Phillips Petroleum Sweeny Complex Clemens Terminal - Executive Summary |
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PHILLIPS SWEENY COMPLEX CLEMENS TERMINAL RISK MANAGEMENT PLAN EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Clemens Terminal has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training and consideration of safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement 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 Clemens Terminal is an underground storage facility of finished and rerun products. The products stored in the underground storage domes are: Normal Butane, iso-Butane, iso-Pentane, Hydrogen, Natural Gas, Propane, Ethane-Propane mix, Butanes-Butylenes mix, NGL, Propylene, and Ethylene. In addition to the undergroun d storage domes. Clemens is capable of treating Ethylene, Propylene, Propane and normal and iso-Butanes for sales. These five products are treated through a molecular sieve bed for the removal of carry-over water resulting during storage. Ethylene and Propylene are additionally treated for the removal of Carbon Dioxide resulting from the underground storage. In our process, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics: There are no toxics stored at Clemens Terminal Flammables: Normal Butane, Ethylene, Propane, Propylene, Ethane, 2-Butene-trans, 1-Butene, 2-Butene-cis, Butene, Isobutane, 2-Butene, Hydrogen, Isopentane, Methane, Pentane HAZARD ASSESSMENT RESULTS The Worst Case Scenario associated with a release of flammable substances is a vapor cloud explosion (VCE) involving the maximum intended inventory of the largest vessel containing a flam mable mixture or substance. Typically, it is assumed the entire contents of the vessel are released instantaneously, thus calculating the distance to a 1 pound overpressure endpoint. However, Clemens Terminal is an underground storage facility with large amounts of storage which cannot be emptied instantaneously. Modeling was based upon a 10 minute release of a substance in the cavern through a failure of the above ground piping, which is the only piping that enters or exits the cavern. This piping is considered the closest release point whereby the cavern contents can be released into the atmosphere. Based on this modeling, our worst case scenario was a failure of the 8" piping on a NGL underground salt dome storage cavern. In a 10 minute time period, 3,290,000 pounds of NGL would be released into the atmosphere resulting in a potential vapor cloud explosion. Due to the piping configuration of the salt domes as stipulated by EPA General Guidance question and answers (Worst Case and Mitigation) 4-11, we have taken credit for passive mitigation. The resulting vapor cloud explosion would reach offsite endpoints and nearby public receptors. The Alternate Release Scenario for flammable substances at Clemens is a vapor cloud explosion resulting from the release of NGL from a 1" nipple failure on associated piping on above ground piping of a cavern (59,640 pounds released over a 7 minute period). The release is expected to be isolated by the operators within 7 minutes (active mitigation). This event was selected as being a practical scenario for use in emergency planning and response. This scenario has no offsite consequences. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Clemens Terminal. Because processes at the plant regulated by the EPA RMP regulation are also subject to the OSHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PS M elements and describes the management system in place to implement the Accident Prevention Program. Employee Participation The Clemens Terminal storage facility encourages employees to participate in all facets of risk 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 Sweeny Complex's Accident Prevention Program. Specific ways that employees can be involved in the Accident Prevention Program are documented in the Employee Participation Element of the Clemens Terminal Risk Management System and in the Employee Participation Section of all other Risk Management Elements. In addition, the terminal has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both proc ess safety and personal safety. The teams typically have members from various areas of the terminal, including operations, maintenance, engineering and terminal management. Two key areas for employee participation include the Employee Behavioral Safety Process (VIPER) and OSHA's Voluntary Protection Program. Clemens Terminal received the OSHA VPP Star award as part of the Sweeny Complex overall inspection by OSHA. Process Safety Information The Clemens Terminal storage facility keeps a variety of technical documents that are used to 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. Specific departments within the terminal are assigned responsibility for maintaining up-to-date Process Safety Information. Process Safety Information reference documents are readily available as part of the written Emp loyee Participation Plan to help employees 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). For specific process areas, the terminal has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the unit-specific Process Safety Information (PSI) document. The terminal verifies 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). Clemens Terminal 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 combinati on 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 confirm that safety features in the process are not compromised. Process Hazard Analysis The Clemens Terminal facility 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. Clemens Terminal primarily uses the HAzard and OPerability (HAZOP) analysis technique 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 and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the proc ess as well as accident prevention and mitigation measures when the team believes such measures are necessary. The PHA Team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained. To confirm the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, Clemens 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 an d findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures Clemens 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 can be used as a reference by experienced operators and provide a basis for consistent training of 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 process. In addition, Clemens maintains a Process Safety Information document that provides guidance on how to respond to upper or lower limit exceedances for spe cific 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, Clemens has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., 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 operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintaine d at an acceptable level. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors Clemens uses contractors as part of its regular 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 verify 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) 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, Clemens evaluates c ontractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to help ensure that contractors are fulfilling their safety obligations. Contractors regularly participate in our emergency drills. Pre-startup Safety Reviews (PSSRs) Clemens conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to confirm 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 p revention program requirements are properly implemented. Mechanical Integrity Clemens 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 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 they can perform their job in a safe manner. Written procedures confirm work is performed in a consistent manner and provi de a basis for training. Inspections and tests are performed to verify quipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). 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. Clemens Terminal 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. Clemens Terminal has developed a team-based defect elimination process known as TPM (Team Perfected Manufacturing). The objective of this employee driven process is to eliminate equipment failu res through predictive and preventive maintenance. As this process continues to mature we expect continuous and substantial improvement in operating reliability and safety. Safe Work Practices Clemens 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 verify isolation of energy sources for equipment undergoing maintenance, (3) procedures 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 confirm 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 Clemens has a c omprehensive system to manage change. 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) verify adequate controls are in place to manage any new hazards and (2) verify 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 on the change. Incident Investigation Clemens Terminal 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 Root Cause and devel op 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 and respective Teams 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) who could be affected by the findings. Incident investigation reports are retained for at least 5 years in order for reports to be reviewed during future PHAs and PHA revalidations. Compliance Audits To confirm the Accident Prevention Program is functioning properly, Clemens 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 participate 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 complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. In addition to the OSHA PSM elements described above, Clemens Terminal incorporates the elements of Phillips Petroleum's Process for Safety & Environmental Excellence and OSHA's Voluntary Protection Program into a single, integrated plant Risk Management Program. The elements of these two management processes are: OSHA VPP ELEMENTS (VOLUNTARY PROTECTION PROGRAM) PSEE ELEMENTS (PROCESS FOR S/E EXCELLENCE) VPP (1) MANAGEMENT COMMITMENT AND PLANNING PSEE (1) ROLES AND RESPONSIBILITIES VPP (2) ACCOUNTABILITY SYSTEMS PSEE (2) TRAINING VPP (3) DISCIPLINARY PROGRAM PSEE (3) INDUSTRIAL HYGIENE & HE ALTH VPP (4) INJURY RATES PSEE (4) EMPLOYEE OWNERSHIP VPP (5) EMPLOYEE PARTICIPATION PSEE (5) BEHAVIOR MODIFICATION VPP (6) SELF INSPECTIONS PSEE (6) STANDARDS & PROCEDURES VPP (7) EMPLOYEE HAZARD REPORTING SYSTEMS PSEE (7) ENGINEERING DESIGN VPP (8) ACCIDENT/INCIDENT INVESTIGATION PSEE (8) MEASUREMENT VPP (9) JSA/PROCESS REVIEW PSEE (9) AUDITS VPP (10) SAFETY & HEALTH TRAINING PSEE (10) CONTRACTOR PERFORMANCE VPP (11) PREVENTATIVE MAINTENANCE PSEE (11) INCIDENT INVESTIGATION VPP (12) EMERGENCY PROGRAMS/DRILLS PSEE (12) RISK MANAGEMENT VPP (13) PERSONAL PROTECTIVE EQUIPMENT PSEE (13) MECHANICAL & OPERATING INTEGRITY VPP (14) HEALTH PROGRAMS PSEE (14) COMMUNITY INVOLVEMENT VPP (15) SAFETY & HEALTH STAFF INVOLVED WITH CHANGES PSEE (15) REGULATORY ASSESSMENT AND ADVOCACY VPP (16) CONTRACTOR SAFETY PSEE (16) PRODUCT STEWARDSHIP VPP (17) MEDICAL PROGRAM PSEE (17) POLLUTION PREVENTION VPP (18) SAFETY AND HEALTH STAFF RESOURCES VPP (19) ANNUAL EVALUATION These elements, combined with the OSHA PSM elements, help ensure a comprehensive Accident Prevention Program. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at Clemens Terminal have hazards that must be managed to help ensure continued safe operation. The Accident Prevention Program summarized previously is applied to all EPA RMP covered process 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, Clemens has safety features on many caverns 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 * Hydrocarbon Detectors with Alarms Release Containment/Control * Process Relief Valves that discharge to a flare to capture and incinerate epis odic releases * Valves to permit isolation of the process (manual or automated) * Automated Shutdown Systems for specific process parameters (e.g., high level, high temperature, release detection) * Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) * Atmospheric Relief Devices Release Mitigation * Fire Suppression and Extinguishing Systems * Deluge System for specific equipment * Trained Emergency Response Personnel * Personal Protective Equipment (e.g., protective clothing, self-contained breathing apparatus) * Control Building is located outside of potential release areas FIVE-YEAR ACCIDENT HISTORY Over the past 5 years there have been no RMP events with offsite effects. Every incident is carefully investigated to determine ways to prevent similar incidents from occurring. EMERGENCY RESPONSE PROGRAM INFORMATION Clemens Terminal maintains a written Emergency Response Program, which is in place to p rotect 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, Clemens Terminal 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 Emergency Response Program is updated when necessary based on modifications made to plant pro cesses 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 Clemens Terminal is coordinated with the Brazoria County 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. Clemens 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, Clemens conducts periodic emergency drills that involve the LEPC and emergency response organizations. In addition to the LEPC, the Sweeny Complex also has a Mutual Aid Sys tem in place. The Emergency Assistance Agreement Committee (EAAC) is a sub committee of the Industrial CAER organization in the Brazosport area. This system provides Mutual Aid from other industry members in the Brazosport area. In addition, the Brazoria Volunteer Fire Department and West Brazos Emergency Medical Service would provide assistance in the event of an emergency at the Clemens Terminal. The EAAC conducts emergency drills quarterly each year, hosted by a facility with the other member facilities participating. PLANNED CHANGES TO IMPROVE SAFETY Clemens Terminal resolves all findings from PHA's, some of which result in modifications to the process. The following types of changes are planned: * Additional Emergency Shutdown Valves on critical equipment lines. |