Aristech Chemical Corporation - Neal, WV Plant - Executive Summary

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Accidental release prevention and emergency response policies:      
The Aristech Chemical Corporation - Neal Plant is committed to operating and maintaining all of our processes in a safe and responsible manner.  As a member of the Chemical Manufacturer's Association (CMA) we are committed to CMA's Responsible Care initiative and work closely with others in the industry and community to address environmental and safety concerns.   The Neal Plant is committed to a continuing effort to improve the industry's responsible management of chemicals. We pledge to manage our business according to these principles: 
To recognize and respond to community concerns about chemicals and our operations. 
To develop and produce chemicals that can be manufactured, transported, used and disposed of safely. 
To make health, safety and environmental considerations a priority in our planning for all-existing and new products and processes. 
To repo 
rt promptly to officials, employees, customers and the public, information on chemical-related health or environmental hazards and to recommend protective measures. 
To counsel customers on the safe use, transportation and disposal of chemical products. 
To operate our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public. 
To extend knowledge by conducting or supporting research on the health, safety, and environmental effects of our products, processes and waste materials. 
To work with others to resolve problems created by past handling and disposal of hazardous substances. 
To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment. 
To promote the principles and practices of Responsible Care by sharing experiences and offering assistance to others, who produce, handle, use, transport or dispose of chemicals.  
The Neal Pla 
nt uses 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 protect the environment.  This document provides an overview of the comprehensive risk management activities that the Neal Plant has implemented. 
The stationary source and regulated substances handled: 
The Neal Plant of Aristech Chemical Corporation was one of the first sites to produce polypropylene in the United States.  The original facilities were brought on line in 1961.  Since then, the uses and demand for polypropylene have grown steadily.  In response, the facilities have been expanded and updated several times, most recently in 1988 with the installation of state-of-the-art Spheripol loop reactors and in 1989 and 1995 with the addition of the latest extrusion technology.  This new technology not only assures customers of a long-term, high quality and consistent source, but it has also made the plant mor 
e energy efficient and environmentally advanced. 
The Neal Plant's polypropylene production process utilizes the regulated flammable substances, propylene and propane, along with catalysts and hydrogen as feedstocks. 
The areas of the plant that are covered by the Risk Management Plan are: 
Propylene and Propane Storage (Area 10) 
Propylene Distillation (Area 11) 
Polymerization Unit  (Area 91) 
Propylene RR Tank Car Unloading 
The worst-case scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. 
Worst-Case Scenario - The failure of the largest propylene storage tank  when filled to the greatest amount allowed is considered the worst case scenario at the facility.  The Operations Department limits the maximum filling of this tank to a level of 80% (88% of the maximum volume).  It is assumed that the entire contents are released as vapor, which finds an ignition source.  Ten percent  
of the released quantity is assumed to participate in the resulting vapor cloud explosion.  This scenario would reach nearby offsite public receptors.  
The storage tanks are equipped with a water curtain system to cover the tanks with a large volume of water in order to cool the tanks in case of fire and to disperse vapors.  The use of the water curtain system to disperse the vapor cloud was not considered in the calculation of the release rate, in accordance with regulatory requirements. 
Alternative-Case Scenario -The Alternative-Case Scenario is defined as a release with off site consequences that is more probable than the Worst-Case Scenario.  At the Neal Plant this scenario is a "pull-away" at one of the Rail Road Unloading Stations and the subsequent release of the contents of a propylene tank car.   It is assumed the released propylene vapor finds an ignition source, resulting in a vapor cloud explosion. This scenario would reach nearby offsite public receptors.  
The Alternati 
ve-Case Scenario does not consider the use of any of the following protection and mitigation systems that are in place at this facility: 
- The railcars that are being unloaded are "chocked" to prevent movement.  Also, derailers are used to protect the unloading stations from cars on the other tracks. 
- The railcars are equipped with excess flow valves that would shut upon separation of the unloading hose. 
- The Rail Road Unloading Stations are equipped with a water curtain system to cover the tank cars with a large volume of water in order to cool the tank cars in case of fire and to disperse the vapor cloud.   
- The Rail Road Unloading Stations are equipped with hydrocarbon detectors that will alarm in the control room if there is a release. 
The general accidental release prevention program and the specific prevention steps: 
The Neal Plant is in full compliance with the OSHA Process Safety Management Standard, which includes the following elements: 
It is the policy of the Neal Plant to involve all employees in the safety program.  It is essential that employees are trained properly to perform their jobs safely and that the experience and knowledge of employees is used to maintain and improve the safety of the plant.  In order to fulfill this policy the following elements of employee participation in the Neal Process Safety Management System are detailed below: 
The primary method for Process Hazard Analysis  (PHA) used at the Neal Plant is the Hazard and Operability Study  (HAZOP) technique.  HAZOP meetings are conducted routinely to analyze the safety of selected areas of the plant and to analyze changes that are initiated by the FOC (Facility or Operational Change) procedure. The HAZOP is conducted by a team that is composed of employees who have experience and knowledge specific to the process being evaluated and at least one member 
who is knowledgeable of the HAZOP methodology.   The membership of the HAZOP committee includes at least one member of the PACE (Paper, Allied Industrial, Chemical and Energy Workers International Union) Union in the affected area of the study.    The results of the HAZOP are posted in the affected area control room.                                                                                                                                                                     
As part of the Agreement between Aristech Chemical Corporation and the PACE Union Article XV - Safety:                                                                                                                                                                 "The Company shall establish a Safety and Health Committee.  The Union shall appoint three Employees as Union representatives and the Company shall appoint three representatives who will participate as permanent members of the Safety and Health Committe 
e.   The Committee will meet once monthly at times mutually agreed to for the purposes of considering and reviewing health and safety conditions and procedures and making constructive recommendations with respect thereto. ... All matters considered by the Committee shall be reduced to writing and copies of the minutes will be furnished to the Committee Members."                                                                                                                                                 
he Safety and Health Committee meets on the first Tuesday of every month.  The Superintendent - Environmental, Safety and Health prepares and distributes the minutes of the meeting.  Process Safety Items along with other general safety items are discussed and resolved as a result of the meeting.                            
Process Safety Information is divided into three categories: 
Information about hazards of chemicals 
Material Safety Data Sheets (MSDS) are used, in accordance with the standard, to supply information pertaining to the hazards associated with the chemicals used in each Process.  Binders containing MSDS for the chemicals used in each of the areas of the plant are maintained and readily accessible in the Maintenance library and the P&D control room.  A master file of all MSDS is maintained in the Plant Training Building.  The Coordinator of Safety and Environmental Services is responsible for maintaining the MSDS binders. The Coordinator of Safety and Environmental Services and/or the Safety Training Specialist is responsible for conducting the Hazard Communication Training.  A copy of the Hazard Communication Program is maintained in the Plant Policy and Procedure Manual and is available for all employees as well as plant contractors to review.      
Information about the techno 
logy of the process    
This information includes Process and Instrument Diagrams (P&IDs), process descriptions, block flow diagrams, relief system designs, and process changes.  The originals of the P&ID are kept in the Drafting Room in the 109 Building.  Copies of the P&ID are kept in the Departments.   Relief system design information is kept in the equipment files in the Maintenance Department.     
Information about equipment in the process        
This information which includes materials of construction, electrical classifications, design codes and equipment data, is found in the equipment files and Job Equipment Books kept in the Maintenance Department.         
The methods used at the Neal Plant for Process Hazard Analysis are the HAZOP technique and the WHAT-IF technique.  The Process Safety Coordinator will determine which technique is appropriate.  A PHA Team meets routinely to evaluate the hazards of existing processes or may evaluate potentia 
l hazards identified by the FOC procedure.  The Process Safety Coordinator will assign an identifier to each PHA and track generated action items to their resolution in a Plant Level Action Item File (PLAIT) database. 
Safe Job Procedures (SJP's) and Operating Procedures are required and include steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions.  Operating procedures that pertain to the ISO 9002 quality system are identified as Work Instructions or WIN.  The Neal Plant's SJP's and Operating Procedures are reviewed annually to keep them current and to certify that practices match procedures.   Monthly training with process safety critical SJP's is a part of the Continuous Training program. 
Standard work practices are required for lockout/tagout, confined space entry, gas testing, vehicle entry and hot work. These Standard Procedures are maintained in the Policy and Procedures Manual. 
All employees in covered processes are trained prior to assignment of their job duties.  This applies to transferred employees and new employees.  All employees in covered processes train continuously on selected procedures and hazards as a part of the Neal Plant Continuous Training program. 
The Neal Plant Training Committee, which is composed of both management and hourly personnel, determines the requirements and frequency for certification and recertification of employees in the covered processes.   Recertification is conducted every three years. 
Training is conducted and certification granted by the selected Senior Foreman/Trainers in the appropriate departments.  Training documentation is kept in the plant master training file maintained by the Safety Training Specialist. 
The Training Coordinator chairs the Training Committee, which meets monthly to discuss training issues.  Two PACE Union members are members of this committee. 
The Maintenance Engineer ha 
s developed written procedures to maintain the ongoing integrity of process equipment.  The covered process equipment includes pressure vessels, pumps, piping systems, relief and vent systems, emergency shutdown systems and process controls. 
All maintenance personnel working on process equipment receive a two-day Process Overview Training Course before working in the plant.  The P&D and F&S Senior Foremen/Trainers and the Safety Training Specialist conduct this course.  
A skills certification program to ensure maintenance employees have the necessary skills to perform assigned jobs was developed by the Maintenance Engineer with the assistance of the Training Coordinator. 
A Pre-Startup Safety Review is conducted for all major changes to the process.  A major change is any modification that will result in a change to the process safety information for the equipment or process in the areas of the plant that are covered by the PSM and RMP standards. 
There is a Facility or Operational Change Procedure (FOC) to ensure for a comprehensive review of changes to the covered process so as to maintain or enhance the safety, environmental, and technical integrity of the Neal Plant.  "Replacements-in-Kind" of equipment or process chemicals, which meet the specifications and normal repairs, are not considered to be changes and are exempt from this policy. 
The Process Safety Management System is audited every three years by a consultant selected by the Corporate Environmental, Health and Safety Department. 
A Potentially Serious Incident (PSI) is defined as an incident which resulted in or could reasonably have resulted in a catastrophic release of a highly hazardous chemical.  All incidents that could have resulted in a serious accident or fatality will also be treated as a PSI. 
The incident investigation team for a PSI will be formed as soo 
n as possible but no later than 48 hours following the incident.  The team will consist of at least two persons who are knowledgeable of the process involved.  If the incident involves the work of a contractor at least one contract employee will be on the team. 
Typically, the PSI team will consist of the following members. 
Superintendent - EH&S 
Department Superintendent for the affected process area 
Employee involved in incident if applicable 
Employee not involved in the incident but knowledgeable of the process  
The Process Safety Committee meets to direct the development and implementation of the Process Safety Management System at the Neal Plant.  The PACE Union selects a representative to serve on this committee.                                                                                                                                   
The following procedures are established for the selection of contractors for all projects or work, directed by local or corpo 
rate management, that will take place in any operating area of the Neal plant or other areas of the Neal plant for work exceeding $25,000.  This does not apply to contractors performing routine "service-type" work, such as landscaping, HVAC, and other non-process area work. 
The Supervisor of Purchasing is responsible for making sure all potential bidders submit signed and completed copies of all necessary documents prior to requesting a bid or quotation.  Necessary documents include, at a minimum, a Pre-Qualification Form, copies of contractors' OSHA logs for the most recent three years, a copy of each contractor's certificate of insurance and workers compensation coverage, a copy of each contractor's drug and alcohol policy, and any other information that may help in determining the acceptability of a potential bidder. 
The Superintendent of EH&S is responsible for reviewing health and safety related information submitted by contractors and determining if the contractor is acceptable 
, prior to bidding on a job.  This determination is made based on the selection criteria established in this procedure. 
The Supervisor of Purchasing, with the assistance of the Superintendent of EH&S, is responsible for establishing a list of "Approved Contractors" for work to be done at the Neal Plant.  This list shall be updated on an annual basis. 
The Supervisor of Purchasing is responsible for making sure that only contractors on the current "Approved Contractors" list are given the opportunity to bid on jobs at the Neal Plant.  All subcontractors that a contractor may use for work at the Neal Plant are subject to this procedure, and must have the appropriate information on file in the Plant Buyer's office and be approved by both Aristech and the Prime contractor prior to bidding. 
The Supervisor of Purchasing is responsible for maintaining a file on each contractor who submits information for approval.  Files will include all information submitted by the contractor, Contractor P 
erformance Evaluation Forms from previous work done by that contractor at the Neal Plant, and copies of any documentation related to quality of work, safety performance, delivery of services, etc. that may exist. 
Contractors must be properly qualified to perform the type of work they may be asked to perform.  Only contractors with past experience and a proven record of satisfactory performance in the particular type of work to be done will be considered for pre-qualification.  Documentation to support claims of satisfactory performance must be included in the file kept for each contractor. 
Only contractors that meet all of the following safety record requirements will be approved for work at the Neal Plant: 
    1.OSHA total recordable incident rate < 12.0 for each of the last three years. 
    2.Total Lost Workday Case rate < 5.5 for each of the last three years. 
    3.Workers' Compensation EMR < 1.5 for each of the last five years. 
Contractors who have had a 
ny fatalities in the last three years will not be considered, unless these fatalities are a result of off-site traffic accidents, or violent crimes that were not under the control of the contractor.  It is the contractor's responsibility to explain all fatalities if they wish to be considered. 
Contractors must have a drug and alcohol policy in place, and/or agree to fully participate and cooperate with the Aristech drug and alcohol policy. 
Contractor Performance Evaluation Forms from past work, along with any documentation related to safety, quality of work, delivery of services, etc., will be reviewed during the pre-qualification process.  Contractors with poor evaluations will not be approved, unless special provisions are made to ensure better performance. 
Contractors will not be approved to bid on any jobs in the plant until all requested documentation is placed in the file for that contractor.  It is the contractor's responsibility to ensure they have submitted all requested in 
Information submitted by contractors for pre-qualification will be evaluated by the Superintendent of EH&S within three (3) days after receipt of the all requested documentation. 
In special circumstances when contractors submitting information for review fail to meet the selection criteria, approval to bid may be granted by the Plant Manager if the safety record shows a trend toward improvement, and special requirements are imposed on that particular contractor, at the Plant Manager's discretion.  Special requirements may include a full time safety coordinator, restrictions on the type of work, requirements for constant observation by Aristech personnel, etc.  It is understood that these special provisions may make that particular contractor's ensuing bid less competitive. 
Once a contractor has been evaluated, a letter stating approval or disqualification will be sent to the Contract Administrator, with a copy placed in the contractor's file.  Any speci 
al requirements imposed on a contractor will be included in this letter. 
Once a letter of approval has been received by the Supervisor of Purchasing, the contractor may be asked to bid on work in the plant for a period of two years, at which time updated information must be submitted.  
Contract Employees who will be performing work in a Neal Plant Operating Area receive the Contractor Safety Orientation.  After completion of the orientation the contract employee is issued a safety information pamphlet and a safety orientation card which is valid for a period of one year.  The training that is a part of the orientation includes: personal protective equipment requirements, smoking policies, emergency and evacuation plans, hazard communication program, hot work permits, confined space entry procedures, vehicle entry procedures, lock-out/tag-out procedures, and hazards associated with specific process areas in the plant. 
Five-year accident history: 
In the past five  
years, there have been no releases of propylene or propane at the Neal Plant that have had an adverse impact on employees, the community, or the environment.   If an incident were to occur, we will conduct a formal incident investigation to identify and correct the root cause of the events. 
The emergency response program: 
The Neal Plant maintains a Emergency Response Manual that has procedures which include responses for the release of propylene or propane, vapor cloud dispersion, fire protection, bomb threats, and plant evacuation.    
There is a fully equipped Emergency Response Team (ERT) with members from all shifts, which provides for 24-hour protection.  The ERT members receive monthly training on site as well as annual training at nationally recognized Fire Schools.  In addition, the training routinely includes drills and simulated plant fire and emergency response scenarios. 
The Neal Plant emergency response program is coordinated with the Cabell/Wayne Local Emergency Plannin 
g Committee.  Also, the Neal Plant works closely with the local emergency responder, Kenova Volunteer Fire Department. 
Over the last year and half, the Neal 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 Neal Plant is also working to obtain assurances from vendors regarding readiness of their systems.  The plant's Y2K activities have been communicated to the Neal Plant employees to enhance their awareness of the issues.  The work on Y2K readiness is expected to be completed by October 1999. 
Planned changes to improve safety: 
The following safety improvements are planned for the Neal Plant: 
1. Insta 
ll automatically actuated isolation valves on the discharge piping from the LPG storage tanks located in Area 10. 
2. The installation of a second power transformer for Area 10 and Area 11 to provide a back-up power source. 
3. Upgrade the electrical classification of the operator enclosure in the Polymerization Unit to a full explosion proof classification.
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