Montell USA Inc. Lake Charles Plant - Executive Summary |
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MONTELL LAKE CHARLES RISK MANAGEMENT PROGRAM 1253 LDEQ Facility ID Number SOURCE AND PROCESS DESCRIPTION The Montell Lake Charles facility has three Program 3 covered processes described as follows: 1) Polyethylene: This is a gas phase polyethylene process, operated via Montell's patented Spherilene technology. The process includes storage vessels containing the following maximum intended inventories: 1-Butene - 353,000 lbs.; Propane - 412,000 lbs. 2) Polypropylene: The polypropylene process is operated via Montell's patented Spheripol technology. The process includes a storage vessel and a pipeline segment containing the following maximum intended inventories: Propylene Storage - 934,000 lbs.; Propylene Pipeline - 13,203 lbs. 3) Ultrahigh Molecular Weight Polyethylene (UHMW): The UHMW process has a covered inventory of titanium tetrachloride. The maximum intended inventory of the titanium tetrachloride storage vessel is 6,400 lbs. SUMMARY OF MAJOR HAZARDS Two worst case flammable scenarios have been selected due to potential impact on different public receptors: 1) Release of the entire contents of the 1-Butene storage vessel in the polyethylene process and subsequent vapor cloud explosion has a 1 psi endpoint that would reach a residential population. 2) Release of the entire contents of the propylene pipeline segment has a 1 psi endpoint that would reach the adjacent industrial complex. The 1 psi endpoint from the alternative flammable release scenario does not reach a public receptor. The worst case toxic release scenario is the release of the entire inventory of the titanium tetrachloride storage vessel in the UHMW process. The ERPG 2 concentration in this scenario would reach a residential population. Although the alternative toxic release of titanium tetrachloride would reach a small residential population if no action was taken, it is believed that emergency response b y operations using water spray from fixed fire monitors would prevent the release from leaving the site. ACCIDENT PREVENTION Most processes at the Montell Lake Charles Plant are covered by 29 CFR 1910.119, the OSHA Process Safety Management (PSM) Standard that requires that each operation be subjected to a detailed Process Hazards Analysis (PHA). As a member of the Chemical Manufacturers Association, Montell is also committed to the Responsible Careb Codes of Management Practices. The Process Safety Code of Responsible Careb requires that all processes at the Lake Charles Plant be subjected to a PHA. The hazards analyses for all Lake Charles Plant processes have been completed, and all safety improvements have been implemented. Any changes to processes (procedures, raw materials, process conditions, etc.) or plant equipment following the PHA must follow the Management of Change (MOC) procedure whereby a team, selected on the basis of expertise and experience, reviews the chang e to determine if there is any impact on safety, health or environment as well as the technical feasibility. The MOC team will track and document completion of requirements, such as procedure revision and operator training, before approving the implementation of the change. All PHA's are revalidated at least every five years, and the PHA and revalidation documentation is retained for the life of the process. The PSM Standard requires that each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, be trained in an overview of the process and the operating procedures, including safety, health, emergency operations, shutdown, and safe work practices. At the Lake Charles Plant both classroom and field training accomplish this, and written tests and field observation verify understanding of the training. Maintenance and contract maintenance employees are trained, not only in the craft skills and repair procedu res, but, also, in the safety and environmental aspects of their job. Refresher training for operators and maintenance personnel is conducted at least every three years and more often if necessary. Training on certain safe work practices (e.g. hot work, confined space entry) is conducted annually. Safety Design Criteria (SDC), based on Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), and Montell's long history of safe operation of our unique technologies world wide, are developed and documented for each process type (e.g. Spheripol Polypropylene, Spherilene Polyethylene). Pre-startup Safety Reviews (PSSR) are conducted to verify compliance prior to startup. PSSR is also conducted as a step in the MOC process when there is an equipment change or modification. The Lake Charles Plant has a formal Mechanical Integrity Management System that defines the frequency and protocol of preventive maintenance which sustains the mechanical integrity of critical process eq uipment such as pressure vessels, storage tanks, piping systems, pressure relief valves, pumps, emergency shutdown systems (interlocks) and control systems (such as chemical detectors and monitoring devices). The Lake Charles Plant has over 300 atmospheric detectors that alarm if a very low level of chemical release is detected. This gives operating and maintenance personnel early warning of a problem which can then be corrected before it presents a hazard to employees or the community. EMERGENCY PREPAREDNESS The Montell Lake Charles Plant has a written Emergency Response Plan which details the responsibilities of employees during emergency situations including fire, explosion, chemical release and process deviations. Each shift has a well-trained Emergency Response Team led by Incident Commanders who are normally the operations Shift Team Leaders. The Emergency Response Team members receive annual training at the Lamar University Fire Training Center, and the Incident Comman ders receive additional leadership training. The plant has a dedicated emergency phone extension that is used to alert the Plant's Security Officers that an emergency situation exists. The Security Officer then activates the plant alarm system that is coded to identify the location and nature of the emergency. The Emergency Response Team then switches to a dedicated emergency radio channel and responds according to the instructions from the Incident Commander. The Emergency Response Team on each shift participates in a practice drill once per month. Although the drills are scripted in advance, the Response Team members are not informed of the location or nature of the drill. Observers time each step of the response and record the quality of the response. After the drill, the observers and team members meet and critique the drill to allow continuous response improvement. Emergency Response Team members and other employees who will be expected to respond to a release of hazardous materials receive Hazardous Waste and Emergency Response (HAZWOPER) training as required by OSHA (29 CFR 1910.120) and employees who are involved with the transport of hazardous materials receive Hazardous Materials (HAZMAT) training as required by the DOT. All Lake Charles Plant employees receive annual fire extinguisher and fire hose handling training. The Lake Charles Plant has written procedures on emergency preparedness for other unusual situations such as hurricanes and bomb threats. Each of the process areas has backup emergency electrical power and instrument air to allow a safe shutdown in the event of an electrical power failure. Montell is an active participant in Southwest Louisiana Mutual Aid whose mission is "the joining together of fire fighting, rescue, first aid and law enforcement personnel, and facilities among LA industries and municipalities for mutual assistance in case of emergency situations." Should the need for additional equipment or resources arise dur ing an emergency, the Incident Commander can call upon Mutual Aid for assistance. COMMUNITY SAFETY Through active participation in the Calcasieu CAER (Community Awareness and Emergency Response) Group and the Calcasieu Parish Local Emergency Planning Committee (LEPC), Montell is involved in developing and maintaining the system designed to protect the community in the event of a chemical emergency. A network of sirens is in place to immediately alert the community of a chemical emergency and the need to monitor radio and TV for instructions from the LEPC. Montell also has a telephone "call down" system which will alert the immediate neighbors of a chemical emergency at the Lake Charles Plant. Lake Charles Plant personnel have helped distribute literature containing instructions on what to do when the siren sounds. Detailed steps are included for Shelter In Place, Evacuation and Protect Your Breathing as well as radio and TV channels that will be giving instructions from the L EPC. Montell engineers have performed detailed risk assessment studies using state of the art computerized vapor cloud modeling programs. Where the risk assessments indicated reasonable potential for off-site impact, equipment and procedures have been put in place to mitigate that off-site impact. INCIDENT HISTORY 40 CFR 68.42, the US Environmental Protection Agency (EPA) requires covered industries to report a five-year accident history in their Risk Management Plan based on the following guidelines: "all accidental releases from covered processes that resulted in deaths, injuries or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage or environmental damage." The Montell Lake Charles Plant has had no incidents in the past five years which meet these criteria. COMMUNITY OUTREACH The CMA requirements for achieving "Practice In Place" for the Responsible Careb codes of management practice (which Montell achieved in 1997) involve a lot of interaction with the community. Although Responsible Careb has certainly increased these activities, Montell Lake Charles has always sought to be a good corporate neighbor. Examples of this are participation in the "Adopt-A-Road" program since 1992 and the adoption of T.S. Cooley Elementary Magnet School as our Partner In Education in 1988. Working with T.S. Cooley, Montell has provided tutors, judges for science and math fairs, chemistry experiments, financial assistance for field trips and competitions and U.S. Savings Bonds for graduates. At Christmas, the students come to the plant and perform a holiday program for employees. Montell Lake Charles has a standing invitation to the community for plant tours, which is published in local print media. Over 1,000 people attended one recent plant tour, which was open to the public. Another popular event was the "Teacher's Shadow Day" during which area teachers spent a day following the work activit ies of individual employees to gain a better understanding of what chemical plant workers do and what the academic requirements are to obtain chemical plant jobs. Montell Plant management is an active participant with the Calcasieu Community Advisory Panel (CCAP). Typical topics of discussion at CCAP meetings are individual plants' safety and environmental objectives and performance, incident investigations, products and processes, financial performance and outlook, expansion plans and impact on the community, and Responsible Careb activities. In addition to scheduled presentations by plant representatives, LEPC members and technical experts (environmental, medical, etc.), the CCAP meetings provide an open forum for community members to question plant management about their concerns relative to plant operations and to provide feedback from the community at large. Montell participates in sponsoring attendance of CCAP members to CMA's "Building Communities Together" workshop. The wo rkshop, which was attended by CAP members and industry representatives from around the country as well as CMA leadership and regulatory officials, was reported to be very informative by CCAP attendees. PLANT HISTORY Beginning in 1959 the Lake Charles facility was owned and operated by Hercules Incorporated; in 1983 Hercules merged their polypropylene business with the polypropylene business of Montedison S.p.A. of Milan, Italy to form Himont; in 1995 Montell was formed through the merger of the majority of the polyolefins interest of Royal Dutch/Shell Group of Companies with those of Montedison S.p.A. including Himont Incorporated. In 1997 Shell acquired the Montedison 50% interest in Montell Polyolefins. The Lake Charles plant is Montell's largest site in North America with over 500 full-time employees. The plant now occupies 285 acres of land on the corner of Highway 108 and Bayou d'Inde Road with an annual production of 1.4 billion pounds. PRODUCT INFORMATION Montell Pol yolefins is a worldwide organization dedicated to the development, manufacturing and marketing of a diverse range of polyolefins. Olefins are hydrocarbon byproducts of oil refining such as propylene and ethylene. When propylene or ethylene undergo a process called catalytic polymerization, polypropylene or polyethylene, commonly called plastic, are formed. At the Lake Charles Plant we manufacture polypropylene and polyethylene resins using Montell patented technology called Spheripol (polypropylene) and Spherilene (polyethylene). Where will you find Montell's polyolefin resins? In the energy-absorbing bumpers on your car. In the siding that protects your home from the elements. In medical gowns. Syringes that administer life-saving medication. Shatter-proof packaging that's safer for children. Bicycle helmets that protect us from injury. And in the plastic wrap that keeps our food fresh. The Lake Charles Plant is one of only two sites in North America that manufactures Ultrah igh Molecular Weight Polyethylene (UHMW). UHMW resin has some unique properties that allow its use in some very unusual applications where strength and durability are required. Montell's UHMW is used to produce the strongest fishing line for a given diameter known to man (SpiderwireT), the bullet-proof vests which protect our law enforcement personnel and you may even find it in your kitchen in the form of a cutting board. Among Montell's unique technological developments is Hivalloy engineering resin alloys, a revolutionary new generation of high performance plastics. The Lake Charles Plant is the only location in the world where this unique plastic is being produced. Hivalloy engineering resin alloys offer a balance of mechanical properties that perform like traditional engineering polymers, but provide superior chemical resistance, processability, moisture resistance and dimensional stability. In addition, Hivalloy resins are significantly lower in density and produce more pa rts per pound, resulting in up to 30% cost savings on raw materials for our customers. Hivalloy resins can be used in a broad range of applications, including automotive, power tool, electronic/electrical equipment, and recreational equipment. |