Aristech Chemical Corporation - La Porte Plant - Executive Summary
ARISTECH CHEMICAL CORPORATION |
LAPORTE, TEXAS PLANT
RMP EXECUTIVE SUMMARY
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES:
At Aristech Chemical Corporation - LaPorte Plant, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:
* A description of our facility and use of substances regulated by EPA's Risk Management Program (RMP) regulation
* A summary of results from our assessment of the potential offsite consequences from accidental chemical releases
* An overview of our accidental release prevention programs
* A five-year accident history for accidental releases of chemicals
regulated by EPA's RMP rule
* An overview of our emergency response program
* An overview of improvements made at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment
* The certifications that EPA's RMP rule requires us to provide
* The detailed information (called data elements) about our risk management program
STATIONARY SOURCE AND REGULATED SUBSTANCES:
Our facility produces prolypropylene using a variety of chemicals and unit operations. The process utilizes the regulated flammable substance propylene along with catalysts, hydrogen and ethylene as feedstocks. These reactants are polymerized in continuous stirred tank reactors with hexane as a carrier. The resulting slurry contains isotactic and atactic polypropylene. The former is dried and extruded into pellets while the latter is recovered by evaporation of the carrier which is recycled. The process contains the RMP-regulate
d substance propylene above the threshold quantity in storage vessels and numerous reactors, columns, tanks and piping within the unit. The process also utilizes titanium tetrachloride in quantities well below the RMP threshold quantity.
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS:
EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:
Worst-case Release Scenario(s) - Regulated Flammable Chemicals:
A horizontal propylene storage vessel fails, releasing the entire contents of the vessel to the
air in 10 minutes. (Storage quantity of the vessel is limited to 85% of the total capacity by company administrative procedure.) Ten percent of the released propylene ignites in a vapor cloud explosion. The EPA's Offsite Consequence Analysis (OCA) look-up tables were used to calculate the distance to the overpressure endpoint of 1 psi. This scenario would reach nearby off-site public receptors, the neighboring industrial facilities.
Alternative Release Scenario(s) - Regulated Flammable Chemicals:
The alternate release scenario consists of a 1-inch diameter pressure relief valve being knocked off the propylene supply pipeline located adjacent to the property line by a truck or backhoe. Propylene is released from the 1-inch hole due to line pressure. It is assumed that it takes 10 minutes to block the line/shutoff flow. Electronic LEL sensing devices are utilized throughout the facility to detect this type of leak. These devices will alarm when a release is detected. The prop
ylene vapor cloud could potentially be ignited by a motor vehicle passing through the area. Due to its close proximity to the facility property line, this scenario would reach close-by public receptors, the neighboring industrial facility.
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS:
Aristech Chemical Corporation - LaPorte Plant is in full compliance with OSHA's Process Safety Management (PSM) Standard. This standard is a fully comprehensive prevention program designed to prevent accidental releases of hazardous chemicals. We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including:
* Process safety information
* Process hazard analysi
* Operating procedures
* Mechanical integrity
* Management of change
* Pre-startup review
* Compliance audits
* Incident investigation
* Employee participation
* Hot work permit
We actively encourage participation from all employees in every aspect of process safety management. Process safety information on chemicals used, process technology and equipment design is readily available to all employees. Employees participate in HAZOP revalidation studies and HAZOP studies required by our Management of Change Program. Procedures are set up to provide knowledge to ensure employees perform their jobs safely and correctly. Employee suggestions for improvement are encouraged. Experienced employees are involved in training. Employees and contractors are trained and are included in the investigation of incidents and accidents.
As prescribed by our Management of Change policy, Pre-Startup Safety Reviews ensure that new installations or modific
ations are safe for startup and continued operation. Our Mechanical Integrity Program has written procedures to assure that affected process equipment is properly and safely maintained. The Aristech Hot Work Permit policy is strictly enforced to ensure that hot work in potentially dangerous areas does not occur.
These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.
Over the last year and half, the LaPorte Plant has been actively addressing the issue of Year 2000 (Y2K) readiness. The plant has been systematically identifying, evaluating, testing, and upgrading (where necessary) computer hardware, software, process control equipment, safety systems and emergency protection equipment
at the facility for Y2K readiness. In addition, impact assessments to evaluate potential business risks and exposures posed by Y2K have been conducted. The LaPorte Plant is also working to obtain assurances from vendors regarding readiness of their systems. The plant's Y2K activities have been communicated to LaPorte employees to enhance their awareness of the issues. The work on Y2K readiness is expected to be completed by October 1999.
FIVE-YEAR ACCIDENT HISTORY:
We keep records for all significant accidental chemical releases that occur at our facility. In the past five years, there have been no releases of propylene or other chemicals at the LaPorte Plant that have had an adverse impact on employees, the community, or the environment. If an incident were to occur, we would conduct formal incident investigations to identify and correct the root cause of the events.
EMERGENCY RESPONSE PROGRAM:
We maintain an emergency response plan which provides the essential planning an
d training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the Channel Industries Mutual Aid (CIMA) and community emergency response plans (LEPC). We utilize the CAER hotline to alert the community in the event of danger.
PLANNED CHANGES TO IMPROVE SAFETY:
The following is a list of improvements that we have implemented at the facility to help prevent and/or better respond to accidental chemical releases:
- Process control DCS system has been upgraded for more effective and efficient control of plant operations;
- Water-spray nozzles were installed in the process centrifuge areas.