Solvay Polymers, Inc. - Executive Summary |
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1.0 Introduction Solvay Polymers, Inc. is committed to operating in a manner that is safe for our employees, the public, and the environment. As part of this commitment, Solvay Polymers, Inc. has established a system to help ensure safe operation of the processes at this facility. One component of this system is a risk management program (RMP) that helps manage the risks at Solvay Polymers, Inc. and that complies with the requirements of the Environmental Protection Agency's Regulation 40CFR68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at Solvay Polymers, Inc. This plan is intended to satisfy the RMPlan requirement of the RMP Rule (40CFR68.150 though 40CFR68.185) and to provide the public with a description of the risk management plan at Solvay Polymers, Inc. 2.0 Accidental Release Prevention and Emergency R epsonse Policies Solvay Polymers, Inc. is committed to the safety of our employees and the public, and to the preservation of the environment through the prevention of accidental releases of hazardous substances. Solvay Polymers, Inc. implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, Solvay Polymers, Inc. emergency response actions are in place to help prevent or minimize injury to the public or the environment. 3.0 Facility Process and Regulated Substances Solvay Polymers, Inc. manufactures polyethylene and polypropylene resins for a wide variety of industrial and consumer applications such as milk bottles, carpet backing, and children's toys. The polyethylene manufacturing process uses ethylene as the basic building block for producing polyethylene. Isobutane is used as a carrier solvent for the polyethylene process. Likewise, propylene is used as the basic building block for the polypropylene pr ocess. Titatnium tetrachloride is used as a catalyst for the polypropylene reaction. Propane is inherent to both the polyethylene and polypropylene processes. 4.0 Offsite Consequence Analysis An offsite consequence analysis was conducted on the Solvay Polymers, Inc. facility. The subject analysis consisted of Worst Case Scenario and Alternative Release Scenario analyses. Two Worst Case Scenarios were completed for flammable RMP compounds since each Worst Case Scenario shows RMP impacts to different offsite receptors. The first is a release of 330,000 pounds of isobutane from an isobutane storage tank, resulting in a vapor cloud explosion. The second is a release of 8,400 pounds of ethylene from the ethylene header, resulting in a vapor cloud explosion. Based on the RMP analysis, the pressure effects formed by the Worst Case Scenarios for these flammable compounds would reach offsite industrial endpoints but would not reach residential populations at the RMP endpoin t. One Worst Case Scenario was completed for toxic RMP compounds. This scenario is an instantaneous release of 3,000 pounds of titanium tetrachloride liquid from a storage vessel, resulting in a toxic gas cloud. Based on the RMP analysis, the resulting toxic cloud would reach offsite industrial endpoints but would not reach residential populations at the RMP endpoint concentration. Worst case weather conditions are considered (stable, low wind speed) for all Worst Case Scenarios. In addition, the Worst Case Scenarios did not consider any existing safety systems or mitigation actiivities. No environmental receptors are within the RPM Worst Case Scenario impact areas. Two Alternative Release Scenarios were completed for flammable RMP compounds since each Alternative Release Scenario shows RMP impacts to different offsite receptors. The first is a BLEVE of a polyethylene reactor containing 58,000 pounds of isobutane. The second flammable ARS is a release of 25,000 pounds of isobu tane from an isobutane railcar, resulting in a vapor cloud explosion. Based on the RMP analysis, the pressure / thermal effects formed by the Alternative Release Scenarios for these flammable compounds would reach offsite industrial endpoints but would not reach residential populations at the RMP endpoint. One Alternative Release Scenario was completed for toxic RMP compounds. This scenario is a release of 3,000 pounds of titanium tetrachloride liquid from a punctured storage vessel, resulting in a toxic gas cloud. Based on the RMP analysis, the resulting toxic cloud would reach offsite industrial endpoints but would not reach residential populations at the RMP endpoint concentration. Most common weather conditions are considered for all Alternative Release Scenarios. In addition, the Alternative Release Scenarios did not consider any existing safety systems or mitigation actiivities. No environmental receptors are within the RPM Altenative Release Scenario impact areas. 5. 0 Accident Release Prevention Program and Chemical-Specific Prevention steps The polyethylene and polypropylene processes are currently covered by the PSM standard. As such, a Program Level 3 prevention program is in place. The following paragraphs describe the prevention program elements at Solvay Polymers, Inc. 5.1 Safety Information - Solvay Polymers, Inc. maintains a variety of technical documents that are used to help ensure safe operations of the polyethylene and polypropylene processes. Material Safety Data Sheets (MSDS) document the physical properties of all hazardous substances handled at Solvay Polymers, Inc. The engineering design documents include the operating parameters, the design basis and configuration of the equipment of the covered process, and references to applicable codes and standards. 5.2 Hazard Review - Solvay Polymers, Inc. performs and periodically updates hazard reviews of the our processes to help identify and control process hazards. Checkl ists include items to help ensure that Solvay Polymers, Inc. operates and maintains the equipment in a manner consistent with the applicable design specifications, codes, standards, and regulations. 5.3 Operating Procedures - Solvay Polymers, Inc. is an ISO9000 certified company. As such we are required to develop and maintain operating procedures to define how tasks related to process operation should be performed. The operating procedures are used to (1) train employees and contractors and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. 5.4 Training - Solvay Polymers, Inc. trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks. A training documentation file is maintained to help ensure that refresher training is provided, as necessary. 5.5 Maintenance - Solvay Polymers, Inc. properly maintains the process equipment. The maintenance program includes (1) procedures to safely guide workers in their maintenance tasks, (2) worker training in the maintenance procedures, and (3) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails. 5.6 Management of Change - Solvay Polymers, Inc. has a program in place to document changes to the process. A significant change in process chemicals, technology, equipment, practices or procedures prompt implementation of this program. The program is designed to (1) evaluate the impact of the change on the process, (2) update records on the process and (3) ensure that workers are informed and trained on any significant changes. 5.7 Pre-startup Review - Solvay Polymers, Inc. performs audits on a new process or an existing process that has undergone a modification affecting the safety information. This review is done prior to operating. The review (1) confirms proper equipment was used, (2) safety, operating, maintenance, and emergency proce dures are updated, (3) a hazard evaluation has been conducted, and (4) training has been updated. 5.8 Compliance Audits - Solvay Polymers, Inc. performs periodic compliance audits of the covered process to verify that the process is operating in compliance with the Process Safety Management standard. Compliance audit reports are prepared after each audit, with documented deficiencies and corrections. 5.9 Incident Investigations - Solvay Polymers, Inc. investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment. Solvay Polymers, Inc. procedures require an investigation team to be assembled, and the investigation to be initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. 5.10 Employee Participation - Solvay Polymers, Inc. requires participation by the affected employees in development (1) of the process hazard evaluation, (2) process safety management, and (3) operating procedures of all covered processes. The employees that work with or maintain the processes are given access to all information required under the rule. 5.11 Hot Work Permits - Solvay Polymers, Inc. has written safety practices in place for fire protection and process operation. A permitting system is used to prevent any unsafe acts on or around the covered process. 5.12 Contractors - Solvay Polymers, Inc. reviews all contractors prior to working on or near a covered process. The contractor must submit information that indicates the work can be performed competently and safely. The company will provide information on the hazards of the process and the safety practices in place. Documents are kept to confirm that the information was received and understood. In addition, Solvay Polymers, Inc. has procedures in place which require the entrance, presence, and exit of contractors to be controlled. 5.13 Chemical-specific Prevention Steps - In addition to engineering review and hazard analyses previously mentioned, workers who perform operations involving RMP listed compounds receive training emphasizing safe handling procedures developed by Solvay Polymers, Inc. In addition, several equipment safeguards are in place. Examples of such safeguards include: hydrocarbon detection and water deluge systems, related piping and vessel periodic inspection and maintenance, and continuous process monitoring for operations involving RMP listed compounds. 6.0 Five-Year Accident History Solvay Polymers, Inc. maintains a 5-year accident history that fulfills the requirements of the RMP rule ('68.42). This history indicates a good record of accidental release prevention. No releases of regulated substances have occurred from Solvay Polymers, Inc. during the subject five year period that have resulted in consequences of interest (i.e., deaths, injuries, or significant property damage on site; or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site). 7.0 Emergency Response Program Solvay Polymers, Inc. has established a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations. This plan has been communicated to local emergency response officials through the local fire department. Regular dialogue is maintained between the facility and the local response personnel, and the company provides appropriate information to the fire chief. Solvay Polymers, Inc. periodically conducts emergency response drills, including annual drills coordinated with the local response authorities. 8.0 Planned Changes to Improve Safety Planned changes to improve safety are described in Solvay Polymers, Inc. Process Hazard Analyses, plant alterations, projects, and the Site Safety, Health & Security Plan. |