Exxon Chemical Company- Baton Rouge Plastics Plant - Executive Summary
LDEQ Facility ID # 285 |
Exxon Chemical Company Baton Rouge Plastics Plant Risk Management Plan:
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Exxon Chemical Company Baton Rouge Plastics Plant (BRPP) has a long-standing commitment to the safety of the neighboring community as well as employees and contractors on plant property. Exxon, operator of BRPP, has a long-standing dedication to safety and environmental stewardship as the corporation's primary goal. Safety and protection of the environment are an integral part of Exxon's operations and corporate culture.
BRPP's dedication to safety is demonstrated in many ways. To help ensure the safety of BRPP operations, BRPP invests significant resources in accident prevention. Accident prevention includes designing safe plants and operating facilities, conducting and providing safety training for employees and contractors, and developing and implementing safe work practices and procedures for the operatio
n and maintenance of plants, processes, and other operations facilities. BRPP's policies and our dedication to safety and environmental stewardship help prevent releases of hazardous substances. If, despite our best attempts to prevent such incidents, a release should occur, trained personnel will respond to, control, and contain the release in accordance with our Emergency Response Plan.
Exxon modified its safety programs in 1991 by adopting a structured safety management systems entitled, "Operations Integrity Management Systems (OIMS)". BRPP 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.
This document has been prepared in accordance with the EPA's new Accidental Release Prevention (ARP) Program
regulations (40 CFR Part 68), which were promulgated in the Federal Register on Thursday, June 20, 1996, Vol. 61, No. 120.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
BRPP, located in East Baton Rouge Parish, Louisiana, is owned and operated by Exxon Chemical Company (Exxon). BRPP is a low density, high-pressure polyethylene (LDPE) manufacturing facility.
In accordance with the EPA's new Accidental Release Prevention (ARP) Program regulations (40 CFR Part 68), which were promulgated in the Federal Register on Thursday, June 20, 1996, Vol. 61, No. 120, BRPP was evaluated to determine if any regulated flammable or toxic substances were on the plant site in quantities above the substance's threshold quantity defined by the regulations. The largest quantity is evaluated because the regulations guide the operator to consider the largest quantity of the substance in a process or operation if a listed substance is used or located in different processes or operations
on a plant site. The term "threshold quantity" is simply the quantity above which the EPA has decided that the substance will be regulated under these new regulations. Based on process knowledge, Exxon identified the regulated substances involved in the operation and determined the quantities of each regulated substance on the site.
BRPP uses six regulated substances above the threshold quantity in 14 separate processes. These substances are acetaldehyde, n-butane, 1-butene, ethylene, propylene, and vinyl acetate.
DETERMINATION OF PROGRAM LEVEL FOR THE SITE
The new regulations under which this document was prepared (i.e., 40 CFR Part 68) require the operator to evaluate a "worst-case release scenario" which the EPA has defined as the "release of the largest quantity of a regulated substance from a vessel or process line failure" Based on this required evaluation of a hypothetical and extremely unlikely scenario, the distances to endpoints (i.e., an overpressure of 1 psi) excee
d the distances to public receptors (i.e., off-site residences, institutions, industrial, commercial and office buildings, parks, or recreational areas, inhabited or occupied by the public). BRPP is also subject to Occupational Safety & Health Administration (OSHA) Process Safety Management (PSM) regulations. Accordingly, BRPP is classified as a Program 3 process under the Accidental Release Prevention (ARP) Program regulations.
OFF-SITE CONSEQUENCE ANALYSIS RESULTS
The ARP Program requires one worst-case scenario for all listed toxic substances. As required by the ARP Program regulations, the worst case release scenario was used to evaluate such a scenario involving the toxic regulated substance that is on site in a quantity above the threshold quantity (vinyl acetate). The ERPG-2 for vinyl acetate (0.26 mg/l) was used to determine the distance to endpoint in the event of a release. The hypothetical scenario involving the release of vinyl acetate was found to
have a distance to endpoint of 1.2 miles.
The ARP Program requires the assumption of an instantaneous release and a vapor cloud explosion, regardless of whether such a scenario is realistic. According to EPA regulations, the endpoint for the "worst-case release" of flammable substances is 1 psi overpressure, which would result from such a worst-case release scenario. A yield factor of 10 percent of the available energy released in this scenario shall be used to determine the distance to the endpoint. Passive mitigation systems are not applicable to the "worst case release scenario" because, according to the regulations, this scenario is based on the assumption that the entire quantity of the substance forms a vapor cloud.
As required by the ARP Program regulations, the regulatory definition of the "worst case release scenario" was used to evaluate such a scenario for those regulated substances that are on site in quantities above their appropriate threshold b
utane, 1-butene, ethylene and propylene. The distance to the endpoint of 1 psi overpressure for each such scenario was determined. These distances were calculated using the EPA equations. The hypothetical scenario that involves the butane was found to be the one with the longest distance to the endpoint, with a 0.54-mile distance to the endpoint. Accordingly, under the regulations, this scenario involving butane is defined as the "worst-case release scenario" for the facility.
The "worst-case release scenario" was evaluated for each flammable substance in accordance with government regulations to identify the scenario with the longest distance to the endpoint, without regard to how unlikely the scenarios are and without consideration of the multiple redundant safety systems and safety programs that are in place to prevent releases and incidents.
ALTERNATIVE RELEASE SCENARIOS
In addition to requiring operators to evaluate the above-described "worst-case release scenarios," the n
ew ARP Program regulations require operators to evaluate other hypothetical release scenarios that involve smaller releases. These hypothetical scenarios are termed "alternative release scenarios." Consideration of active and passive mitigation systems is allowed for alternative release scenarios.
One alternative-case release scenario for each toxic substance that will reach an endpoint off-site is required under the ARP Program. The alternative-case release scenario for vinyl acetate is a pump failure on TK-932, resulting in the deinventory of 11,000 pounds of vinyl acetate into the pump diked area. The evaluation is based upon the assumption that the pump containment area is completely filled with vinyl acetate. The distance to the toxic endpoint for this scenario is 0.07 miles which is within the plant boundary.
The new ARP regulations require the operator to model a single "alternative release scenario" for all regulated flammable subs
tances. Vapor cloud explosions (VCE) produced from releases of various quantities of ethylene in congested areas were evaluated for risks within the explosive domain. It was determined that there are no alternative-case release scenarios capable of producing a 1 psi overpressure beyond the fenceline. The alternate case scenario for flammable substances at BRPP is a VCE resulting from a reactor and recycle piping system failure releasing 4,400 pounds of ethylene. The maximum distance to the 1 psi overpressure for this event is 0.10 miles.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
The following is a general overview of the main elements of the Accident Prevention Program that is currently in operation at BRPP. BRPP has aligned and integrated its safety management programs at a high level with OSHA's Process Safety Management (PSM) Program regulations for consistency and effectiveness. Because processes at BRPP that are regulated by the EPA RMP regulation are also subject to th
e 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. In addition, Exxon Corporation has implemented OIMS at each of its operations worldwide that include the aspects of EPA's prevention program. OIMS has been attested as equivalent to ISO 14001 as a valid management system to oversee the implementation of the risk management activities.
All employees at BRPP are encouraged 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 accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participatio
n plan that is maintained at the plant and addresses each accident prevention program element. In addition, BRPP has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming 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
BRPP keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address written data and engineering drawings on the design of the facility, the chemistry of the process and associated hazards, safe operating limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information. Specific departments, sections or groups 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 written employee participation plan to help employees locate any of the process safety information.
Safety data is maintained for all chemicals that are used, handled, or produced at the facility. This data includes permissible exposure limits, physical data, reactivity and corrosive information, thermal and chemical stability, toxicity data (if applicable), personal protective equipment, and measures to be taken in the event of physical contact or airborne exposure to a chemical. This information is maintained in Material Safety Data Sheets (MSDS), as part of OSHA's Hazard Communication Program at the plant. For specific process areas, the plant has documented the safety-related limits for specific process parameters (e.g., temperature, pressure, level, etc.). The plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trai
ned personnel, and protective instrument systems such as automatic shutdown systems.
The plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes the materials of construction, design pressure and temperature ratings, and electrical ratings of equipment. 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 (PHA)
BRPP has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. This is a systematic procedure in which each process is systematically examined to identify all of the potential hazards, and to ensure that adequate controls are in place to manage these hazards
BRPP primarily uses the hazard and operability (HAZOP) analysis technique to perform these PHA 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 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 appropriate.
The PHA team findings and suggestions are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative priority ranking assigned by the PHA team. This ranking process is intended to ensure that potential hazards that are considered to have the highest priority receive immediate attention. All approved mitigation options being implemented are tracked unti
l they are complete. The final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards are continuously evaluated and maintained in a safe condition, the plant periodically updates and revalidates the Process Hazard Analysis. 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 retained. Once again, the team findings are forwarded to management for consideration and final resolution of the findings is documented and retained.
BRPP maintains written operating 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 provide the basis for consistent training of new oper
ators, and they provide good reference materials for experienced operators. These procedures are periodically reviewed and 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, BRPP maintains CAPS (Compentency Analysis Profile System) Documentation which contains sections that provide 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.
BRPP employs a comprehensive training program for all employees at the plant. New employees receive job-specific basic training in plant operations. After successfully completing this training, a new operator is paired with a senior operator to learn proc
ess-specific duties and tasks. After operators demonstrate (e.g., through test, 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 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 provided as often as necessary, and no less than every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training.
BRPP uses contractors to perform project-specific activities and to supplement the plant workforce during periods of increased maintenance or construction activities. For those contractors who work on or near process equipment, the plant has procedures in place to ensure that these contractors (1) perform their work in a safe manner, (2) have the appropriate k
nowledge and skills to work safely around the process, (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) 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, BRPP evaluates contractor safety programs and performance during the selection of a contractor. Safety personnel periodically monitor contractor safety performance to ensure that contractors are fulfilling their safety obligations.
Pre-Startup Safety Reviews (PSSRs)
BRPP conducts a Pre-Startup Safety Review (PSSR) for any new facility or modification that requires a change in the process safety information. The purpose of the PSSR is to ensure, before startu
p of the new or modified process or unit, that the construction or modification was completed in accordance with design specifications. The PSSR is also intended to ensure that safety features, procedures, personnel, and equipment are properly prepared for startup before the new or modified equipment is put in service. This review provides one additional check to make sure that all personnel and supporting systems are operationally ready to operate the new or modified process or equipment. 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.
BRPP has well-established practices and procedures to maintain process equipment, including pressure vessels, piping systems, relief and vent systems, controls, pumps, 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 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 jobs in a safe manner. Written procedures are intended to ensure that maintenance 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 pressure vessels). If a defici
ency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change 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. Quality assurance measures are incorporated into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that the proper materials and spare parts are used when repairs are made.
Safe Work Practices
BRPP developed safe work practices designed to ensure worker and process safety and these safe work practices are followed regularly to ensure that operations and maintenance activities are performed safely. Examples of safe work practices include (1) control of the entry/presence/exit of support personnel in the process areas (2) a lockout/tagout procedure to ensure isolation of energy
sources for equipment undergoing maintenance, (3) a procedure for the safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work permit), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space.
These safe work practices and procedures, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely at all times.
Management of Change (MOC)
BRPP has a comprehensive system in place to manage and document any changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, or other changes be properly reviewed and authorized by a number of people with different functional expertise before being implemented. Changes are reviewed to (1) ensure that ad
equate controls are in place to manage any new hazards and (2) verify that existing controls have not been negatively affected by the change. A part of the MOC process ensures that any chemical hazard information, process operating limits, equipment information, and/or procedures are updated as appropriate to incorporate the effects of the modification. A critical piece of the MOC process ensures that operating and maintenance personnel are provided any necessary training regarding the process modification.
BRPP 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 underlying cause(s) of the incident to develop corrective actions and implement steps to prevent a recurrence of the incident and prevent similar incidents. The investigation team documents its findin
gs, develops recommendations to prevent similar incidents, and forwards these results to management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are fully complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who 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.
To help ensure that the Accident Prevention Program is functioning properly, BRPP periodically conducts audits to determine whether the procedures and practices required by the accident prevention program are being implemented properly, to evaluate the effectiveness of the program, and to develop ideas for improving the program. OSHA PSM Compliance audits are conducted at least ev
ery 3 years. The audit team 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 final resolution of each finding is documented, and the two most recent audit reports are retained for future review.
CHEMICAL-SPECIFIC ACCIDENT PREVENTION STEPS
The processes at BRPP have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all covered processes at the plant. 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 plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a release in the unlikely event of an accidental release, and (3) reduce the consequences of (mitigate) a rele
ase. The following types of safety features are used in various processes:
1. Hydrocarbon gas detectors with alarms and infrared sensor with alarms.
1. Process relief valves that discharge to a flare system to contain and incinerate releases
2. Scrubber to neutralize chemical releases
3. Valves to permit isolation of the process (manual or automated)
4. Automated shutdown systems for specific process parameters (e.g., high pressure or temperature)
5. Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank)
6. Curbing or diking to contain liquid releases
7. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system)
8. Atmospheric relief devices.
1. Fire detection, suppression, and extinguishing systems
2. Deluge system for specific equipment
3. Trained emergency response personnel
4. Personal protective equipment (e.g., protect
ive clothing, self-contained breathing apparatus)
5. Blast-resistant buildings to help protect control systems and personnel
FIVE-YEAR ACCIDENT HISTORY
BRPP has an excellent record of accident prevention over the past 5 years; the frequency of accidental releases has decreased. Two incidents have occurred in the past 5 years (June 1994 - June 1999) that are considered RMP events, none of which resulted in offsite effects. We investigate every incident very carefully to determine ways to prevent similar incidents from occurring. The following table is a summary of the number of incidents that have occurred during the past 5 years.
Year 1994; 1995; 1996; 1997; 1998; 1999
Number of RMP releases: 0; 1; 1; 0; 0; 0
EMERGENCY RESPONSE PROGRAM INFORMATION
BRPP maintains a written emergency response program, which is in place to protect worker (employees and contractors) and public safety as well as the environment and to minimize any effects in the unlikely event of an emergency. The
plan consists of procedures for responding to any accidental releases, as well as procedures for responding to any fires that could occur in the unlikely event of a release of a flammable substance. These response procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and for accounting for all personnel (employees, contractors, and visitors) 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 instructions that address the use of emergency response equipment. Employees receive training to enable them to fulfill their role in an emergency. The emergency response program is updated, when necessary, based on modifications made to processes. The emergency respons
e 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 BRPP is coordinated with the East Baton Rouge Parish 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. BRPP has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a method for notifying the public in the event of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, BRPP conducts periodic emergency response drills that involve the LEPC and emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regu
lated substance in the plant.
PLANNED CHANGES TO IMPROVE SAFETY
As explained above, many of the elements of BRPP's Accident Prevention Program include initiatives, methods, or procedures for continuous improvement of safety programs and employee and public safety. These elements are part of an overall ongoing safety improvement process. The following elements of the management system are specifically intended to improve safety:
7 Process Hazard Analysis
7 Management of Change
7 Compliance Audits