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ExxonMobil Baton Rouge Polyolefins Plant (BRPO)

Parent Companies:
Exxon Mobil Corporation
EPA Facility ID:
100000122477
Other ID:
Facility DUNS:
615319886
Parent Company DUNS:
8072118

Location:

Address:
12875 North Scenic Highway
Baton Rouge, LA 70807
County:
EAST BATON ROUGE
Lat / Long:
30.560, -91.206 (Get map)
Method:
GPS Code Measurements (Psuedo Range) Standard Positioning Service Corrected
Description:
Center of Facility
Horizonal accuracy:
20 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
ExxonMobil Chemical
Phone:
(225) 977-9239
Address:
P.O. Box 53006
Baton Rouge, LA 70892 -3006
Foreign Address:

Person responsible for RMP implementation:

Name:
George Jones
Title:
Site Environmental Coordinator

Emergency contact:

Name:
First Line Supervisor
Title:
First Line Supervisor - Production
Phone:
(225) 977-9312
24-hour phone:
(225) 977-9312
Ext or PIN:
Email:
N/A

Other contacts:

Facility (or company) email:
Facility phone:
(225) 977-9000
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
East Baton Rouge LEPC
Full-Time Equivalent Employees:
280
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0840-00003 V-6
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
March 12, 2010
Inspecting Agency:
Department of Transportation
Using Predictive Filing:
No

Processes:

Ethylene/Isobutane Mix
RMP ID:
1000062092
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene [Ethene]
74-85-1
20,000
No
Isobutane [Propane, 2-methyl]
75-28-5
33,000
No
Flammable Mixture
00-11-11
53,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Isobutane
RMP ID:
1000062093
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Isobutane [Propane, 2-methyl]
75-28-5
110,000
No
Public OCA Chemical
0
No
Hydrogen
RMP ID:
1000062094
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen
1333-74-0
16,000
No
Public OCA Chemical
0
No
Propylene/Propane Mix
RMP ID:
1000062095
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
150,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
CK Associates, LLC
Address:
17170 Perkins Road
Baton Rouge, LA 70810
Foreign Address:

Phone:
(225) 755-1000

Latest RMP Submission:

Date:
April 28, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000049495

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

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 Propylene/Propane Mix)
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 Isobutane)
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:
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Ethylene/Isobutane Mix, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000051607
Safety Review Date
July 7, 2014, since latest RMP submission
PHA Update Date
July 7, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Polymerization
  • Overpressurization
  • Corrosion
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Rupture Disks
  • Excess Flow Device
  • Quench System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 5, 2015, since latest RMP submission
Training Review Date
April 1, 2015, since latest RMP submission
Maintenance Review Date
Jan. 15, 2014, since latest RMP submission
Maintenance Inspection Date
March 11, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 14, 2015
Management of Change Review Date
Oct. 22, 2014
Pre-startup Review Date
March 11, 2015
Compliance Audit Date
April 19, 2013
Compliance Audit Change Completion Date
Aug. 1, 2014
Incident Investigation Date
Jan. 5, 2015
Incident Invest. Change Completion Date
Dec. 31, 2015
Participation Plan Review Date
Dec. 5, 2014
Hot Work Review Date
Jan. 2, 2013
Contractor Safety Review Date
Jan. 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
April 15, 2015, since latest RMP submission
Isobutane, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000051604
Safety Review Date
July 7, 2014, since latest RMP submission
PHA Update Date
July 7, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Polymerization
  • Overpressurization
  • Corrosion
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 5, 2015, since latest RMP submission
Training Review Date
April 1, 2015, since latest RMP submission
Maintenance Review Date
Jan. 15, 2014, since latest RMP submission
Maintenance Inspection Date
March 11, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 14, 2015
Management of Change Review Date
Oct. 22, 2014
Pre-startup Review Date
March 11, 2015
Compliance Audit Date
April 19, 2013
Compliance Audit Change Completion Date
Aug. 1, 2014
Incident Investigation Date
Jan. 5, 2015
Incident Invest. Change Completion Date
Dec. 31, 2015
Participation Plan Review Date
Dec. 5, 2014
Hot Work Review Date
Jan. 2, 2013
Contractor Safety Review Date
Jan. 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
April 15, 2015, since latest RMP submission
Hydrogen, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000051605
Safety Review Date
July 7, 2014, since latest RMP submission
PHA Update Date
July 7, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Oct. 9, 2014, since latest RMP submission
Training Review Date
Oct. 9, 2014, since latest RMP submission
Maintenance Review Date
Jan. 15, 2014, since latest RMP submission
Maintenance Inspection Date
Aug. 17, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 5, 2014
Management of Change Review Date
Oct. 22, 2014
Pre-startup Review Date
Oct. 14, 2014
Compliance Audit Date
April 19, 2013
Compliance Audit Change Completion Date
Aug. 11, 2014
Incident Investigation Date
Sept. 28, 2014
Incident Invest. Change Completion Date
Feb. 1, 2016
Participation Plan Review Date
Dec. 5, 2014
Hot Work Review Date
Jan. 2, 2013
Contractor Safety Review Date
Jan. 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
April 15, 2015, since latest RMP submission
Propylene/Propane Mix, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000051606
Safety Review Date
Feb. 19, 2014, since latest RMP submission
PHA Update Date
Feb. 19, 2014, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Fire
  • Explosion
  • Polymerization
  • Overpressurization
  • Overfilling
  • Contamination
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Rupture Disks
  • Excess Flow Device
  • Quench System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Aug. 12, 2014, since latest RMP submission
Training Review Date
Aug. 12, 2014, since latest RMP submission
Maintenance Review Date
Jan. 15, 2014, since latest RMP submission
Maintenance Inspection Date
Jan. 7, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 7, 2015
Management of Change Review Date
Oct. 22, 2014
Pre-startup Review Date
Jan. 29, 2015
Compliance Audit Date
April 19, 2013
Compliance Audit Change Completion Date
Aug. 1, 2014
Incident Investigation Date
Sept. 28, 2014
Incident Invest. Change Completion Date
Feb. 1, 2016
Participation Plan Review Date
Dec. 5, 2014
Hot Work Review Date
Jan. 2, 2013
Contractor Safety Review Date
Jan. 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
April 15, 2015, since latest RMP submission

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:
March 2, 2015
Local Response Agency:
Local Response Agency Phone:
(225) 354-1421
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

LDEQ Facility ID 3519



ExxonMobil BRPO Risk Management Plan: Executive Summary



April 2015 5-Year Update (Minor correction submitted May 12, 2015)



The following discussion is provided as supporting information to the preparation of this RMP 5-year update submission.



There are no changes to the regulated chemicals including on-site inventories. As such, there are no changes to the Worst Case Scenario. A review of past releases and PHA activities did not produce an Alternative Release Scenario which would change the current scenario. Both, however, were re-run using the current RMP Comp software and impact distances changed. The endpoint for the Worst Case Scenario was reduced from 0.43 miles to 0.4 miles and when centered on the actual storage location results in affecting zero population.



Affected population was determined by using Marplot Version 4.2.4 which utilizes the 2010 population census and the estimated residential populations within distance to endpoints were revised as needed.



A review of the 5-year Accident History revealed that within the past 5 years ExxonMobil BRPO has had no accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.



All Prevention Program (Section 7) and Emergency Response (Section 9) elements were reviewed and updated as needed.



ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES



ExxonMobil Baton Rouge Polyolefins (ExxonMobil BRPO) has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, ExxonMobil BRPO
trained personnel will respond to, control, and contain the release.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES



ExxonMobil BRPO operates a high density polyethylene production facility in Baton Rouge, Louisiana. The primary operation of the facility is the production of HDPE at a rate of up to 2.2 billion pounds per year. Ethylene and comonomers are metered into a recirculating loop reactor. Polyethylene is produced in small particles and is recirculated as a slurry in the isobutane. Isobutane, as well as small amount of unreacted ethylene and comonomers, are recovered and recycled back to the reactor. Polyethylene product is dried and sold as a powder or pellet. ExxonMobil BRPO also operates a polypropylene unit. This unit uses processes similar to the polyethylene facility. This process uses propylene as the raw material. The unit began operation in early May 2000. Fuels used at the plant include natural gas, gasoline, and diesel.



ExxonMobil BRPO was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, ExxonMobil BRPO identified the regulated substances and quantities kept on site.



Listed flammable substances which are stored above threshold quantities at ExxonMobil BRPO are isobutane, ethylene/isobutane mixture, hydrogen, 1-butene and propylene/propane mixture. Based on worst-case analyses of the regulated substances, the distances to endpoints exceed the distances to public receptors. In addition, ExxonMobil BRPO is subject to OSHA PSM. Therefore, ExxonMobil BRPO is classified as a Program 3 process under the ARP Program.



GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM



The following is a summary of the accident prevention program in place at ExxonMobil BRPO plant. Because processes at the plant that are regulated by the EPA's risk management program (RMP) regulation are also subject to the OSHA's PSM standard, this summary addresses ea
ch of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.



Employee Participation



The ExxonMobil BRPO facility encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation include updating and compiling technical documents and chemical information to participating as a member of an incident investigation team. Employees have access to all information created as part of the plant's accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the facility and addresses each accident prevention program element. In addition, the facility 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



The ExxonMobil BRPO facility keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within ExxonMobil BRPO 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 HAZOP Process Safety Information Checklist procedure 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 (M
SDSs). 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, ExxonMobil BRPO has documented safety-related limits for specific process parameters (e.g., temperature level, composition). ExxonMobil BRPO ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).



ExxonMobil BRPO 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, and electrical rating 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)



The ExxonMobil BRPO 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 the adequate controls are in place to manage these hazards.



The ExxonMobil BRPO facility 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 process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/
or mitigation measures when the team believes such measures are necessary.



The PHA team findings are forwarded to local and as necessary, 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 in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained.



To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and 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



The ExxonMobil BRPO facility 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 when a process change occurs. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process.



In addition, The ExxonMobil BRPO facility maintains guidance on how to respond to upper or lower limit exceedances for speci
fic process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.



Training



To complement the written procedures for process operations, The ExxonMobil BRPO facility has implemented a comprehensive training program for all employees involved in operating a process. New employees receive job specific basic training in ExxonMobil BRPO operations. After successfully completing this training, a new operator is paired with a qualified 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 are qualified and can work independently. In addition, all operators periodically receive refresher training to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. Qualification cards and computer based training records are maintained to verify completion and understanding of training.



Contractors



The ExxonMobil BRPO facility uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, ExxonMobil BRPO 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 ExxonMobil BRPO personnel of any hazards that they find during their work. This is accomplished by providing contractors with a handbook that includes (1) a process overview, (2) information about safety and health hazards, (3) emergency response
plan requirements, and (4) safe work practices prior to their beginning work. In addition, The ExxonMobil BRPO facility evaluates contractor safety programs and performance during the selection of a contractor. ExxonMobil BRPO personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.



Pre-startup Safety Reviews (PSSRs)



The ExxonMobil BRPO facility conducts a PSSR for any facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.



Mechanical Integrity



The ExxonMobil BRPO facility 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 that they c
an perform their jobs in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency 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. The ExxonMobil BRPO plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.



Safe Work Practices



The ExxonMobil BRPO facility 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 for equipment undergoing maintenance, (3) a procedure for 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), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.



Management of Change



The ExxonMobil BRPO facility has a comprehensive system to manage and document changes to all covered processes. This system requires that changes to items such as process equipment, chemical
s, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.



Incident Investigation



The ExxonMobil BRPO facility promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to ExxonMobil BRPO management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) 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.



Compliance Audits



To help ensure that the accident prevention program is functioning properly, The ExxonMobil BRPO facility 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. The audit team develops findi
ngs that are forwarded to ExxonMobil BRPO management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.



CHEMICAL-SPECIFIC PREVENTION STEPS



The processes at The ExxonMobil BRPO facility have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility.



Universal Prevention Activities



The accident prevention program summarized previously is applied to all RMP-covered processes at The ExxonMobil BRPO facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.



Specialized Safety Features



The ExxonMobil BRPO facility has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes:



Release Detection



1. Hydrocarbon detectors with alarms.



Release Containment/Control



1. Process relief valves that discharge to a flare to capture and incinerate episodic releases

2. Valves to permit isolation of the process (manual or automated)

3. Vessel to permit partial removal of the process inventory in the event of a release (e.g. dump tank)

4. Automated shutdown systems for specific process parameters (e.g., high temperature)

5. Curbing or diking to contain liquid releases

6. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)

7. Atmospheric relief devices



Release Mitigation



1. Fire suppression and extinguishing systems

2. Deluge system for specific equipment

3. Trained emergency res
ponse personnel

4. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus)

5. Blast-resistant buildings to help protect control systems and personnel



FIVE-YEAR ACCIDENT HISTORY



The ExxonMobil BRPO facility has not had any accidental releases during the past five years which meet the criteria for an accidental release per 40 CFR 68.42.



EMERGENCY RESPONSE PROGRAM INFORMATION



The ExxonMobil BRPO facility maintains a written incident response plan, which is in place to protect worker and public safety as well as the environment during an emergency. The plan 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 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 plan is updated when necessary based on modifications made to plant processes. The emergency response program changes are administered through management of change process, which includes informing and/or training affected personnel in the changes.



The overall emergency response program for the ExxonMobil BRPO facility is coordinated with the East Baton Rouge, Emergency Planning Committee. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local g
overnment officials, and industry representatives. The ExxonMobil BRPO facility has around-the-clock communications capability with the appropriate LEPC officials and emergency response organization (e.g. fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the ExxonMobil BRPO facility conducts periodic emergency drills that involve the LEPC and emergency response organization, and ExxonMobil BRPO provides annual refresher training to local emergency responders regarding the hazards of regulated substances in ExxonMobil BRPO.



PLANNED CHANGES TO IMPROVE SAFETY



The ExxonMobil BRPO facility has several elements of the management system of the accident prevention program in place to improve safety throughout the facility. These elements are part of an overall ongoing safety improvement process. The following elements of the management system are present to improve safety.



? Process Hazard Analysis

? Management of Change

? Compliance Audits

? Job Observations

? Implemented Loss Prevention System(c) behavior-based safety improvement program

? Incident Investigation (Loss and Near Loss Reporting)

? Contractor Safety Management