CONDEA Vista Company - Executive Summary

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CONDEA Vista Company 
Baltimore Chemical Plant 
Risk Management Plan 
Executive Summary 
CONDEA Vista Company's Baltimore Chemical plant is committed to worker and public safety.  Our commitment is demonstrated by the resources we have invested to ensure that our processes are safely designed, operated and maintained by qualified personnel.  Our policy is to implement reasonable controls to prevent chemical accidents.  However, if a chemical release does occur, our trained personnel will respond in coordination with emergency responders from Baltimore City and the Maryland Department of the Environment to mitigate the release and protect public health and the environment. 
CONDEA Vista is committed to the Chemical Manufacturer Association's Responsible Care. initiative for safe management of chemicals.  The Responsible Care. Codes of Management Practices are integral to CONDEA Vista's Environmental, Health and Safety policy.  In particular, the Responsible Care. Community Awareness and Em 
ergency Response Code is designed to assist emergency preparedness and foster community right-to-know, and the Process Safety Management Code is designed to prevent chemical accidents. 
CONDEA Vista's Baltimore plant uses by-products from petroleum refinery operations to produce linear alkylbenzene (LAB) and other specialty chemicals.  LAB is used in the production of household detergents.  The Baltimore plant uses chlorine to promote chemical reactions within the LAB process.  The chlorine is converted to hydrogen chloride gas, which is absorbed into water to produce hydrochloric acid.  Both chlorine and hydrogen chloride gas are regulated toxic substances.  The Baltimore plant also uses propane as a fuel in the plant's flare.  Propane is a regulated flammable substance. 
The worst case scenario for a regulated toxic substance at the Baltimore plant involves catastrophic failure of a full chlorine tankcar and release of 180,000 pounds of chlorine.  The USEPA's RMP Comp software was us 
ed to estimate the maximum distance to the toxic endpoint (8.7 milligrams per liter).  The maximum distance to the toxic endpoint in the worst case scenario is 14 miles. 
The alternative case scenario for chlorine involves release of chlorine from a ruptured unloading hose on a chlorine tankcar, with failure of the excess flow check valve in the chlorine tankcar.  The USEPA's RMP Comp software was used to estimate the chlorine release rate and the distance to the toxic endpoint.  The distance to the toxic endpoint in this scenario is 0.8 miles. 
The alternative case scenario for hydrogen chloride gas involves release of hydrogen chloride gas from a ruptured pipe in the LAB process.  The release rate used in this scenario is the maximum hydrogen chloride gas generation rate that the LAB process can produce.  The USEPA's RMP Comp software was used to estimate the distance to the toxic endpoint (30 milligrams per liter).  The distance to the toxic endpoint in this scenario is 0.8 miles. 
The worst case scenario for a regulated flammable substance at the Baltimore plant involves catastrophic rupture of a full propane tank and release of 65,000 pounds of propane.  This inventory is assumed to ignite and produce a vapor cloud explosion.  The USEPA's RMP Comp software was used to estimate the maximum distance to the 1-psi overpressure endpoint.  The distance to the 1-psi overpressure endpoint in this scenario is 0.3 miles. 
The alternative case scenario for propane involves release of propane from a ruptured propane pipe.  The released propane is assumed to ignite and produce a vapor cloud fire.  The USEPA's RMP Comp software was used to estimate the distance to the lower flammability limit endpoint (36 milligrams per liter).  The distance to the lower flammability endpoint in this scenario is 0.1 miles. 
With the exception of the worst case scenario for toxic regulated substances, all endpoints are within the Fairfield peninsula of Baltimore City.  The alternative case sc 
enarios selected for this RMP involve circumstances and emission rates that have never occurred at the Baltimore plant, and are therefore highly improbable. 
Process Safety Information 
The Baltimore plant maintains a variety of technical documents that are used to help maintain safe operation of plant processes.  These documents address chemical properties and associated hazards, limits for key process parameters, specific chemical inventories and equipment design basis/configuration information.  Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information.  Employees are provided training on how to locate the information from computer terminals. 
Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS).  This information is supplemented by documents that address known corrosion concerns and hazards associated within i 
nadvertent mixing of specific chemicals.  Safety related limits for specific process parameters (e.g. temperature, pressure, composition, etc.) have been documented.  Processes are maintained within these limits using process controls, monitoring instruments, protective instrument systems and trained personnel. 
The Baltimore plant also maintains an electronic database, accessible to both employees and contractor supervision, which provides information about the design and construction of process equipment.  This information includes materials of construction, design pressure and temperature ratings, electrical classification, etc.  In combination with written procedures and trained personnel, this information 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 comprised. 
Process Hazard Analysis (PHA) 
The Baltimore plant has a comprehensive program 
to help ensure that the 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. 
The Baltimore plant 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.  HAZOP analyses are conducted using a team of people who have operating and maintenance experience and engineering expertise.  The team identifies and evaluates hazards of the process and accident prevention and mitigation measures, and makes recommendations for additional prevention and/or mitigation measures where deemed necessary. 
HAZOP team findings are made available to personnel who operate and maintain the process for comments, and forwarded to management for resolution.  Implementation of mitigation options 
in response to PHA findings is based on a relative ranking assigned by the PHA team.  This ranking helps ensure that potential accident scenarios assigned the highest rank receive immediate attention.  All approved mitigation options that are implemented in response to PHA findings are tracked until complete.  The final resolution of each finding is documented and retained. 
Operating Procedures 
Operators, supervisors and plant engineers work together to develop and maintain operating procedures.  These procedures define how tasks related to process operations are safely performed.  At the Baltimore plant, operating procedures are used to train employees and serve as reference guides for appropriate actions to take during both normal operations and process upsets.  Operating procedures include: 
7 Steps for safely conducting activities 
7 Applicable process safety information, such as safe operating limits, 
7 Safety and health considerations, such as chemical hazards, personnel protect 
ive equipment required and steps to take if exposed to a particular chemical. 
Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operation, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. 
The Baltimore plant trains its workers to safely and effectively perform their assigned tasks.  The training program includes both initial and refresher training. 
All new operators receive several weeks of comprehensive training before being assigned to a specific operating position.  This training includes training on specific types of equipment, such as pumps and compressors, a general overview of the process, properties of hazardous substances in the process and a detailed review of complex procedures such as safe work practices and emergency response.  Written tests are used to verify that employees understand the training material before a 
new employee can report to a process unit.  When a new employee reports to a particular process unit, he/she then receives detailed training with respect to process specific procedures.  When the new hire has demonstrated, through hands-on demonstration in the field, mastery of process specific operating procedures for specific tasks, he/she is allowed to begin work in a specific operating position. 
Refresher training covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process, and (3) a detailed review of the process operating procedures and safe work practices.  Demonstration in the field is used to verify that employees understand the training before an employee can resume work in the process.  Operators are consulted in safety meetings and through questionnaires regarding effectiveness and frequency of training.  Recommendations are reviewed and changes to the training program are implemented as appropriate. 
Management of Change 
The Management of Change procedure at the Baltimore plant evaluates all proposed changes to chemicals, equipment, procedures and controls within covered processes to help ensure that a change does not adversely affect the safety of plant operations.  Proposed changes are reviewed and approved by qualified personnel, process safety information and procedures are updated, and affected employees are notified of the change. 
Pre-Startup Safety Review (PSSR) 
The Baltimore plant conducts a safety review of new and modified processes before the process is placed in service.  The purpose of the PSSR is to ensure that processes, procedures and personnel are appropriately prepared for startup prior to startup.  The review provides an additional check to make sure that construction is in accordance with 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 co 
nstruction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. 
Mechanical Integrity 
The Baltimore plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, emergency shutdown systems and rotating equipment (pumps and compressors) in a safe operating condition.  The basic aspects of this program include (1) maintenance procedures, (2) personnel training in maintenance procedures, (3) equipment inspections and testing, (4) correction of identified deficiencies, and (5) quality assurance measures.  In combination, these activities form a system that maintains the mechanical integrity of the process. 
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.  Written procedure 
s 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, equipment is repaired in a timely manner.  All outstanding deficiencies are tracked until corrective action has been implemented and documented. 
Another integral part of the mechanical integrity program is quality assurance.  The Baltimore plant incorporates quality assurance into equipment purchase and repairs. This helps ensure that new equipment is suitable for intended use and that proper materials and spare parts are used when repairs are made. 
Safe Work Practices 
The Baltimore plant has a long-standing safe work program in place to ensure worker safety.  Examples of the program include (1) control of the entry/presence/exit of support personnel, (2) lockout 
/tagout procedures to ensure 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 procedures to conduct spark producing activities (i.e, hot work), (5) a permit and procedures to ensure that adequate precautions are in place before entry into a confined space, and (6) procedures to ensure that hazardous jobs are closely coordinated by qualified supervision.  These procedures, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 
Incident Investigation 
The Baltimore plant investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public or the environment in order to prevent similar incidents from occurring in the future.  Plant employees are trained to identify and report any incident requiring investigation.  Investigations are ini 
tiated within 48 hours of an incident.  Depending on the incident, an investigation team may be formed. Results of investigations are documented and appropriate changes are made. 
Employee Participation 
The Baltimore plant maintains a written employee participation program to help ensure that safety and environmental concerns of plant workers are addressed.  The plant encourages active participation of personnel in safety, health and environmental programs at the plant.  Employees are involved in all aspects of the prevention program, including PHAs (Process Hazard Analyses), development of operating procedures, management of change and incident investigations. 
Compliance Audits 
The Baltimore plant audits chemical processes to be certain that the prevention program effectively addresses safety, health and environmental requirements. The audit team may include consultants or CONDEA Vista personnel who are knowledgeable in plant processes.  The team evaluates whether the prevention pr 
ogram satisfies the requirements of the RMP rule and whether the prevention program is sufficient to ensure safe operation of the plant.  The results of the audit are documented, recommendations are resolved and appropriate enhancements are made to plant operations. 
The Baltimore plant has established a program to help ensure that contractor activities are performed in a safe manner.  The program reviews the safety record of contractors to ensure only contractors who can perform the desired task safely are hired.  The plant communicates to contractor supervisors the hazards of the process on which they and their employees will work, Baltimore plant safe work practices and Baltimore plant emergency response procedures.  The plant requires that contractor supervisors train each of their employees on hazards and procedures specific to the Baltimore plant.  The plant periodically reviews contractor training documents and work performance to help ensure that safe practices ar 
e followed. 
Five Year Accident History 
The Baltimore plant experienced one accidental release during the last five years that involved regulated substances and resulted in on-site injuries and property damage.  On October 13, 1998 a chemical reactor overpressured and failed catastrophically during performance of a process shutdown procedure.  A mixture of hydrogen chloride gas, hydrogen and combustible hydrocarbons was released from the reactor and ignited.  The subsequent fire injured five workers on-site and damaged the LAB process unit.  Based on video footage of the fire, emissions modeling, forensic evidence and failure analysis by expert consultants, no persons off-site could possibly have required hospitalization or medical treatment due to exposure to toxic concentrations, radiant heat or overpressure.  The Baltimore City Fire Department immediately responded and extinguished the fire.  There was no need to evacuate or shelter-in-place persons off-site, and there was no prope 
rty damage or environmental damage off-site.  The principal cause of the accident was human error. 
Emergency Response Program 
The Baltimore plant emergency response program has been developed to meet the emergency planning, response, and notification requirements of the following regulations: 
7 OSHA 29 CFR 1910.38 (a) - Employee Emergency Action Plans 
7 OSHA 29 CFR 1910.120 (q) - Hazardous Waste Operations and Emergency Response (HAZWOPER) 
7 OSHA 29 CFR 1910.110 (n) - Process Safety Management of Highly Hazardous Chemicals 
7 OSHA 29 CFR 1910 Subpart L - Fire Protection 
7 EPA 40 CFR Part 302.6 - Notification Requirements 
7 EPA 40 CFR part 355.40 - Emergency Planning and Release Notification 
7 EPA 40 CFR Part 68 - Risk Management Programs for Chemical Accidental Release Program 
7 EPA 40 CFR Part 355.30 - Facility Coordinator and Emergency Response Plan 
7 EPA 40 CFR Part 112 - Facility Response Plan 
7 EPCRA 302 - List of Extremely Hazardous Substances 
The emergency response strategy fo 
r the Baltimore plant is to prevent and/or control emergency situations via the use of engineering, design and fixed protection systems.  Plant personnel, in combination with the Baltimore City Fire Department, are available 24 hours per day and trained to respond and take actions to contain, control and mitigate any release that might occur.  Emergency responders have access to on-site and off-site emergency equipment that is appropriate for situations that could possibly occur at the plant.  In addition to the considerable on-site resources, the Baltimore plant is a member of the South Baltimore Industrial Mutual Aid Program (SBIMAP).  This membership allows the plant (if needed) to draw on the emergency response resources of other industries in the immediate area. 
Drills are periodically conducted either individually or jointly with the LEPC and SBIMAP to assess emergency response at the Baltimore plant and/or the surrounding district. 
The Baltimore plant is a participant in the c 
ommunity planning process cooperating with the Baltimore City Local Emergency Planning Committee.  A copy of the plant's Emergency Response Plan has been forwarded to the Baltimore City Fire Department per the requirements of 40 CFR 355.   
Planned Changes to Improve Safety 
The Batimore plant constantly strives to improve safety and reduce risk through auditing, suggestions from employees, incident investigations, advancements in technology and the use of engineering standards and specifications.  For example, new process technology is currently being developed that will eliminate chlorine use in the LAB process within 3 years.
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