Intercontinental Terminals Co.-Anchorage Terminal - Executive Summary |
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INTERCONTINENTAL TERMINALS COMPANY ANCHORAGE CHEMICAL TERMINAL EXECUTIVE SUMMARY 19556 LDEQ FACILITY ID NUMBER ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Intercontinental Terminals Company's Anchorage Chemical Terminal (ACT), located in Port Allen, LA, modified its safety programs in 1991 by adopting a concept of structured safety management systems entitled, "Operations Integrity Management Systems (OIMS)." The Anchorage Chemical Terminal utilizes a formal program of operations integrity along with the Chemical Manufacturers Association (CMA) Responsible Care initiative to assure proper design, operation, maintenance, inspection, work permits, change management, and emergency response in a proactive effort to minimize risk to the public, environment, and the plant. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Anchorage Chemical Terminal emplo ys 20 associates who live and work in the Baton Rouge, LA area. In business at the same location since 1977, the company is a quality bulk storage/distribution facility for propylene and butadiene. Butadiene is shipped to companies around the United States, who in turn use the chemical to produce products such as tires, automotive parts, roofing materials, wire and cable coating, etc. Propylene, which is shipped to companies in Texas, is a key ingredient used to produce plastic and rubber products. Intercontinental Terminals Company has two chemicals in threshold quantities affected by the rule - 1,3 butadiene and propylene. HAZARD ASSESSMENT RESULTS The hazard assessments were done using the EPA supplied "look-up tables" for the Worst Case Scenarios (WCS) and Alternate Release Scenarios (ARS). The WCS for flammables is the total release of the entire contents of 1,3 butadiene from a refrigerated tank. The entire volume is assumed to vaporize instantaneously and ignite, resul ting in a vapor cloud explosion. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this WCS. This WCS has offsite impacts. The ARS involves the failure of a gasket on the 10" tank suction line on a butadiene storage tank. The ARS has the potential for limited offsite impact. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general Accident Prevention Program in place at the Anchorage Chemical Terminal. EPA's Program 3 prevention requirements were implemented because some processes at the plant meet Program 3 criteria and are also subject to the OSHA Process Safety Management (PSM) standard. In addition, Intercontinental Terminals Company has implemented Operations Integrity Management Systems (OIMS) at the Anchorage Chemical Terminal that includes the aspects of EPA's prevention program and this summary describes OIMS. Further, OIMS has been attested as equivalent to ISO 14001 as a valid management system to oversee the implementation of the risk management activities. EMPLOYEE PARTICIPATION The Intercontinental Terminals Company encourages associates to participate in all facets of process safety management and accident prevention. Examples of associate participation range from updating and compiling operating and maintenance procedures to participating as a member of a Process Hazard Analysis (PHA) team. Associates have access to all information generated from HAZOPs and Site Risk Assessments. In addition, the plant has a number of initiatives underway that address process safety and associate safety issues via the ACT Safety Committee which is comprised of site personnel and selected contractors. PROCESS SAFETY INFORMATION The Anchorage Chemical Terminal keeps a variety of technical documents that are used to help maintain safe operation of the precesses. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. The ACT Terminal Manager is responsible for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the OIMS documentation to help associates 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 (MSDS). 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 identified operating envelopes, i.e., documented safety related limits for specific process parameters such as temperature, level, and compositions. The plant ensures that th e process is maintained within these limits using computerized process controls and monitoring instruments, highly trained personnel, and protective instrument systems (i.e., automated shutdown systems, alarm systems). The plant 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 form evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. PROCESS HAZARD ANALYSIS The Anchorage Chemical Terminal has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is system atically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Anchorage Chemical Terminal primarily uses the Knowledge Based Hazard and Operability (HAZOP) study that is an adaptation by Exxon Research and Engineering and Exxon Chemical Americas of widely used industry methodologies 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 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, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team finding are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is base d on a relative risk evaluation done by the PHA team. This evaluation helps ensure that potential accident scenarios assigned greater risk receive attention first. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The resolution of each finding is documented and retained. To ensure that the process controls and/or process hazards do not deviate significantly from the original design safety features, the Anchorage Chemical Terminal periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years for the life of the process. 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. OPERATING PROCEDURES AND SAFE WORK PRACTICES The Anchorage Chemical Terminal maintains written procedures that address various modes of process operations, such as (1) startup, (2) shutdown, (3) normal, and (4) emergency operations. These procedures can be used as a reference by experienced operators and provide a consistent basis for training of new operators. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. The plant has identified operating envelopes, i.e., documented safety related limits for specific process parameters such as temperature, level, and compositions. This information, along with written operating procedures, is readily available to operators and for other personnel to use as necessary to safely perform their job tasks. The Anchorage Chemical Terminal 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 f or 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 ensure that operations and maintenance activities are performed safely. TRAINING To complement the written procedures for process operations, the Anchorage Chemical Terminal has implemented a comprehensive training program for all associates involved in operating a process. New associates receive basic training in plant operations. After successfully completing this training, a new operator is paired with an experienced operator to learn process specific duties and tasks. After employees demonstrate (i.e., 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 operations personnel periodically receive refresher training to ensure that their skills and knowledge are maintained at an acceptable level. All of this training is documented for each operator. CONTRACTORS The Anchorage Chemical Terminal uses contractors to supplement its workforce 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 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 plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) safety orientation; (2) information about safety and heath hazards; (3) emergency response plan requirements; and (4) safe work practices prior to their beginning work. In addition, the Anchorage Chemical Terminal 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. MECHANICAL INTEGRITY The Anchorage Chemical Terminal 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 o f 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 preformed 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 (i.e., adequate wall thickness for pressure vessels). If a deficiency is identified, associates will correct the deficiency before placing the equipment back into service (if possible) or a 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 Anchorage Chemical Termin al 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. HOT WORK The Anchorage Chemical Terminal has a Work Permit System in place to protect personnel, site facilities, and the surrounding community. The purpose of the Work Permit System is to ensure that jobs are planned, equipment is prepared, personnel are informed to hazards and procedures, precautions are taken, and work is executed in a manner to protect safety, health, and the environment. The Work Permit System covers hot work and other categories of work such as opening equipment, excavation, lifting, and confined spaces. MANAGEMENT OF CHANGE The Anchorage Chemical Terminal 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 c onditions), 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 necessary training before the change is implemented. INCIDENT INVESTIGATION The Anchorage Chemical Terminal promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, 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 f indings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions are taken in response to the investigation team's findings and recommendations are tracked until they are complete. The resolution of each finding or recommendation is documented and the investigation results are reviewed with all associates (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least five years so that the reports can be reviewed during future PHAs and PHA revalidations. COMPLIANCE AUDITS To help ensure that Safety, Health and Environmental (SHE) management systems are functioning properly, the Anchorage Chemical Terminal periodically conducts audits to determine whether the procedures and practices required by the OIMS are being implemented. Compliance audits are conducted semi-annually and external SHE audits are conducted at least every three years. The audit te am develops findings that are forwarded to management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The resolution of each finding is documented, and the most recent audit reports are retained. CHEMICAL SPECIFIC PREVENTION STEPS The processes at the Anchorage Chemical Terminal have hazards that must be managed to ensure continued safe operation. Prevention activities in place at ACT help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. In addition to the prevention activities, the plant has safety features on many units to help, (1) quickly detect a release, (2) contain/control a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release Detection 1. Hydrocarbon detectors with alarms Release Containment/Control 1. Process relieve valves tha t discharge to a flare to capture and incinerate episodic releases 2. Valves to permit isolation of the process (manual or automated) 3. Automated shutdown systems for specific process parameters (i.e., high level, high temperature) 4. Curbing or diking to contain liquid releases 5. Redundant equipment and instrumentation (i.e., backup firewater pump) 6. Atmospheric relief devices Release Mitigation 1. Fire suppression and extinguishing systems 2. Deluge system for specific equipment 3. Trained emergency response personnel 4. Personal protective equipment (i.e., protective clothing, self-contained breathing apparatus) 5. Blast resistant buildings to help protect control systems and personnel FIVE YEAR ACCIDENT HISTORY The Anchorage Chemical Terminal has an excellent record of accident prevention over the life of the facility. The have been no accidents for the past fiv e years, which are reportable under this regulation. EMERGENCY RESPONSE PROGRAM INFORMATION The Anchorage Chemical Terminal 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 plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instruction that address the use of emergency response equipment. Associates 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 plant processes or 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 Anchorage Chemical Terminal is coordinated with the West Baton Rouge Parish Local Emergency Planing Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (i.e., Port Allen Fire Department and Exxon Baton Rouge Chemical Plant Emergency Response Team). This provides a means of notifying the public of an incident as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the plant conducts periodic emergency drills that involve the local response agencies. PLANNED CHANGES TO IMPROVE SAFETY The Anchorage Chemical Terminal resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned: 1. Installing automated deluge valves to supply firewater to the propylene bullet deluge system 2. Installing Elliott Motor controls on P-103 and C-103A&B 3. Upgrading firewater pump eductor systems |