Geismar Ethylene Plant - Executive Summary |
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17854 LDEQ Facility ID Number Executive Summary Union Texas Petrochemicals Geismar Ethylene Plant Geismar, Louisiana Accidental Release Prevention and Response Policies The Union Texas Petrochemicals, Geismar Ethylene Plant has a long-standing commitment to protect employees, the community and the environment. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety and environmental consequences in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of hazardous materials. However, if a release does occur, our trained emergency response personnel will respond to control, contain and mitigate the release. Description of the Stationary Source and Regulated Substances The Geismar Ethylene Plant, located in Geismar, Louisiana, operates a cracking and fractionation process to produce ethylene, propylene, crude butadiene and debutanized aromatic concentrate from ethane and propane feedstocks. The Geismar Ethylene Plant is subject to the requirements of 40 CFR Part 68 - Chemical Accident Prevention Provisions. The Geismar Ethylene Plant has regulated flammable substances including, propane, 1,3-butadiene, propylene, ethylene and ethane. Additionally, the plant uses chlorine, which is also a regulated toxic substance. The coordinates of the Geismar Ethylene Plant is, 30o, 14', 09" N Latitude and 91 o, 03', 02" Longitude measured at the center of the facility. Hazard Assessment Results Toxic Materials. The worst-case scenario associated with a toxic material involves the release of 2,000 pounds of chlorine over a 10-minute period. Under worst-case conditions, chlorine could travel up to 4.5 miles as estimated by EPA's OCA Guidance (Table 7), with an endpoint concentration of 3.0-ppm (ERPG-2). No administrative controls or passive mitigation measures were considered in evaluating this s cenario. The alternative release scenario for a toxic material at the Geismar Ethylene Plant involves the release of 216 pounds of chlorine over a 30 minute period due to the mechanical shear of a <" chlorine cylinder vapor valve. Under alternative release conditions, chlorine could travel up to 0.4 miles as estimated by SaferTrace, with an endpoint concentration of 3.0-ppm (ERPG-2). Flammable Materials. The worst-case scenario associated with the release of a flammable material at the plant involves the release of 1,524,500 pounds of 1,3-butadiene over a 10-minute period. Under worst-case conditions, the resulting vapor cloud explosion could cause an overpressure of 1 pound per square inch (psi) at a distance up to 0.92 miles as estimated by EPA TNT Equivalency Model, Eq. C-1. No administrative controls or passive mitigation measures were taken into account in evaluating this scenario. The alternate release scenario for a flammable material at the plant involves the release of 13,800 pounds of crude butadiene over a 10-minute period due to the mechanical shear of a 2" line downstream of the emergency shutdown (ESD) valve at the storage sphere. Under alternative release conditions, the resulting vapor cloud explosion could cause an overpressure of 1 pound per square inch (psi) at a distance up to 0.05 miles as estimated by the Baker-Strehlow model. Five-Year Accident History The Geismar Ethylene Plant has had an excellent record of accident prevention over the past 5 years. Every incident is investigated very carefully to determine ways to prevent the incident or similar incidents from recurring. Table 1 below is a summary of the RMP-reportable incidents that have occurred during the last 5 years. Table 1. Five-year Release History of the Geismar Ethylene Plant. Regulated Substance: PROPANE Date, Time and Duration of Release: 08/01/95; 9:15 P.M.; 45 MINUTES Quantity Released: 16,416 LBS. PROPANE CONSUMED BY FIRE Type of Release Event and Sou rce: FIRE - FOUR (3/4") BLEED VALVES Weather Conditions: 1.8 MPH NNW, 81 F Onsite Impacts: ONE INJURY; $750,000 PROPERTY DAMAGE Offsite Impacts: NONE Initiating Event: HUMAN ERROR - OPEN BLEED VALVE Offsite Responders Notified? YES - LOCAL COMPLEX BRIGADE MEMBERSNOTIFIED AND ASSISTED IN COOLING ACTIVITIES Operational Process Changes: MODIFIED OPERATING PROCEDURES AND CONDUCTED ADDTIONAL TRAINING General Accidental Release/Chemical-Specific Prevention Programs Steps The following is a summary of the accident prevention program in place at the Geismar Ethylene Plant. Because the process at the Geismar Ethylene Plant is regulated by the EPA Risk Management Program (RMP) regulation and is also subject to the OSHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation The Geismar Ethylene Plant provides for, encourages an d requires employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information, Management of Change (MOC) Review, to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the Geismar Ethylene Plant accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation procedure that is maintained at the Geismar Ethylene Plant and addresses each accident prevention program element. In addition, the Geismar Ethylene Plant has a number of initiatives under way that address process safety and employee safety issues. These initiatives including forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, mainte nance, engineering, safety and plant management. Process Safety Information The Geismar Ethylene Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the Geismar Ethylene Plant are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the written employee participation plan to help employees locate any necessary process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets. For specific process areas, the plant has documented safety-related limits for specific process p arameters (e.g., temperature, level; composition) in the operating procedures. The Geismar Ethylene Plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The Geismar Ethylene Plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, 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 compromised. Process Hazard Analysis (PHA) The Geismar Ethylene Plant has a comprehensive program to help ensure that 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 Geismar Ethylene 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. The analyses are conducted using a team of people who have operating, maintenance, health, safety and environmental experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary or the probability and severity of an incident produce an unacceptable risk. The PHA team findings are forwarded to management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential incident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Geismar Ethylene Plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. Operating Procedures The Geismar Ethylene Plant maintains written operating procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators, and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained current and accurate by revising them on a continual basis to reflect changes made through the management of change process. In addition, the Geismar Ethylene Plant maintains a Key Process Parameter Document that provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, the Geismar Ethylene Plant has implemented a com prehensive training program for all employees involved in plant operations. All new employees receive basic training in plant operations. After successfully completing this training, a new operator is paired with an area-qualified operator to learn process-specific duties and tasks. After operators demonstrate (e.g., tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner, they are qualified for that area and are allowed to work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The Geismar Ethylene Plant uses contractors for normal maintenance as well as to supplement its workforce during pe riods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the Geismar Ethylene Plant periodically monitors contractor performance to ensure that contractors are fulfilling their safety program and performance obligations. Pre-startup Safety Reviews The Geismar Ethylene Plant conducts a Pre-Startup Safety Re view (PSSR) for any new facility or facility modification that requires a change in the process safety information that exceeds $50,000 or otherwise deemed necessary by local management. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. In addition to Management of Change, the PSSR provides an additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. Mechanical Integrity The Geismar Ethylene Plant has well-established mechanical integrity practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying 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 control plans, and (5) safe work practices to 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, vibration limits, etc.). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a group of experts will review the use of the equipment and determine what actions are necessary to ensure the continued safe operation of the equipment. Another int egral part of the mechanical integrity program is quality assurance. The Geismar Ethylene Plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The Geismar Ethylene Plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) control of the entry/presence/exit of support personnel, (2) lockout/tagout procedures to ensure isolation of energy sources for equipment that is being worked on, (3) permit and procedures for safe removal of hazardous materials before process piping or equipment is opened, (4) permit and procedures to control spark-producing activities (i.e., hot work), and (5) permit and procedures to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with annual training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Geismar Ethylene Plant has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes to be properly reviewed and authorized before being implemented. Changes are reviewed to: (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The Geismar Ethylene Plant promptly inve stigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, significant environmental event, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are completed. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To ensure that the accident prevention program is functioning properly, the Geismar Ethylene Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Geismar Ethylene Plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are completed. The final resolution of each finding is documented, and the two most recent audit reports are retained. Summary of Process Hazards, Safety Features, and Hazard Analysis Findings Universal Prevention Activities The accident prevention program summarized previously is applied to all EPA RMP-covered processes of the Geismar Ethylene Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. Specialized Safety Features The Geismar Ethylene Plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered process: Release Detection Hydrocarbon detectors with alarms, Perimeter monitors Release Control Vents, Process relief valves that discharge to a flare to capture and incinerate episodic releases, Check valves, Flares, Manual shutoffs, Automated shutdown systems for specific process parameters (e.g., high level, high temperature), Interlocks, Alarms and procedures, Keyed bypass, Emergency instrument air supply, Emergency power, Backup pump, Grounding equipment, Inhibitor addition, Rupture disks, Excess flow device, Purge system Release Containment Vessel to permit partial removal of the process inventory, curbing a nd diking to contain liquid releases, redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump), and atmospheric relief devices. Release Mitigation Dikes in process areas and surrounding storage vessels, Fire water system administered through fire monitors throughout the plant, Valves to permit isolation of the process (manual or automated), Fire suppression and extinguishing systems, Deluge system for specific equipment, Trained emergency response personnel, Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus) Emergency Response Program Information The Geismar Ethylene Plant maintains a written emergency control program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance i s accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the Geismar Ethylene Plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency control program is updated when necessary based on modifications made to Geismar Ethylene Plant processes or other Geismar Ethylene Plant facilities. The overall emergency control program for the Geismar Ethylene Plant is coordinated with the Ascension and Iberville Parishes Local Emergency Pl anning Committees (LEPC). This coordination includes periodic meetings of the committees, which include local emergency state officials, local government officials, and industry representatives. The Geismar Ethylene Plant has around-the-clock communications capability with appropriate officials and emergency response organizations (e.g., sheriff's office, Geismar Area Mutual Aid, complex emergency brigade, etc.). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Geismar Ethylene Plant conducts periodic emergency drills. Planned Changes to Improve Safety The Geismar Ethylene Plant is committed to operating our facility in a safe and responsible manner. We are continually evaluating our equipment and procedures to meet this objective. The Geismar Ethylene Plant resolves all findings from Process Hazard Analyses, some of which result in modifications to the p rocess. As of May 1997, all of the PHA findings have been implemented. The following types of changes are being implemented in response to PHA findings: 1. Installation of process controls, process detection systems and perimeter monitoring systems. 2. Enhancement of mitigation systems such as upgrades to the fire water system. 3. Revisions to personnel training programs, written operating procedures, and Health, Environmental and Safety Procedures A comprehensive Process Safety Management Audit was conducted in April 1998. All recommendations from this audit have been completed. Further, Hazard and Operability Studies (HAZOPS) are presently being revalidated. |