Equistar Chemicals, L.P. - Corpus Christi Complex - Executive Summary |
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Risk Management Plan Executive Summary Equistar Chemicals, LP Corpus Christi Complex 1. Accidental Release Prevention and Emergency Response Policies Equistar is committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at Equistar. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. The Corpus Christi Complex maintains a full time, dedicated emergency response team. If a release occurs, Refinery Terminal Fire Company (RTFC) and Equistar personnel are at hand to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled The Equistar Corpus Christi Complex uses liquefied petroleum gas and raw materials to produce ethylene plus principal co-products of propylene, benzene and butadiene. The Corpus Christi Complex is situated on a 1,600 acre site located 12 miles west of downtown Corpus Christi. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario Methodology given in the RMP Offsite Consequence Analysis Guidance by the EPA using tables and equations has been employed by Equistar to perform worst and alternative case release scenarios. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from mixed C4 gas storage in the 1,3-butadiene manufacturing process. The scenario involves the release of 1,517,959 pounds of mixed C4 gasses. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity part icipating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of approximately 0.92 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 3 flammable substances involves a release from mixed C4 gas storage in the 1,3-butadiene manufacturing process. The release is assumed to result from a failed pressure relief valve on a storage sphere. The scenario involves the release of approximately 17,000 pounds of mixed C4 gasses in 5 minutes. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under neutral weather conditions, the maximum distance of approximately 0.14 miles is obtained corresponding to an endpoint of 1 psi overpressure. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Equistar has taken the n ecessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68. This facility was designed and constructed in accordance with NFPA-58 Standard. A number of processes at Equistar are subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program in place at Equistar. Process Safety Information Equistar maintains a record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Equistar conducts studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is referred to as a unit PHA. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated on an as needed basis. Any findings related to t he hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting operations activities, Equistar maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved with the processes. Training Equistar has a training program in place to ensure that employees that are operating processes are competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity Equistar carries out documented maintenance checks on pr ocess equipment to ensure proper functions. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance is carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Equistar to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a process modification are trained in proper operation and maintenance of the modified process prior to the modified equipment being placed in service. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Equistar. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Equistar conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. As an OSHA VPP worksite, Equistar conducts annual audits. Any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Equistar investigates any incident that has resulted in, or could reasonably result in, an employee injury or a catastrophic release of a hazardous material. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. Investigation reports are retained for a minimum of 5 years. Employee Participation Equista r believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation to the RMP rule in particular information resulting from process hazard analyses. Equistar is a member of the OSHA Voluntary Protection Program. As VPP Star Work Site, this facility has gone above and beyond the normal safety requirements to provide employees with a safe working environment. Contractors Equistar utilizes contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Equistar has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are al so informed of the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History The Corpus Christi Complex has an excellent operating history. During the preceding five years, there have been no fires, explosions or releases, which have significantly impacted the plant's employees, surrounding public or the environment. 6. Emergency Response Plan Equistar's written emergency response plan deals with accidental releases of hazardous materials. The plan includes many aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. Emergency response planning is coordinated with the Nueces County LEPC, the Refinery Terminal Fire Company, local law enforcement, the Corpus Christi Fire Department and area hospitals. In addition, the plan is updated to reflect any per tinent changes taking place within our processes that would require a modified emergency response. The Corpus Christi Complex has implemented an emergency equipment inspection, testing and maintenance program which ensures that emergency response equipment will operate properly when needed. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Equistar is presently working jointly with the Nueces County LEPC to increase public awareness and communication in the event of a chemical release. This includes a public education effort undertaken along with other Corpus Christi industries as well as improved radio communications to promote rapid dissemination of information. |