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Baker Petrolite Corporation - Sand Springs

Parent Companies:
Baker Hughes, Inc.
EPA Facility ID:
100000103345
Other ID:
74063CHMLN9100W
Facility DUNS:
107266629
Parent Company DUNS:
174987909

Location:

Address:
9100 W. 21st Street
Sand Springs, OK 74063
County:
TULSA
Lat / Long:
36.133, -96.095 (Get map)
Method:
Interpolation - Map
Description:
Storage Tank
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Baker Petrolite Corporation
Phone:
(918) 245-2224
Address:
9100 W. 21st Street
Sand Springs, OK 74063
Foreign Address:

Person responsible for RMP implementation:

Name:
Todd Shilt
Title:
HSE Manager

Emergency contact:

Name:
Todd Shilt
Title:
HSE Manager
Phone:
(918) 246-2480
24-hour phone:
(918) 671-4262
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Tulsa LEPC
Full-Time Equivalent Employees:
179
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 12, 2012
Inspecting Agency:
Risk Assessment by Star Technical (Insurance)
Using Predictive Filing:
No

Processes:

Propylene Oxide Storage
RMP ID:
1000043785
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propylene oxide [Oxirane, methyl-]
75-56-9
1,025,000
No
Public OCA Chemical
0
No
Ethylenediamine Storage
RMP ID:
1000043786
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylenediamine [1,2-Ethanediamine]
107-15-3
36,000
No
Public OCA Chemical
0
No
Ethylene Oxide Storage
RMP ID:
1000043787
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
1,160,000
No
Public OCA Chemical
0
No
Aqueous Ammonia Storage
RMP ID:
1000043788
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (conc 20% or greater)
7664-41-7
60,000
No
Public OCA Chemical
0
No
Formaldehyde(37%) Storage
RMP ID:
1000043789
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Formaldehyde (solution)
50-00-0
165,000
No
Public OCA Chemical
0
No
Isopropylamine Storage
RMP ID:
1000043790
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Isopropylamine [2-Propanamine]
75-31-0
62,000
No
Public OCA Chemical
0
No
Isopentane Storage
RMP ID:
1000043791
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Isopentane [Butane, 2-methyl-]
78-78-4
690,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
David Burton
Address:
9100 West 21st Street
Sand Springs, OK 74063
Foreign Address:

Phone:
(918) 246-4808

Latest RMP Submission:

Date:
Nov. 11, 2013
Type:
Resubmission
Reason:
Revised PHA / Hazard Review due to process change (40 CFR 68.190(b)(5))
Registered:
Yes
RMP ID:
1000035777

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ethylene Oxide Storage)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Public OCA Chemical (in Formaldehyde(37%) Storage)
CBI claimed:
No
Percent weight:
37.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Propylene Oxide Storage)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Deluge systems
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Ethylenediamine Storage)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Ethylene Oxide Storage)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Excess flow valve
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers
Public OCA Chemical (in Aqueous Ammonia Storage)
CBI claimed:
No
Percent weight:
24.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Formaldehyde(37%) Storage)
CBI claimed:
No
Percent weight:
37.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Isopentane Storage)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Isopropylamine Storage)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve
Public OCA Chemical (in Isopentane Storage)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

July 31, 2011 at 01:00
ID:
1000029556
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Duration:
1 minutes
Chemicals involved:
  • Isopropylamine [2-Propanamine]
Release events:
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
10.0 miles/h
Temperature:
90.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
1
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
  • Unusual weather conditions
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures

7. Prevention: Program level 3

Propylene Oxide Storage, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000038043
Safety Review Date
March 4, 2013
PHA Update Date
June 1, 2009
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Aug. 19, 2013
Training Review Date
June 1, 2011
Maintenance Review Date
Jan. 1, 2009
Maintenance Inspection Date
Feb. 29, 2012
Equipment Tested
Yes
Management of Change Most Recent Date
July 30, 2013
Management of Change Review Date
Nov. 23, 2011
Pre-startup Review Date
July 11, 2013
Compliance Audit Date
May 9, 2013
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Aug. 14, 2011
Hot Work Review Date
June 1, 2011
Contractor Safety Review Date
March 19, 2012
Contractor Safety Eval. Date
Aug. 6, 2013
Ethylenediamine Storage, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000038037
Safety Review Date
Feb. 1, 2009
PHA Update Date
Feb. 1, 2009
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
Process Controls
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Alarms
  • Emergency Air Supply
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Enclosure
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Sept. 27, 2012
Training Review Date
June 1, 2011
Maintenance Review Date
Feb. 1, 2009
Maintenance Inspection Date
Feb. 1, 2009
Equipment Tested
Yes
Management of Change Most Recent Date
July 15, 2013
Management of Change Review Date
Nov. 23, 2011
Pre-startup Review Date
Feb. 1, 2009
Compliance Audit Date
May 9, 2013
Compliance Audit Change Completion Date
Dec. 20, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Aug. 14, 2011
Hot Work Review Date
June 1, 2011
Contractor Safety Review Date
March 19, 2012
Contractor Safety Eval. Date
Aug. 6, 2013
Ethylene Oxide Storage, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000038038
Safety Review Date
Aug. 25, 2008
PHA Update Date
Nov. 19, 2009
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Detection
  • Perimeter Monitoring
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Aug. 19, 2013
Training Review Date
June 16, 2011
Maintenance Review Date
Sept. 10, 2008
Maintenance Inspection Date
Nov. 17, 2010
Equipment Tested
Yes
Management of Change Most Recent Date
July 30, 2013
Management of Change Review Date
Nov. 23, 2011
Pre-startup Review Date
July 11, 2013
Compliance Audit Date
May 9, 2013
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Aug. 14, 2011
Hot Work Review Date
June 1, 2011
Contractor Safety Review Date
March 19, 2012
Contractor Safety Eval. Date
Aug. 6, 2013
Aqueous Ammonia Storage, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000038039
Safety Review Date
Feb. 1, 2009
PHA Update Date
Feb. 1, 2009
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 30, 2013
Training Review Date
June 15, 2011
Maintenance Review Date
June 2, 2007
Maintenance Inspection Date
Sept. 21, 2011
Equipment Tested
Yes
Management of Change Most Recent Date
July 15, 2013
Management of Change Review Date
Nov. 23, 2011
Pre-startup Review Date
July 19, 2013
Compliance Audit Date
Aug. 6, 2013
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Aug. 14, 2011
Hot Work Review Date
June 1, 2011
Contractor Safety Review Date
March 19, 2012
Contractor Safety Eval. Date
Aug. 6, 2013
Formaldehyde(37%) Storage, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000038040
Safety Review Date
April 16, 2013
PHA Update Date
Nov. 19, 2009
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Tornado
Process Controls
  • Vents
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Interlocks
  • Alarms
  • Rupture Disks
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 30, 2013
Training Review Date
Dec. 1, 2011
Maintenance Review Date
Dec. 1, 2008
Maintenance Inspection Date
Aug. 22, 2012
Equipment Tested
Yes
Management of Change Most Recent Date
June 3, 2013
Management of Change Review Date
Nov. 23, 2011
Pre-startup Review Date
June 5, 2013
Compliance Audit Date
May 9, 2013
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Aug. 14, 2011
Hot Work Review Date
June 1, 2011
Contractor Safety Review Date
March 19, 2012
Contractor Safety Eval. Date
Aug. 6, 2013
Isopropylamine Storage, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000038041
Safety Review Date
Jan. 13, 2011
PHA Update Date
Feb. 1, 2009
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Contamination
  • Tornado
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 20, 2013
Training Review Date
July 1, 2011
Maintenance Review Date
Feb. 1, 2009
Maintenance Inspection Date
Feb. 1, 2009
Equipment Tested
Yes
Management of Change Most Recent Date
June 3, 2013
Management of Change Review Date
Nov. 23, 2011
Pre-startup Review Date
June 5, 2013
Compliance Audit Date
May 9, 2013
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Aug. 14, 2011
Hot Work Review Date
June 1, 2011
Contractor Safety Review Date
March 19, 2012
Contractor Safety Eval. Date
Aug. 6, 2013
Isopentane Storage, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000038042
Safety Review Date
July 29, 2009
PHA Update Date
July 19, 2009
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
June 24, 2013
Training Review Date
Dec. 5, 2011
Maintenance Review Date
April 15, 2009
Maintenance Inspection Date
March 22, 2012
Equipment Tested
Yes
Management of Change Most Recent Date
May 14, 2013
Management of Change Review Date
Nov. 23, 2011
Pre-startup Review Date
May 20, 2013
Compliance Audit Date
May 9, 2013
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Aug. 14, 2011
Hot Work Review Date
June 16, 2011
Contractor Safety Review Date
March 19, 2012
Contractor Safety Eval. Date
Aug. 6, 2013

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Oct. 4, 2013
Local Response Agency:
Local Response Agency Phone:
(918) 596-1785
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES



We at Baker Petrolite Corporation (BPC) Sand Springs are strongly committed to employee, public, and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release where to occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release.



THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED



Our facility's primary activities encompass the manufacturing of oil-field chemicals. We have seven regulated substances present at our facility that are over the threshold amount. Toxic substances include Aqueous Ammonia, Ethylene Oxide, Formaldehyde 37% solution, Propylene Oxide, and Ethylenediamine. Flammable substances include Isopentane, Isopropylamine, and Propylene.



The regulated substances are used in various processes at the facility. Ammonia and isopropylamine are used in acid neutralization reactions. Ethylene Oxide and Propylene Oxide are used in alkyloxylation reactions. Formaldehyde solution is used in the production of resins. Isopentane are used in the production of a pipeline drag reducing agent. Ethylenediamine is used for resin blends.



THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE CHEMICAL-SPECIFIC PREVENTION STEPS



Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. A number of processes at our facility are subject to OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements for the release prevention program that is in place a
t our stationary source.



PROCESS SAFETY INFORMATION - BPC-Sand Springs maintains a detailed record of safety information that describes chemical hazards, operating parameters, and equipment designs associated with all processes.



PROCESS HAZARD ANALYSES - Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is the HAZOP method. The studies are undertaken by a team of qualified personnel with expertise in engineering, plant operations, and maintenance. Employees get to make suggestions to improve the safety and environmental operation of their work environment. The analyses are reviewed and revalidated at least every five years. Any findings related to the hazard analysis are addressed in a timely manner.



OPERATING PROCEDURES - For the purposes of safely conducting activities within our covered processes, BPC-Sand Springs maintains written operating procedures. These procedures address normal operations, including startup, shutdown, and emergency operations. The information is regularly reviewed and is readily accessible to operators involved in the process.



BPC-Sand Springs is an ISO 9001 certified facility. This requires the facility to keep up-to-date procedures on all of our operating procedures. There are regular audits from both internal and external auditors.



TRAINING - BPC-Sand Springs has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Process competence is demonstrated by periodic testing. Also, in excess of 150 hours per year are spent in operational, safety, and environmental training by every plant employee. This includes offsite fire training where simulations are real and the employee must learn to react quickly to protect himself, his fellow employee, and property from harm. In additi
on, BPC-Sand Springs has supported and sponsored training for members of the local fire department for many years.



MECHANICAL INTEGRITY - BPC-Sand Springs carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. BPC-Sand Springs also participates in a quarterly leak detection and repair program. Maintenance operations are carried out by qualified personnel with training and experience in maintenance practices. Furthermore, these personnel are provided specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.



BPC-Sand Springs also has a vessel inspection program that checks the vessel thickness of our reactors on a regular basis. This program was started in September 1998 and has been continuously maintained.



MANAGEMENT OF CHANGE - Written procedures are in place at BPC-Sand Springs to manage changes in process chemicals, technology, equipment, and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and provided training to deal with the modification.



PRE-STARTUP SAFETY REVIEWS - Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at BPC-Sand Springs. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.



COMPLIANCE AUDITS - BPC-Sand Springs conducts internal audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three years and any correctiv
e actions required as a result of the audits are undertaken in a safe and prompt manner. Process safety management audits are conducted every 3 years. In addition, BPC-Sand Springs is routinely audited by outside parties and Federal and state agencies.



INCIDENT INVESTIGATIONS - BPC-Sand Springs promptly investigates any incident that has resulted in, or could have resulted in, a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective action to prevent the release from reoccurring. All reports are maintained for a minimum of 5 years.



EMPLOYEE PARTICIPATION - BPC-Sand Springs truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses. There is an on-site Safety Committee composed of employee representatives from each plant operating area and chaired by the Site Safety and Health Manager. The committee meets monthly and conducts an audit of a different operations area as part of its activities. Recommended improvements are submitted to the plant manager and monitored by the committee for implementation.



CONTRACTORS - On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Baker BPC-Sand Springs has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. Con
tractors are required to provide a written safety program which contains specific safety policies for the type of work they will perform. They must also certify that their employees have been trained and equipped as required by applicable Federal, state, and local regulations. Contractors are required to advise plant personnel of specific hazardous processes or materials involved in their work.



FIVE-YEAR ACCIDENT HISTORY



BPC-Sand Springs has had an excellent record of preventing accidental releases of RMP regulated substances over the past five years due to our stringent release prevention policies. However, there has been one accidental release which resulted in a fatality of an employee. During this event, there was no significant damage to the property or offsite consequence. No other accidental releases have occurred which resulted in injury requiring off-site medical care to an employee or an area resident or significant damage to property over this period.



EMERGENCY RESPONSE PLAN



BPC-Sand Springs maintains a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.



To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the emergency plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.



PLANNED CHANGES TO IMPROVE SAFETY



BPC-Sand Springs is committed to continuously improving safety at our facility to protect our employees, our community, and the environment. We will continue to cooperate with area municipal and county emergency management authorities and other regulated firms in the community to develop mutual support procedu
res, to improve employee safety and health training, and to participate in community outreach activities. Overall, process safety reviews and associated changes are ongoing and are implemented as necessary to improve our ability to protect our neighbors and the environment.