoco Texas City Chemical Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our plant adheres to process safety policies, guidelines, and best practices that have been developed based on company and industry experience over the years. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The BP Amoco Texas City Chemical Plant is located at 2800 FM 519 East, Texas City Texas 77590. The plant is owned by BP-Amoco PLC. The plant produces 4.5 billion pounds a year of petrochemical products including paraxylene, metaxylene, polybutene, polymer and chemical grade propylene, and styrene monomer. The plant contains nine operating units and three support units all of which are covered under the RMP rule. Of these process units, six of them qualify for Program 3 coverage. Six covered processes contain regulated flammable mixtures held above the threshold quantity of 10,000 pounds. The flammable mixtures contain various regulated substances such as but not limited to propane, propylene, butane, butene, ethylchloride, and ethylene. HAZARD ASSESSMENT RESULTS The RMP rule requires facilities to calculate worst case and alternative release scenarios for each regulated substance on-site. The purpose in calculating these types of scenarios is to encourage community dialogue on chemical accident prevention and risk reduction. The BP Amoco Texas City Chemical Plant has performed these calculations using the methodology given in the EPA's Offsite Consequence Analysis Guidanc e Document. The results of these calculations have been provided to the EPA and to the Texas City/LaMarque LEPC, and have been shared with members of the local community. The likelihood of these types of events is extremely remote. The BP Amoco Texas City Chemical Plant employs many layers of protection to reduce risk and to prevent chemical accidents. Flammable Worst Case Scenario: The worst-case scenario for a flammable substance would be a vapor cloud explosion resulting from an instantaneous failure of a propylene storage vessel. In calculating the potential impact zone, no credit was taken for administrative controls, or mitigation systems. The impact zone from such an event would extend beyond the boundaries of the plant. Flammable Alternative Release Scenario: The alternative release scenario (ARS) for a flammable substance is a vapor cloud explosion resulting from a release of propylene. The impact zone from such an event would extend beyond the boundaries of the plan t. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS Following is a summary of the general accident prevention program in place at the Texas City, Texas plant. Because processes at the plant that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation The Texas City, Texas chemical plant 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 plant accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participa tion plan. In addition, the plant has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming numerous 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 Texas City, Texas 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 and specific chemical inventories, and equipment design basis/configuration information. Operating areas within the plant 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 process safety overview information for each process to help employee s and visitors 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, the plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in a Safe Operating Limits Document. The plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). In addition, tables summarizing the consequences of deviation from these limits and the corrective actions to take are readily available. The plant also maintains technical documents that p rovide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, piping and instrument drawings, 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 Texas City, Texas plant 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. The Texas City, Texas plant exclusively uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analys is 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 reviewed by management for resolution. A written action plan is generated by management assigning responsibility and determining an expected completion date for each recommendation made during the HAZOP study. All approved mitigation options being implemented in response to PHA team findings are tracked in an electronic database 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 devi ate significantly from the original design safety features, the Texas City, Texas plant 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 longer operating. The results and findings from these updates are documented and tracked. 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 Texas City, Texas plant 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 are written by experienced operators or foremen as needed and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annual ly 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 process. In addition, the plant maintains a Safe Operating Limit Document that provides guidance on how to respond 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 Texas City, Texas plant has implemented a comprehensive training program for all employees involved in operating a process. Entry level standards have been set for new operators in conjunction with educational institutions. In addtion, new operators receive basic training in plant operations. After successfully completing this training, a new operato r is placed on shift with experienced personnel to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge and skills to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training 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 Texas City, Texas plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the ap propriate knowledge and skills, (3) are aware of the hazards in their work place, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the Texas City, Texas plant evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. The contractors are required to report all injuries to BP Amoco. Pre-startup Safety Reviews (PSSRs) The Texas City, Texas plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety i nformation. 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 verify 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 Texas City, Texas plant 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 proced ures and plans, (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 containment systems). 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. The Texas City, Texas 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. Safe Work Practices The Texas City, Texas plant 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 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 Texas City, Texas plant 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 any ne cessary training on the change. The system ensures that all documentation is updated and training completed prior to the commissioning of the change. Incident Investigation The Texas City, Texas plant 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 recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to 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) w ho 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 Texas City, Texas plant 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 have participated as audit team members. The audit team develops findings that are forwarded to 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 Texas City, Texas plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied not only to all Program 3 EPA RMP-covered processes at the Texas City, Texas plant, but to the entire facility. 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, the Texas City, Texas plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release Detection 7 Hydrocarbon detectors with alarms 7 An on-going fugitive emissions monitoring program Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases 2. Valves to permit isolation of the process (manual or automa ted) 3. Automated shutdown systems for specific process parameters (e.g., high level, high temperature) 4. Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump valve) 5. Curbing or diking to contain liquid releases 6. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 7. Atmospheric relief devices Release Mitigation 1. Fire suppression and extinguishing systems 2. Deluge systems for specific equipment 3. Trained emergency response personnel 4. Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 5. Mobile fire fighting equipment FIVE-YEAR ACCIDENT HISTORY The BP Amoco Texas City Chemical Plant has experienced no releases within the past five years that meet the EPA RMP reporting requirements with respect to on-site or off-site injuries or property damage. EMERGENCY RESPONSE PROGRAM INFORMATION The Texas City, Texas plant maintains a written emergency response program, which 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 post incident cleanup and decontamination requirements. In addition, the Texas City, Texas plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergen cy response program is updated when necessary based on modifications made to plant processes or other plant facilities. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Texas City, Texas plant is coordinated with the Texas City/LaMarque Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Texas City, Texas plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). 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 LEPC meetings, the Texas City, Texas plant conducts periodic em ergency drills that involve the LEPC and emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. |