Phillips Puerto Rico Core Inc. - Executive Summary |
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Executive Summary Phillips Puerto Rico Core Inc. Risk Management Plan Submittal ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Phillips Puerto Rico Core Inc. (PPR Core) is committed to protecting the health and safety of employees, the public and the environment. PPR Core takes seriously the obligation to provide information to the community, as well as to actively participate in community emergency planning and community right to know. This includes public access to information on chemicals manufactured, handled and stored within the facility. PPR Core's policy is to implement controls to prevent foreseeable releases of regulated substances through engineering design, installation, operation and maintenance of the processes in the facility. However, if a release does occur, PPR Core trained employees shall respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED PPR Core is a petrochemical plant located on the southeast coast of the island of Puerto Rico. The facility is situated approximately 2.5 miles southwest of the town of Guayama and approximately 0.25 miles from the Caribbean Sea. The operating facilities include a series of petrochemical units designed to produce a select, high purity group of aromatic hydrocarbons. Motor fuel gasoline is also produced during this process. Feedstock Naphtha - 30,000 bbls per day Mixed-xylenes - 5,000 bbls per day Products Paraxylene - 8,250 bbls per day Cyclohexane - 9,300 bbls per day Orthoxylene - 1,750 bbls per day Gasoline - 14,000 bbls per day General Process Flow a) Reform naphtha to produce benzene, toluene, xylene (BTX) and hydrogen b) Extract BTX to high purity c) Recombine hydrogen with benzene to produce cyclohexane d) Convert toluene to benzene and mixed xylenes e) Separate paraxylene and orthoxylene from the mixed xylenes f) Remainder is blended and sold as motor fuel gasoline All feedstocks and most product shipments are via tankers through the marine dock facility. All of the gasoline, and a small amount of toluene, xylene, and cyclohexane, is loaded via tank trucks at the truck loading rack for use on the island. Aromatics produced at Core serve as building blocks for many chemicals produced by our customers. Paraxylene is used as a feedstock for producing polyester (poly/ cotton blend fabrics) and PET resins (soft drink bottles, X-ray film such as Mylar). Orthoxylene is used to produce various plasticizers and polyesters. Cyclohexane is used to produce nylon. In these processes, PPR Core has identified one toxic and two flammables that exceed the threshold levels established by the List Rule of the Clean Water Act. The flammables identified are butane and pentane. PPR Core has two chlorine cylinders used for water treatment in the facility containing 2,000 pounds of chlorine each. The butane is stored in 4 spheres with two spheres containing 2,837,268 pounds each and two spheres containing 1, 891,512 pounds each. Pentane is stored in two spheroids each with a capacity of 6,951,306 pounds. OFF-SITE CONSEQUENCE ANALYSIS (WCS & ARS) Worst Case Release Scenarios (WCS) and Alternate Release Scenarios (ARS) were developed for the toxics and flammables identified in the facility using the EPA's RMPComp program and/ or the modeling program PHAST. All eight covered processes were examined for the determination of the Toxic and Flammable WCS and ARS for the facility. Populations affected are based on census data. A 1-ton chlorine cylinder was used for both the toxic WCS and ARS as it is the only toxic material in the facility meeting the established threshold. The modeling program PHAST was used for the determination of the WCS release due to the lack of real world results supplied by the RMPComp program. RMPComp was used for the Toxic ARS. The Toxic WCS Chlorine indicates that the liquid spill and vaporization of the chlorine would travel 2.90 miles and affect a population of 41,591. The Toxic WCS Chlorine models the total release of the 1-ton cylinder inventory instantaneously and does not take credit for secondary containment or employee response. The Toxic ARS Chlorine was developed as a more realistic scenario in which a transfer line is broken. Based on the diameter of the transfer hose, the calculated amount of chlorine to be release in 10 minutes was 130 pounds of chlorine. After 10 minutes, it is estimated that active mitigation would occur. A release of this size would travel .43 miles and affect a population of 114. The Flammables WCS was determined by modeling each of the spheres and spheroids in RMPComp and choosing the vessel release that traveled the greatest distance. Again, for the Flammables WCS, no secondary containment was considered and the vessel contents were modeled as an instantaneous release of the total contents of the vessel. The Flammable WCS selected was a Pentane Spheroid releasing 6,951,306 pounds instantaneously. The distance affected was calculated at 1.52 miles and affecting a population of 1,699. The Flammables ARS was determined by modeling a more realistic release of 4,503 pounds of butane from a 2-inch opening release for 30 minutes from the bottom of one of the Butane Spheres. The distance to the endpoint was calculated at .06 miles. A release of this size would affect population of two (2) people. Passive mitigation considered included dikes, sprinkler/ deluge systems and relief valves. GENERAL ACCIDENT RELEASE PROGRAM PPR Core utilizes an Operating Excellence Plan to identify improvement opportunities in the areas of employee involvement, productivity, quality and loss prevention. Through the Operating Excellence Plan, PPR Core identifies areas in which people, systems and assets can be managed to maximize operating reliability and reduce the potential for releases in the facility. Following are some of the areas in which the general accident release program is supported by th e Operating Excellence Program. Employee Participation PPR Core encourages employees from all levels to participate in all facets of process safety management and accident prevention in the facility. Examples of employee participation range from subcommittees developed to review and revise safety standards to participating as a member of a process hazard analysis (PHA). In addition, PPR Core supports employees by providing roles and responsibilities, training in safety and loss prevention, encouraging employee involvement through key performance measures and visitations to local area schools by employees to discuss the risks and rewards of the local chemical industry. Systems PPR Core uses various systems to enhance the release prevention program in specific ways. Through process hazard analysis (PHAs), regulatory compliance and third party audits, incident investigations, standards and procedures, evaluation of contractor performance, PPR Core works to reduce the probability th at a release will occur. Assets PPR Core uses engineering design and mechanical reliability elements to minimize release potential and to ensure potential releases are controlled at the source. This includes the evaluation of system designs and areas for improvement. In addition, PPR Core ensures all employees understand the impact of their actions on pollution. PPR Core also uses risk management to lessen identified risks to acceptable levels through the use of a risk identification, assessment and management system. FIVE-YEAR ACCIDENT HISTORY PPR Core has an excellent record of accident prevention over the last five years. No incidents resulted in off-site impacts. EMERGENCY RESPONSE PROGRAM INFORMATION PPR Core maintains a comprehensive emergency response plan to prepare for and manage all emergencies affecting the facility or the community. The plan includes: the Emergency Action Plan, Incident Command System - Management, Incident Command System - Unit Leader Guidelines , Emergency Response Team Manual, Emergency Equipment Inventory, Emergency Response Standard Operating Guidelines, Fire Preplans, Mutual Aid, Emergency Equipment Operating and Training Manual, Facility Response Plan, Training Lesson Plans, Fire Pump Maintenance and Inspection, and Storage Tank Fire Preplans. Employees in the facility are organized into the Initial Response Team, the Volunteer Fire Brigade, Specialty Teams and Incident Command System. The Initial Response Team, which consists of operators for 24-hour coverage, acts as first responders to releases and other incidents. The Volunteer Fire Brigade consists of employees from all levels throughout the facility to manage all incidents beyond the incipient stage. Members of both the Initial Response Teams and the Volunteer Fire Brigade are assigned to specialty teams for additional response capabilities and specialty training. These specialty teams include the Hazardous Materials Team, the Rescue Team, the Equipment Operat ors Team, and the Emergency Medical Service Team. The Incident Command System also provides a structure for management personnel to support the field response organization and involves office personnel from the president down. Emergency response personnel receive approximately 64 hours per year of specialized training in addition to on the job training and drills. PLANNED CHANGES TO IMPROVE SAFETY PPR Core intends to continue to use the Operating Excellence Plan to enhance employee involvement, facility productivity, quality, and loss prevention. In addition to the goals outlined by the Operating Excellence Plan for the facility's people, systems and assets, PPR Core will respond to PHA requirements, corporate regulatory audits and incident investigation findings and shall continue to strive to be considered a valued partner in our community. |