Lyondell South Charleston Plant - Executive Summary |
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LYONDELL CHEMICAL COMPANY SOUTH CHARLESTON PLANT RISK MANAGEMENT PLAN EXECUTIVE SUMMARY Introduction: HISTORY Lyondell Chemical Company, one of the world's largest chemical companies, is comprised of wholly owned businesses operating under the Lyondell name and major ownership positions in Equistar Chemicals, LP, Lyondell-Citgo Refining LP and Lyondell Methanol Company, LP. In 1998, Lyondell acquired the assets of ARCO Chemical Company (ACC), including the facilities in South Charleston and Institute, West Virginia. These facilities are located within the existing Union Carbide Corporation's South Charleston plant, and within the Rhone-Poulenc plant in Institute. Also included in this acquisition were urethanes research and development facilities located within the Union Carbide South Charleston Technical Center. Worldwide, the Lyondell enterprise operates in 15 countries, has approximately 11,000 employees, and consists of businesses with more than $17 billion in assets. In West Virginia, Lyondell directly employs about 135 people and provides employment for about 135 people under contract from Union Carbide and Rhone-Poulenc. PRODUCTS The Lyondell enterprise produces quality chemicals, polymers, and refined petroleum products that form the basis for plastics and synthetics of all kinds. Products made from these materials fill the supermarket shelves and go into automobiles, housing, clothing and other necessities that improve the quality of life by making products safer, healthier and more convenient. The products made at our West Virginia facilities belong to a family of chemicals called polyether polyols, and are derived from a chemical called propylene oxide, which is supplied by other Lyondell plants on the Gulf Coast. Polyols are used primarily in polyurethane foams for products ranging from bedding and furniture, to automotive applications such as seat cushions and energy absorbing instrument panels and side panels. Nearly two-thirds of all t he auto seats in the U.S. today are made using the Lyondell polyols products from the Kanawha Valley. Other polyols products we make here are used by our customers for applications as diverse as roof coatings, varnishes, roller blade wheels, and bowling balls. All of the products are shipped to customers in other states or are exported to Europe, Asia, and South America. Another product from our West Virginia facilities is technology. The scientists and technicians at our South Charleston Technical Center work closely together with our manufacturing organization here to develop new or improved polyols products and process technologies. These new technologies can then be used by other Lyondell polyols manufacturing sites around the world. RESPONSIBLE CARE. Lyondell Chemical Company is fully committed to the principles of Responsible Care, which is an initiative of the Chemical Manufacturers Association (CMA) to improve industry performance in the areas of environment, health and sa fety, to improve the industry's safe management of chemicals, and to respond to public concerns. Since 1990, emissions of hazardous chemicals to the air from the Lyondell West Virginia facilities have been reduced by over 90% through improving processes and eliminating inefficient operations. We have also made continuous improvements in our safety performance every year and rank among the industry leaders in this important aspect. It is a policy of Lyondell to establish goals for continuous improvement in the areas of health, safety, and the environment based on sound science, risk assessment and benefit analysis, against which we will measure, audit and communicate our performance. Another initiative for continuous improvement is called Manufacturing Excellence. Manufacturing Excellence, launched in 1991, is a program of corporate standards which incorporates all of the Responsible Care. codes and Lyondell's own rigorous management systems. Manufacturing Excellence incorporates a system of Manufacturing Excellence Standards which ensure superior performance and continuous improvement in the following five key areas: safety and health, environmental, product quality, manufacturing reliability, and efficiency. The Manufacturing Excellence System consists of 43 performance standards in the five key areas listed above, and a system of Lyondell Facility Audits and Third Party Audits to evaluate compliance with the performance standards. The Third Party Audit System evaluates the regulatory compliance, reliability, and liability associated with the following types of third parties: Waste Sites, Terminals, Tollers, Key Suppliers, and Transporters. A rigorous auditing process evaluates how well our facility is meeting the high standards of Manufacturing Excellence. Audit teams composed of experts from various Lyondell facilities and the corporate auditing department examine performance, site conditions, and documentation to make sure the Manufacturing Excellenc e standards are met. I. Accidental Release Prevention and Emergency Response Policies The Lyondell Chemical Company South Charleston Plant is a tenant facility within the Union Carbide South Charleston Plant. Lyondell has a contract with Union Carbide to obtain emergency response services from the Union Carbide South Charleston Plant Emergency Response Team. The Lyondell South Charleston Plant, is committed to operating and maintaining all of our processes in a safe and responsible manner. We have implemented 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 to protect the environment. These programs include Lyondell's Manufacturing Excellence requirements, Union Carbide's Responsible Care. requirements, and governmental requirements, such as the Environmental Protection Agency's (EPA) Risk Management Program (RMP) rule (40 CFR Part 68) and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 CFR Part 1910.119). This document is intended to satisfy the RMP Plan requirements of the RMP rule and to provide the public with a description of the risk management program at the facility. II. STATIONARY SOURCE AND REGULATED SUBSTANCES The Lyondell South Charleston Plant is a manufacturing facility that produces a family of chemicals called polyether polyols. The polyols we make are used by our customers to manufacture polyurethane foams for such applications as furniture cushions, mattresses and for automotive applications such as seat cushions and energy absorbing instrument panels and side panels. Other customer applications include various coatings, adhesives, sealants, and elastomers. The RMP rule requires that if a facility, such as the South Charleston Plant, has a specific amount (threshold) or more of any one of 140 toxic and flammable chemicals, the facility must follow the RMP rule requir ements. The Lyondell South Charleston Plant handles RMP-regulated toxic substances and an RMP-regulated flammable substance in sufficient quantity to be covered by the RMP rule, is covered by the OSHA PSM standard, and falls under RMP Program Level 3. Lyondell handles and stores threshold quantities of the following RMP-regulated toxic substances at the South Charleston Plant: 7 Acrylonitrile 7 Ethylene Oxide 7 Propylene Oxide Lyondell handles and stores threshold quantities of the following RMP-regulated flammable substances at the South Charleston Plant: 7 Vinylidene Chloride III. Offsite Consequence Analysis Scenarios The Risk Management Program rule requires that covered stationary sources handling regulated substances conduct off-site consequence analyses (OCA) to evaluate the potential off-site impact of a worst-case scenario (WCS) and an alternative release scenario (ARS) for each regulated toxic chemical on site. RMP also requires covered sources to evaluate on e worst-case scenario and one alternative release scenario for a single chemical representing the class of flammables. All of these scenarios are developed using guidelines established in the RMP rule. In developing worst-case scenarios, companies must presume the release of the entire quantity of the largest container of a regulated chemical over a 10-minute period. Only passive mitigation systems, such as those that do not require energy or action by an employee to initiate can be considered. U.S. EPA acknowledges that these worst-case scenarios are unlikely to occur, so the RMP rule also requires that companies develop alternative release scenarios based on more credible release assumptions. Alternative release scenarios differ from worst-case scenarios in several important ways. They may be based on actual incident history or on events which are more likely to occur, and allow the use of both active and passive mitigation to reduce the potential impact of a release on the community outside the facility. EPA's Off-Site Consequence Analysis (OCA) Guidance Tables were used for evaluating the consequences of the WCS and ARS for both regulated flammable and toxic materials. Use of these tables resulted in the determination of a release endpoint distance. The EPA-recommended LANDVIEW program was used to estimate the number of people potentially affected in each scenario. The West Virginia Kanawha/Putnam County Emergency Services Maps and CD-ROM Program were utilized to identify the public and environmental receptors located within the scenario endpoint distance. According to the RMP rule, the release endpoint distance is intended to provide an estimate of the maximum possible area that might be affected for each scenario. It is intended to ensure that potential risks to the public health are recognized. For toxic releases, the endpoint is the distance beyond which chemical concentrations are low enough that an average individual could be exposed for up to one hour without suffering irreversible or debilitating health effects. For flammable releases, the endpoint distance is that distance beyond which the community would be subject to a pressure wave of less than 1 psi resulting from the formation of an exploding vapor cloud. Below this value little or no impact to the community is expected. The RMP rule requires that we provide information about the worst case and alternative case scenarios in our facility Risk Management Plans. The following are brief summaries of these hypothetical scenarios. Unless otherwise specified, no credit was taken for administrative controls or mitigation measures in the worst case scenarios. However, chemical-specific steps that would likely be taken to prevent or mitigate the effects of each scenario are listed immediately following the scenario description. The alternative release scenario descriptions include those mitigation measures that were considered, and any measures for which credit was no t taken are listed. More information on the facility's general accident prevention program is described in Section IV. A) Regulated Toxic Substances 1. Worst Case Scenario(s) 1.1 Worst Case Scenario - acrylonitrile The worst case scenario for acrylonitrile assumes a catastrophic failure of a storage tank, releasing 332,000 pounds of acrylonitrile as a liquid into a containment dike, leading to a vapor cloud release. According to EPA's Off-Site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. The following passive mitigation measure was used in this analysis: 7 Concrete Dike: The dike contains the acrylonitrile release and minimizes acrylonitrile evaporation to the atmosphere. This worst case scenario does not allow credit to be taken for the following safety and prevention systems which are in place to prevent this scenario from occurring, and to mitigate its effects should it occur: 7 Inventory Restriction: The storage tank is filled to a maximum of 90% of capacity. This inventory restriction limits the amount and effect of release. 7 Redundant Tank Level Devices: A system to monitor tank levels which includes two independent devices to measure and monitor tank levels. 7 Remote Actuation Valves: Remotely operated isolation valves on tank and pipelines. 7 Fail-safe Valves: All control valves are designed and installed to fail in the specific safe position, either fail-open or fail-closed. 7 Emergency Shutdown System: This computer-controlled system automatically shuts down or isolates a process under certain conditions and provides an audible alarm. 7 Deluge System: A water spray system which knocks down acrylonitrile vapor that is activated as needed. 7 Combustible Gas Detectors: Detects vapor and provides audible alarms. 7 Interlocks: Prevents improper process sequences and ensures all reactors operate within the established safe operating envelope defined by the Operational Safety Standards. 7 Surveillance: Operating employees routinely monitor the process and make routine unit walk-throughs to make sure equipment and systems are operating properly. 7 Low Emissions Piping Specifications: Minimum number of connections used in piping. Also special valves, pipe fittings, and gaskets have been installed in the acrylonitrile piping system to prevent emissions. 2. Alternative Release Scenario(s) 2.1 Alternative Release Scenario - propylene oxide The alternative release scenario for propylene oxide assumes a gasket failure on a reactor vessel below the liquid level, releasing 3,690 pounds of propylene oxide, during a 30-minute period, as a liquid into a containment dike, leading to a vapor cloud release. The gasket hole size is 0.79 inches and the release rate is 123 pounds per minute for 30 minutes. The reactor has to cycle through the cook out stage before it can be emptied. According to EPA's Off-Site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. The following passive mitigation measure was used in this analysis: 7 Concrete Dike: The dike contains the propylene oxide release and minimizes propylene oxide evaporation to the atmosphere. The following active mitigation measures were used in this analysis: 7 Surveillance: Operating employees routinely monitor the process and make routine unit walk-throughs to make sure equipment and systems are operating properly. 7 Remote Actuated Valves on Header: Isolates leak and minimizes the amount of material released. 7 Automatic and Manual Shut Off Valve: Both valves isolate propylene oxide flow from the plant propylene oxide distribution system. This scenario assumes that the leak is detected and stopped over a 30-minute period. The 30-minute time period is required to respond and cook out the reactor on an emergency basis. This alternative release scenario does not allow credit to be taken for the following safety and prevention systems which are in pla ce to prevent this scenario from occurring, and to mitigate its effects should it occur: 7 Inventory Restriction: The storage tank filled is to maximum of 90% of capacity. This inventory restriction limits the amount and effect of release. 7 Redundant Tank Level Devices: A system to monitor tank levels which includes two independent devices to measure and monitor tank levels. 7 Remote Actuation Valves: Remotely operated isolation valves on tank and pipelines. 7 Fail-safe Valves: All control valves are designed and installed to fail in the specific safe position, either fail-open or fail-closed. 7 Emergency Shutdown System: This computer-controlled system automatically shuts down or isolates a process under certain conditions and provides an audible alarm. 7 Deluge System: A water spray system that knocks down propylene oxide vapor that is activated as needed. 7 Combustible Gas Detectors: Detects vapor and provides audible alarms. 7 Interlocks: Prevents improper process seque nces and ensures all reactors operate within the established safe operating envelope defined by the Operational Safety Standards. 7 High Pressure Alarm and Shutdown: Alerts operator that the system is experiencing high pressure which could be indicative of a reaction occurring in the piping network or back pressure into the system from a connecting process and shuts system down. 2.2 Alternative Release Scenario - ethylene oxide The alternative release scenario for ethylene oxide assumes a gasket failure on a 2-inch ethylene oxide header feed pipe to the reactor vessel, releasing 2,200 pounds of ethylene oxide, during a 60-minute period, as a liquid into a containment dike, leading to a vapor cloud release. The release height is 4 meters, the gasket hole cross section is 0.098 square inches, and the release rate is 36.66 pounds per minute for 60 minutes. According to EPA's Off-Site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. The following passive mitigation measure was used in this analysis: 7 Concrete Dike: The dike contains the ethylene oxide release and minimizes ethylene oxide evaporation to the atmosphere. The following active mitigation measures were used in this analysis: 7 Surveillance: Operating employees routinely monitor the process and make routine unit walk-throughs to make sure equipment and systems are operating properly. 7 Remote Actuated Valves on Header: Isolates leak and minimizes the amount of material released. 7 Automatic and Manual Shut Off Valve: Both valves isolate ethylene oxide flow from plant ethylene oxide distribution system. This scenario assumes that the leak is detected and stopped over a 60-minute period. The leak is stopped by closing off the header valves. This alternative release scenario does not allow credit to be taken for the following safety and prevention systems which are in place to prevent this scenario from occurring, and to mitigate its effects should it occur: 7 Inventory Restriction: The storage tank filled is to maximum of 90% of capacity. This inventory restriction limits the amount and effect of release. 7 Redundant Tank Level Devices: A system to monitor tank levels which includes two independent devices to measure and monitor tank levels. 7 Remote Actuation Valves: Remotely operated isolation valves on tank and pipelines. 7 Fail-safe Valves: All control valves are designed and installed to fail in the specific safe position, either fail-open or fail-closed. 7 Emergency Shutdown System: This computer-controlled system automatically shuts down or isolates a process under certain conditions and provides an audible alarm. 7 Deluge System: A water spray system that knocks down ethylene oxide vapor that is activated as needed. 7 Combustible Gas Detectors: Detects vapor and provides audible alarms. 7 Interlocks: Prevents improper process sequences and ensures all reactors operate within the established safe operating envelop e defined by the Operational Safety Standards. 7 High Pressure Alarm and Shutdown: Alerts operator that the system is experiencing high pressure which could be indicative of a reaction occurring in the piping network or back pressure into the system from a connecting process and shuts system down. 2.3 Alternative Release Scenario - acrylonitrile The alternative release scenario for acrylonitrile assumes a gasket failure on the acrylonitrile unloading pump discharge line, on the pump inlet side, located at the railcar unloading station, releasing 6,160 pounds of acrylonitrile, during a 20-minute period, as a liquid, leading to a vapor cloud release. The leak is downstream from the low flow detection device. The release height is 1 meter, the gasket hole size is 0.88 inches, and the release rate is 308 pounds per minute for 20 minutes. According to EPA's Off-Site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. The following passive mitigation measure was used in this analysis: 7 Flangeless Line: The acrylonitrile unloading line is welded pipe with no flanges from the connection at the acrylonitrile unloading pump discharge side at the railcar, up to the connection at the unit boundary automatic valve, close to the acrylonitrile storage tank. This flangeless pipe section minimizes acrylonitrile releases. The following active mitigation measures were used in this analysis: 7 Surveillance: Operating employees routinely monitor the process and make routine unit walk-throughs to make sure equipment and systems are operating properly. 7 Cameras: The acrylonitrile railcar unloading area is under surveillance by area cameras that are watched from the main control room. This is in addition to the field surveillance. This scenario assumes that the leak is detected and stopped over a 20-minute period. The leak is stopped by turning off the pump and closing the valve on the line. This alternative release scenario d oes not allow credit to be taken for the following safety and prevention systems which are in place to prevent this scenario from occurring, and to mitigate its effects should it occur: 7 Low Flow Detection and Alarm: The acrylonitrile unloading line contains low flow detection and alarm to provide an alarm warning of a possible leak. 7 Remote Actuation Valves: Remotely operated isolation valves on tank and pipelines. 7 Fail-safe Valves: All control valves are designed and installed to fail in the specific safe position, either fail-open or fail-closed. 7 Deluge System: A water spray system that knocks down acrylonitrile oxide vapor that is activated as needed. 7 Combustible Gas Detectors: Detects vapor and provides audible alarms. 7 Low Emissions Piping Specifications: Minimum number of connections used in piping. Also special valves, pipe fittings, and gaskets have been installed in the acrylonitrile piping system to prevent emissions. 7 Automatic and Manual Shut Off Val ve: Both valves isolate acrylonitrile flow from plant acrylonitrile distribution system. 7 Spray Protection at Unloading and Discharge: Water spray protection at both ends of the flangeless acrylonitrile line which reduces the loss of acrylonitrile to the atmosphere. B) Regulated Flammable Substances 1. Worst Case Scenario(s) 1.1 Worst Case Scenario - vinylidene chloride The worst case scenario for vinylidene oxide assumes a catastrophic failure of a storage tank, releasing 148,000 pounds of vinylidene chloride as a liquid into a containment dike, leading to a vapor cloud explosion and overpressure. The release height is 7.5 meters and the release rate is 667 pounds per minute for 15 minutes. According to EPA's Off-Site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. The following passive mitigation measure was used in this analysis: 7 Concrete Dike: The dike contains the vinylidene chloride release and minimizes vinylidene chloride evaporation to the atmosphere. This worst case scenario does not allow credit to be taken for the following safety and prevention systems which are in place to prevent this scenario from occurring, and to mitigate its effects should it occur: 7 Inventory Restriction: The storage tank filled is to maximum of 90% of capacity. This inventory restriction limits the amount and effect of release. 7 Redundant Tank Level Devices: A system to monitor tank levels which includes two independent devices to measure and monitor tank levels. 7 Remote Actuation Valves: Remotely operated isolation valves on tank and pipelines. 7 Fail-safe Valves: All control valves are designed and installed to fail in the specific safe position, either fail-open or fail-closed. 7 Emergency Shutdown System: This computer-controlled system automatically shuts down or isolates a process under certain conditions and provides an audible alarm. 7 Deluge System/Spray Protection at Storage Tank: A water spra y system that knocks down vinylidene chloride vapor that is activated as needed. This system minimizes the fire hazard and prevents vapor cloud explosions. 7 Combustible Gas Detectors: Detects vapor and provides audible alarms. 7 Interlocks: Prevents improper process sequences and ensures all reactors operate within the established safe operating envelope defined by the Operational Safety Standards. 7 Surveillance: Operating employees routinely monitor the process and make routine unit walk-throughs to make sure equipment and systems are operating properly. 2. Alternative Release Scenario(s) 2.1 Alternative Release Scenario - vinylidene chloride The alternative release scenario for vinylidene chloride assumes an overfill of the vinylidene chloride storage tank, releasing 10,000 pounds of vinylidene chloride through the pressure relief valve, during a 15-minute period, as a liquid into a containment dike, leading to a vapor cloud explosion and overpressure. According to EPA' s Off-Site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. The following passive mitigation measure was used in this analysis: 7 Concrete Dike: The dike contains the vinylidene chloride release and minimizes vinylidene chloride evaporation to the atmosphere. The following active mitigation measures were used in this analysis: 7 Surveillance: Operating employees routinely monitor the process and make routine unit walk-throughs to make sure equipment and systems are operating properly. This scenario assumes that the release is detected and stopped over a 15-minute period. This alternative release scenario does not allow credit to be taken for the following safety and prevention systems which are in place to prevent this scenario from occurring, and to mitigate its effects should it occur: 7 Inventory Restriction: The storage tank is filled to a maximum of 90% of capacity. This inventory restriction limits the amount and effect of r elease. 7 Redundant Tank Level Devices: A system to monitor tank levels which includes two independent devices to measure and monitor tank levels. 7 Remote Actuation Valves: Remotely operated isolation valves on tank and pipelines. 7 Fail-safe Valves: All control valves are designed and installed to fail in the specific safe position, either fail-open or fail-closed. 7 Emergency Shutdown System: This computer-controlled system automatically shuts down or isolates a process under certain conditions and provides an audible alarm. 7 Deluge System/Spray Protection at Storage Tank: A water spray system that knocks down vinylidene chloride vapor that is activated as needed. This system minimizes the fire hazard and prevents vapor cloud explosions. 7 Combustible Gas Detectors: Detects vapor and provides audible alarms. 7 Interlocks: Prevents improper process sequences and ensures all reactors operate within the established safe operating envelope defined by the Operational Safety Sta ndards. 7 High Pressure Alarm and Shutdown: Alerts operator that the system is experiencing high pressure which could be indicative of a reaction occurring in the piping network or back pressure into the system from a connecting process and shuts system down. 7 Automatic and Manual Shut Off Valve: Both valves isolate vinylidene chloride flow from plant vinylidene chloride distribution system. IV. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps General Program The Lyondell West Virginia general accident prevention program consists of compliance with the EPA RMP rule and the OSHA PSM standard, and implementation of Lyondell's Manufacturing Excellence Standards, Union Carbide's Operational Safety Program and Union Carbide's Episodic Risk Management System. The key elements of these systems include the following: Equipment Design: Vessels (including shipping containers) and other process equipment are designed according to recognized industry standards and/or governmental requirements. Process Safety Information: Chemical hazard, process technology, and equipment information is documented, maintained up-to-date, and available to operating personnel. Critical Operating Parameter (COPs): Never exceed limits and normal operating windows on process variables such as temperature, flowrate, and pressure. Process Hazard Analysis: A rigorous practice of reviewing new processes or changes to existing processes at the design stage to identify and mitigate potential safety, health, and environmental issues before the process is installed and operated. Scheduled process hazard/risk reviews are conducted to revalidate initial process hazard reviews on a periodic basis. Process hazard analyses are conducted every five years to identify major process hazard scenarios and to recommend corrective action(s) needed to prevent their occurrence. Episodic Risk Management System: Periodic reviews are conducted to identify hazards which coul d have significant community impact and to recommend corrective action(s) needed to prevent their occurrence. These reviews utilize advanced quantitative risk assessment techniques. Operational Safety Standards: A company sponsored operational safety program that meets OSHA Process Safety requirements. Design requirements for active and passive mitigation controls used to prevent major process hazards are documented in the operational safety standards. Operating Procedures: Operating procedures provide detail on how to safely operate a process and are maintained up-to-date. All operating procedures are based on process hazard/risk reviews. Operator Training/Certification Program: The plant has a training and testing program which provides operators with the proper skills and knowledge prior to allowing them to independently operate a process. Computerized Process Simulation: Computerized process simulation programs are used for training and troubleshooting. Technical Staff Trai ning and Support: Trained technical staff employees are available 24 hours a day to support operations. Maintenance Procedures: The plant has specific procedures for maintaining process equipment so that it operates safely. Plant and unit specific procedures for servicing operating equipment are in place, including preventative maintenance and reliability programs. Maintenance Training: The plant trains and tests mechanics and craftsmen who perform routine or complex maintenance tasks on process equipment and inspections on operating equipment to ensure they have the required knowledge and skills. Mechanical Integrity Program: Vessels (including shipping containers) and other process equipment are periodically tested and inspected to ensure safe operation of process equipment, following recognized standards and/or government requirements. This program includes testing, inspection and maintenance of critical equipment, including pressure relief devices, hoses, piping, instruments, and shutdown systems. Material Analysis: Analysis of key chemical raw materials to ensure they meet specifications prior to charging into the process reactor. Lyondell obtains a Certificate of Analysis from the supplier for all raw material shipments. Quality Assurance: The plant has a system to ensure that purchased equipment and materials meet established engineering standards and specifications. Management of Change: The plant has a management system to ensure that modified facilities and processes are safe for operation. Design and pre-startup safety reviews are conducted for facility or process changes before the changes are implemented. Pre-Startup Safety Reviews: Reviews are conducted just prior to startup to ensure that modified facilities and processes are safe for operation. Incident Investigation: The plant has a program to ensure accidents, incidents, and near miss events are properly investigated to determine the Root Cause(s) and Contributing Cause(s), and to i mplement corrective action(s) that are needed to prevent recurrence. Employee Participation: The plant has a program to involve employees in prevention program elements. Permits: The plant uses a variety of work permits to control those activities that represent work outside of regular plant operations. These include Lockout/Tagout, Hot Work, Line Breaking and Confined Space Entry permits. Employees are involved in designing, implementing and following the permits. 7 Lockout/Tagout - Isolation of equipment to be serviced from energy sources. This prevents chemical releases and injuries to workers from unexpected energization, start-up, or release of stored energy. 7 Hot Work - Protects employees and property by preventing fires and explosions. It ensures, among other things, that no flammable materials are present when an open spark or flame may be present for maintenance activities. The plant has a procedure to ensure that welding, cutting and brazing are safely performed in a reas where flammable or combustible material may be present. 7 Line Breaking - Requires isolation and draining of lines to be opened. It details required personal protective equipment based on the chemical contained in the line. 7 Confined Space Entry - System using engineering and administrative controls, along with personal protective equipment, to protect the health and safety of personnel working within confined spaces, such as tanks. Contractor Safety Program: The plant has a program to ensure that contractors are properly trained and perform their work in compliance with safety requirements. Contractors must meet rigorous safety performance requirements before being allowed to work on process equipment. Contractor employees and regular plant employees must follow all of the same plant safety procedures and requirements. Compliance Audits: Periodic corporate-led and plant-led audits are conducted to ensure that process operations comply with governmental, Lyondell and Union Carbide requirements. Emergency Procedures: Plant and process specific emergency response procedures and training to ensure proper response and notification in the event of a release. Manufacturing Excellence Standards: Rigorous corporate standards that we follow to ensure that we operate our facilities in a safe and environmentally sound manner. Our compliance to these standards is routinely audited by corporate experts. We have Manufacturing Excellence Standards in the following areas: Environmental, Health and Safety; Technical; Operations; Maintenance; Transportation and Storage; Quality; and Purchasing. Manufacturing Excellence is Lyondell's comprehensive program to ensure that all the elements listed above are implemented and maintained at every Lyondell facility. This program includes accountabilities for timely and proper implementation of the program elements. These general prevention elements and the chemical specific steps discussed in the previous section are parts o f an overall management system to prevent accidental chemical releases. Our company and our employees are committed to the standards that these management systems set. We have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. V. Five-Year Accident History In the last five years there has not been an accident or incident involving an EPA RMP chemical at the Lyondell South Charleston Plant that resulted in an on-site death, injury, or property damage; or a known off-site death, injury, evacuation, shelter-in-place, property damage, or environmental damage. VI. Emergency Response Program The Lyondell Chemical Company South Charleston Plant is a tenant facility within the Union Carbide South Charleston Plant. Lyondell has a contract with Union Carbide to obtain emergency response services from the Union Carbide South Charleston Plant Emergency Response Team and the Union Carbide Emergency Operations Center (EOC). Th e South Charleston Plant maintains a highly trained emergency response team to provide safe and appropriate response to any type of plant emergency and hazardous materials incident. It also participates in local fire and industrial mutual aid systems through the Kanawha Putnam Emergency Planning Committee (KPEPC). The South Charleston Plant maintains a written emergency response program to protect worker and public safety, as well as the environment. The program consists of procedures for responding to releases of hazardous substances, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response including: 7 Proper first-aid and medical treatment for exposures 7 Evacuation plans and accounting for personnel after an evacuation 7 Notification of local emergency response agencies and the public if a release occurs 7 Post-incident cleanup and decontamination requirements, and 7 Inspect ing, testing, maintaining, and using emergency response equipment. The emergency response program is updated when necessary based on modifications made to facility processes. The South Charleston Plant maintains a trained emergency squad to handle fires, explosions, toxic vapor releases, spills, and medical emergencies. The plant emergency squad trains and drills with local emergency responders to enhance their skills and tactics for responding to an accidental chemical release. Critiques are held on drills and actual events. In addition to the plant emergency squad, Union Carbide staffs a Hazardous Emergency Leak Prevention (HELP) team in the Kanawha Valley that responds to accidental releases in the South Charleston Plant and from transportation equipment throughout the continental United States. The emergency response program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Detaile d emergency response plans are developed and coordinated with the Kanawha Putnam Emergency Planning Committee and the community. VII. Planned Changes to Improve Safety The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: 7 A new Corporate program designed to ensure that process safety information is maintained evergreen. 7 Continue use and implementation of the Apollo Root Cause Analysis problem solving technique to investigate incidents, to identify causes of process problems, and to develop effective solutions to prevent their recurrence. 7 Continue to implement the storage tank and piping repainting program to protect against corrosion, weathering and rust. 7 Add redundant relays, controls and switches to some existing unit instrumentation. 7 Upgrade Distributed Control Systems (DCS) for better reliability and capability. 7 Replacement of Propylene Oxide header piping sectio ns. This will eliminate 50 to 60 sets of flanges from the line and eliminate older piping. 7 Upgrade to Deluge Systems throughout Polyols Facility to replace older equipment and to improve emergency response capability. 7 Additional piping supports in areas identified by process hazard analyses and by the piping vibration analysis program. 7 Heat exchanger upgrades to improve process safety, reliability and capability. 7 Upgrade and replace process safety valves and relief valves to improve process safety capability. 7 Upgrade Acrylonitrile Unloading Facilities to improve electrical control system and deluge system. 7 Upgrade dikes around Vinylidene Chloride pumping systems. 7 Upgrade Reactor Systems to improve process reliability. 7 Upgrade piping switchbanks to minimize potential for spills and leaks. 7 Upgrade to tank farm diking containment. 7 Upgrade nitrogen distribution system to improve process control reliability and capability. 7 Upgrade emergency response computer databas e to improve ability to calculate release quantities and to increase reference data to improve emergency response capability 7 Annual testing, inspection, and replacement of flexible transfer hoses at the Vinylidene Chloride Unloading Station |