CONDEA Vista Company - Executive Summary |
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3271 LDEQ Facility ID Number CONDEA Vista, Inc. Lake Charles Chemical Complex Risk Management Plan Executive Summary CONDEA Vista's Lake Charles Chemical Complex (LCCC) has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, training of highly qualified personnel, and considering safety in the design, installation, operation and maintenance of our processes. Our policy is to implement reasonable controls to prevent chemical releases. However, if a release does occur, our trained personnel will respond to control, contain, and mitigate the release. CONDEA Vista is committed to Responsible Care(r) voluntary initiative for safe management of chemicals. CONDEA Vista follows the Responsible Care(r) Code of Management Practice, which is integral to the implementation of the CONDEA Vista Environmental and Health and Safety policies. The Responsible Care(r) Community Awareness Code of Management Pract ice and CONDEA Vista's Community Awareness and Emergency Response policies are designed to assist emergency preparedness and to faster community right to know. CONDEA Vista's Lake Charles Chemical Complex (LCCC) located in Westlake, Louisiana uses natural gas by-products from refinery operations and chlorine as the primary raw materials to produce specialty chemicals for detergents, cosmetics, and plastics. The chemical complex uses or produces several regulated flammables such as ethylene, vinyl chloride monomer, propane, butane, propylene, ethane, butene, hydrogen, methane, and pentane. In addition, the Chemical Complex uses ethylene oxide, hydrochloric acid, and hydrofluoric acid, which are also regulated substances. Other regulated chemicals used in our process, which are stored below the threshold quantity, are chlorine, sulfur dioxide and ammonia. The worse case scenario (WCS) associated with a toxic substance handled at the Lake Charles Chemical Complex (LCCC) involves cata strophic failure of the hydrogen chloride storage vessel with the resulting release of 721,000 pounds of anhydrous hydrogen chloride. Although we have numerous controls to prevent such a release and to manage the consequences, no credit for administrative controls or passive mitigation measures was taken into account when evaluating this scenario. Look up tables published by USEPA were used to determine the maximum distance to the toxic endpoint. Based on these Look-up tables, maximum distance to the scenario endpoint of 20-ppm (milligrams per liter) for the worse case scenario is 25 miles. The alternative case scenario (ARS) for hydrogen chloride is the release of hydrogen chloride vapor over a 15-minute period from a one-inch hole in a process line that contains hydrogen chloride. The 15-minute release duration is the maximum time necessary to block off and transfer to storage the hydrogen chloride contained in the process line thus stopping the release. No other mitigation meas ures other than to empty the process line were taken into account when evaluating this scenario. A dense phase dispersion model "PHAST" developed by Det Norse Veritas (DNV) was used to determine the maximum distance to the toxic endpoint of 20-ppm (0.28 milligrams per liter) to be 1.02 miles. Other chemicals listed in the EPA's list of toxic chemicals which are maintained on site at the LCCC above EPA's threshold quantity are ethylene oxide and hydrogen fluoride The alternative case scenarios (ARS) for ethylene oxide is the failure of a 3/4 inch nozzle on a process line. This ARS results in the release of 12,000 pounds of ethylene oxide over a 20 minute period. The 20-minute time period represents the maximum time required for unit personnel to block in, isolate, and empty the process, thus stopping the release. The maximum distance the toxic endpoint of 50 ppm as determined by PHAST (a dense phase dispersion computer simulation program) is 0.53 miles. The alternative case scen arios for hydrogen fluoride is the failure of a 3/4 inch connection on a process line. This ARS results in the release of 675 pounds of hydrogen fluoride over a 10 minute period. The 10 minute time period represents the time required to block in and the isolate the process line to empty, thus stopping the release. The results given by PHAST for the maximum distance to the toxic endpoint of 20 ppm (parts per million) at 0.64 miles. No credit was taken for the installed water curtain. If credit had been taken for this safety equipment, the distance to the toxic endpoint would be less than 700 feet or such that no one outside the plant boundary would be exposed to hydrogen fluoride. The WCS (worse case scenario) associated with the release of a flammable substance involves the release of largest inventory, in a single vessel, (as allowed by administrative controls) of vinyl chloride monomer (VCM). No credit was taken for active mitigation measures when evaluating this scenario. Th erefore, the maximum allowable single vessel inventory allowed to release under established administrative controls is 6,400,000 pounds. This inventory is assumed to vaporize and ignite, resulting in a vapor cloud explosion (VCE) which would result in a maximum distance to the 1-psi overpressure endpoint of 1.1 miles. The ARS for flammable substances at the LCCC over a 60-minute time period (the time required to empty the tank) is the release of 160,000 pounds of pentane from a 2-inch diameter hole in a pentane storage vessel. This release is assumed to result in a VCE. The distance to the 1-psi overpressure endpoint for this ARS scenario is 0.13 miles. Process Safety Information The LCCC (Lake Charles Chemical Complex) maintains 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, specific chemical inventories, and equipment design b asis/configuration information. Specific departments within the chemical complex are assigned responsibility for maintaining up-to-date process safety information. Employees are provided training on how to locate the information from various computer terminals located throughout the chemical complex. Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS). This information is supplemented by documents that address known corrosion concerns and known hazards associated within inadvertent mixing of specific chemicals. For the different process areas, the chemical complex has documented safety related limits for specific process parameters (e.g. temperature, pressure, composition, etc.). The chemical complex ensures that the processes are maintained within these limits using process controls, monitoring instruments, protective instrument systems, and highly trained personnel. Th e chemical complex also maintains an electronic database, that is accessible by both employees and contractor supervision, which provides information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical classification, 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 comprised. Process Hazard Analysis The Lake Charles Chemical Complex (LCCC) has a comprehensive program to help ensure the 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 LCCC primarily uses the hazard and op erability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analysis are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The 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. The PHA team findings are made available to people associated with the process unit for comments and forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest rank receive immediate attention. All approved mitigation options being implemented in resp onse to PHA findings are tracked until they are complete. The final resolution of each finding is documented and retained. Operating Procedures Operators, supervisors, and plant engineers work together to develop and maintain operating procedures. These procedures define how tasks related to process operations are safely performed. At the Lake Charles Chemical Complex (LCCC), operating procedures: (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: * Steps for safely conducting activities * Applicable process safety information, such as safe operating limits, * Safety and health considerations, such as chemical hazards, personnel protective equipment required and steps to take if exposed to a particular chemical. Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operation, nor mal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. Training The Lake Charles Chemical Complex (LCCC) trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training. All new operators receive six weeks of comprehensive training before ever being assigned to a specific operating unit. This training includes training on specific types of equipment, such as pumps and compressors, general overview of the process, properties and hazard substances in the process, detailed review of complex procedures, such as, safe work practices and emergency response. Oral reviews and written tests are used to verify that employees understand the training material before a new employee can report to a process unit. Once a new employee reports to a particular process unit, he receives detailed training with respect to process specific procedures. Once the new hire has demonstrated, through oral review and written tests, mastery of process specific operating procedures and for specific tasks, he is allowed to begin work in a specific operating unit. Refresher training covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process and, (3) a detailed review of the process operating procedures and safe work practices. Oral review and written tests are used to verify that employees understand the training before an employee can resume work in the process. The operators have been consulted in safety meetings and through questionnaires regarding effectiveness and frequency of training. Recommendations are reviewed and changes to the training program are implemented as appropriate. Management of Change The Management of Change program for the LCCC evaluates and approves all proposed changes to chemicals, equipment, and procedures for covered processes to help ensure that a change does not negati vely affect safe operations. Process changes that are determined to be a replacement in kind (e.g. replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through a full management of change program to help ensure process safety information and procedures are updated, and affected employees are notified of the change. Pre-Startup Safety Review (PSSRs) The Lake Charles Chemical Complex (LCCC) conducts a safety review of a new or modified process before the process is placed in service. The purpose of the PSSR is to ensure the safety features, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment in service. The review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of re adiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The Lake Charles Chemical Complex (LCCC) has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, emergency shutdown systems, and rotating equipment (pumps and compressors) 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 response pl ans, and (5) applicable safe work practices. Written procedures help ensure that work is performed in consistent manner and provides 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 for pressure vessels). If a deficiency is identified, the equipment will be repaired in a timely manner. All outstanding deficiencies are tracked until such time a final solution has been implemented and documented. Another integral part of the mechanical integrity program is quality assurance. The LCCC incorporates quality assurance into equipment purchase and repairs. This helps ensure that new equipment is suitable for intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The Lake Charles Chemical Complex (LCCC) has a long-standing safe work program in place to ensure worker safety. Examples of the p rogram include (1) control of the entry/presence/exit of support personnel, (2) lockout/tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedures to conduct spark producing activities (i.e, hot work), and (5) a permit and procedures to ensure that adequate precautions are in place before entry into a confined space. These procedures, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Incident Investigation The Lake Charles Chemical Complex (LCCC) investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so similar incidents can be prevented. The LCCC trains employees to identify and report any incident requiring investigation. The investigation is initiated within 4 8 hours of the incident. Depending on the incident, an investigation team may be formed. Results of the investigation are documented and appropriate changes are made. Employee Participation The Lake Charles Chemical Complex (LCCC) maintains a written employee participation program to help ensure that safety and environmental concerns of the plant workers are addressed. The plant encourages active participation of personnel in safety, health, and environmental activities at the plant. Employees are consulted and/or informed about all aspects of the RMP prevention program including PHA's (Process Hazard Analysis) and operating procedures. Compliance Audits The Lake Charles Chemical Complex (LCCC) audits the covered processes to be certain that the prevention program is effectively addressing safety, health, and environmental issues. The complex assembles an audit team that includes personnel knowledgeable in the processes. This team evaluates whether the prevention program satisf ies the requirements of the RMP rule and whether the prevention program is sufficient to ensure safe operation of the complex. The results of the audit are documented, recommendations are resolved, and appropriate enhancements made to the operations of the LCCC. Contractors Lake Charles Chemical Complex (LCCC) has established a program to help ensure that contractor activities are performed in a safe manner. This program reviews the safety record of the contractors to ensure the plant only hires contractors who can safely perform the desired task. The complex communicates to the contractor supervisor the hazards of the process on which they and their employees will work, the plants safe work practices, and the plants emergency response procedures. The plant requires that the contractor supervisors train each of their employees on hazards and procedures specific to the complex site. The plant periodically reviews contractors training documents and work performances to help ensur e that safe practices are followed. Five Year Accident History The facility has experienced three events in the period of June 1994 to present, which had offsite impacts. In addition, there was one event that did not result in any offsite consequences but did result in three minor onsite injuries. The four events are as follows: * January 24,1995-Accidental release of hydrogen chloride, vinyl chloride monomer, and ethylene dichloride. No injuries, exposure to toxic chemicals or property damage either offsite or within a the boundaries of the complex occurred as a result of the release. As a precaution,. approximately 1000 people were sheltered in place. * March 10, 1995 - Accidental release of hydrogen chloride, vinyl chloride monomer, and ethylene dichloride. One person on-site was treated and released and on-site damage was minimal. No injuries, exposure to toxic chemicals, property damage or environmental damage occurred off-site as a result of this release. As a precaution, approximately 5000 people were sheltered in place as a result of this release. * August 10,1996 - Accidental release of hydrogen chloride and chlorine. Three employees were treated for exposure to hydrogen chloride and chlorine before returning to work. No exposure to toxic chemicals, injuries, property damage or environmental damage occurred off-site as a result of the release. Because the release was easily contained, no one was sheltered in place. * June 5, 1997 - Accidental release of hydrogen chloride. No injuries, exposure to toxic chemical, or property damage either off-site or within the boundaries of the complex occurred as a result of this release. As a precaution, 1000 people were sheltered in place. Emergency Response Program The Lake Charles Chemical Complex (LCCC) emergency response program has been developed to meet the emergency planning, response, and notification requirements of the following regulations: * OSHA 29 CFR 1910.38 (a) - Employee Emergency Action Plans * OSHA 29 CFR 1910.120 (q)-Hazardous Waste Operations and Emergency Response (HAZWOPER) * OSHA 29 CFR 1910.110 (n) Process Safety Management of Highly Hazardous Chemicals * OSHA 29 CFR 1910 Subpart L-Fire Protection * LADEQ LAC 33.1' 3901- Notification Regulations for Unauthorized Discharge * LDPS Title 33, Part V, Subpart 2, Ch.101' 1011-Release Reporting * EPA 40 CFR Part 302.6- Notification Requirements * EPA 40 CFR part 355.40-Emergency Planning and Release Notification * EPA 40 CFR Part 68- Risk Management Programs for Chemical Accidental Release Program * EPA 40 CFR Part 355.30- Facility Coordinator and Emergency Response Plan * EPA 40 CFR Part 112- Spill prevention, Control and Countermeasures Plan * EPCRA 302- List of Extremely Hazardous Substances The emergency response strategy for the Lake Charles Chemical Complex (LCCC) is to prevent and/or control emergency situations via the use of engineering , design, and fixed protection systems. The plant has an Emergency Resp onse Team that is available 24 hours per day, and trained to respond and take actions to contain, control, and mitigate any release that might occur. The team has access to on-site emergency equipment which is appropriate for situations that could possibly occur at the LCCC. In addition to the considerable on-site resources, the LCCC is a member of Calcasieu Mutual Aid. This membership allows the LCCC (if needed) to draw on the emergency response resources of other industries in the immediate area. The following is a partial listing of the equipment which is available for emergency response: Firepumps w/ fixed firewater system Fire Monitors Fire Extinguishers Dry Chemical Truck Foam Pumper Water Deluge Systems Fixed Extinguishing Systems Spill Response Unit Emergency Response Team Drills are conducted to assess the emergency response effort at the LCCC. The CONDEA Vista Company Lake Charles Facility is a participant in the community planning process cooperating with the Calcasi eu Parish Local Emergency Planning Committee. A copy of the plant's Emergency Response Plan has been forwarded to the Office of Emergency Preparedness per the requirements of 40 CFR 355. Planned Changes to Improve Safety The Lake Charles Chemical Complex (LCCC) constantly strives to improve safety and reduce risk through auditing, suggestions from employees, incident investigations, and the use of proper engineering standards and specifications. 1 1 |