Formosa Plastics Corporation,Texas - Executive Summary |
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EXECUTIVE SUMMARY Formosa Plastics Industrial Park, located on F-M 1593 in Point Comfort, Texas, is operated by Formosa Plastics Corporation, Texas (FPC-TX). FPC-TX is a vertically integrated organization. It consists of nine "covered process" operations and four support organizations. The facility is located in the city of Point Comfort, Calhoun County, Texas. The facility currently employs 1,281 employees. The Risk Management Plan (RMP) was prepared by the Corporate Process Safety Management Coordinator. Each operating unit has appointed one individual as the person responsible for implementation of the RMP in that Unit. The Environmental, Health and Safety Department, through the Emergency Response Coordinator, oversees, provides guidance, and audits the RMP activities of the operating units. Compliance with 29 CFR 1910.119: On May 26, 1992, OSHA's Process Safety Management (PSM) rule went into effect. FPC-TX is covered under this rule. The PSM rule consists of fourteen (14) ele ments. The facility has developed and implemented the fourteen elements of this rule. Worst Cases for Toxic Chemicals was the release of anhydrous hydrogen chloride gas from VCM Unit, column VC-501. Worst Case for Flammable Chemicals was the release of C4 Mix* from the Olefins Unit, Tank 6440FA. *C4 mix (containing 52% 1,3-Butadiene and 13% 1-Butene) is a chemical that falls under the definition of a mixture with an NFPA rating of 4 5-year accidental release history: March 1, 1994 through March 31, 1999 was selected for the five year accidental release history. As the facility updates their R&D Plan, the 5-year period will be adjusted accordingly. There was only one accidental release,12/4/98, that had any offsite consequence in that there was shelter-in-place and minor off-site environmental impacts. SUPPORT ORGANIZATIONS Administration Department Plans, organizes, directs, and controls the activities of the administrative services to carry out the administrative sup port operations at the company. Store Inventory: Total commitment to providing service by ensuring that proper material stock levels are maintained, all materials received meet specifications, and right materials of the best quality are delivered at the correct time. Personnel. Provides quality service to Operation Units in Human Resource management, i. e., securing consistency in the applications, policy, training, and providing timely answers to employee's questions, complaints, and concerns. General Services: To provide reliable quality service in ground maintenance, office administration, and general affairs services. Technical Department Technical Department's responsibility is to provide laboratory-scale analyses and support to Operations for process control, environmental compliance, and product development. The personnel handle small amounts of hazardous gases and liquids in their daily functions. Environmental, Health and Safety Department The Environmental, Health and Safety Department (EHS) performs three major functions: 1) Policy writing 2) Training program development 3) Auditing of facility compliance ENVIRONMENTAL, HEALTH AND SAFETY POLICY The company is committed to the protection of the environment, the safety and health of our employees and the community. This is accomplished through the use of clear and well documented systems and procedures, proper training and qualification, high performance expectations, continual improvement in pollution prevention, minimization and recycling, as well as workplace hazard analysis and prevention. Through the joint efforts of every employee, we shall maintain full compliance with all applicable environmental and safety laws and regulations, conserve natural resources, reduce wastes and keep our workplace free of health and safety hazards, for ourselves, for the community and for future generations. Environmental is divided into two sections: Air Management and Water & Waste Management. The Water an d Waste Management Section is responsible to seek continual improvements in pollution prevention, waste minimization and recycling with regard to applicable water and solid hazardous waste laws. Through the development of policies and procedures, training and auditing, the Water and Waste Management section strives to assist the Operations units in meeting their Environmental Goals. The Air Management Section is responsible for policy development with regards to applicable air laws and regulations. Routine auditing of the facility insures continued compliance and enhances all employees environmental awareness. This section is also responsible for the operation of offsite air monitoring systems. Health is divided into two sections: Industrial Hygiene and Medical. 7he Industrial Hygiene Section is responsible for policy development and training in the areas of physical and chemical stressors. The section also audits these programs to help maintain compliance with regulations. - Th e Medical Section provides a comprehensive physical examination program in accordance with OSHA standards. The staff utilizes the latest in medical equipment and technology to treat medical emergencies for company and contractor employees. This group provides assistance for non-occupational illnesses and injuries, coordinates Worker's Compensation claims, provides immunizations for hepatitis and tetanus vaccines and facilitates return to work for occupational and non-occupational cases. Safety is divided into two sections: Process Safety and Emergency Response. Process Safety is responsible for policy development as well as Facility auditing to check compliance with both Formosa policy and Federal safety standards. The Process Safety section is also involved with Safety Module Instruction Training (SMIT) as well as development of specific training modules used by the Operations group. The Emergency Response section is responsible for management and mitigation of emergencies (Fire, H az-Mat, Rescue, Medical) which may occur in the Facility. The Emergency Response section supervises and trains Operations group personnel assigned to the Plant Emergency Response Team (ERT). Through routine auditing and inspections, the Emergency Response section checks compliance with certain Formosa Plastics Corporation Environmental, Health and Safety procedures. The facility Emergency Response Team members receive a total of 64 hours training each every year; including 32 hours at the Texas A&M Industrial Fire School at College Station, Texas. Maintenance Department The FPC, Texas Maintenance Department is a multilevel Department established to maintain and increase equipment reliability and efficiency. Following are brief descriptions of the Maintenance Departments and their inter-relationships within this Facility. Central Maintenance Central Maintenance includes Overall Maintenance Management and Staff, Maintenance Discipline Management, Maintenance Shop, Predictive Mainten ance, Civil Maintenance, and DCS and Analyzer Maintenance. Maintenance Management (A. V P) Responsible for overall Maintenance Department functions. The Maintenance A. V. P. is the primary contact point between Maintenance and Operations Management and the General Manager and Vice President of Operations. Maintenance Shop Provides machine shop, rotating equipment support, fabrication services, garage, fuel service, hydroblasting, vacuum truck service, valve repairs and other maintenance services for both Operations and the other Maintenance Departments. The Maintenance shop also serves as a paper and used oil recycling collection point for the Facility. Civil Maintenance Provides civil maintenance support to all Departments. In addition they are responsible for railcar and rail repair. Predictive Maintenance Predictive Maintenance provides a computerized corrosion/erosion program on predetermined intervals for the Facility to ensure equipment integrity is maintained. Additio nal services provided include Vibration analysis, various non-destructive testing services, remote visual inspection, alloy verification, freon leak survey, oil analysis, tank settlement monitoring, visual inspections, gas leak testing, and other predictive maintenance services as requested. Instrument Maintenance Analyzer/DCS Department This Instrument Department located in the Central Maintenance Shop provides scheduled maintenance on Analyzers, DCS Control Equipment, Continuous Emission Monitors and various in-plant monitors. This Department also provides instrument repair services in support of Instrument Field Maintenance. Maintenance Staff Maintenance Staff provides computer hardware, software, and network support to all the Departments. In addition, a Project team group provides assistance with capital improvement projects, small projects, and special projects as required. Maintenance Satellite Shops The Maintenance Department has an established Satellite Shop at each o perating plant. These satellite shops provide Mechanical, Electrical, and Instrument Maintenance Services to the Operating Units. The following descriptions apply to all three Maintenance Disciplines. Interactions with Operating Units is through established Equipment Route Checks, scheduled preventative maintenance, and analysis of abnormal equipment conditions. In addition to regularly scheduled maintenance activities, the Satellite shops meet weekly with Operations to discuss concerns, schedules, and abnormal analysis results. Various Maintenance services are also performed upon request from Operations through the work order system. This system allows requested work to be managed and completed in a timely manner. The Maintenance Organization as a whole exists to support Operations and provide equipment reliability, efficiency, and therefore equipment safety. Engineering Center (E/C) Administration E/C Administration is divided into three sub-sections and has a Project and Field C oordinator to act as an intermediary between Operations groups and contractors to insure maximum cooperation and coordination of contract activities. Schedule Control has primary function to control input and updates of construction schedules for the E/C and coordinate scheduling activities to avoid abnormal impacts between Engineering groups and Operations. Document Control is a support group to E/C for reproduction and distribution of related activities to design drawings and filing network into computer database for future reference and retrieval to all site personnel. QA section has primary responsibility to implement Quality Assurance Program and Owners Project Manuals for E/C. QA has authority to identify discrepancies and recommend solutions for corrective actions. QA also provides inspection support to Operations as conditions warrant for preparation of audits. Mechanical Project-I acts as an intermediary to insure maximum cooperation between the Operations group and the C ontractors in plant. Areas of responsibility include but are not limited to Offsite areas, Olefins, EG, PVC, and VCM plants for mechanical projects. Project-II acts as an intermediary to insure maximum cooperation between the Operations group and Contractors in the plant. Areas of responsibility include but are not limited to Utilities, Waste-Water Treatment, Chlor-Alkali, and Ethylene Dichloride, Polypropylene, 11igh-Density and Linear Low Density plants for mechanical projects. Design Team has intermediary responsibility for design activities related between Operations group and E/C on new work and construction projects assigned to E/C. The inter-relationship between Design Team and Operations is to insure the project guidelines and quality issues are included in design. Electrical Electrical acts as an intermediary to insure maximum cooperation between the Operations and Contractors in the plant for electrical construction projects assigned to the E/C. Responsibilities include new work and construction related projects to assure quality and production schedule are met. Instrument Instrument acts as an intermediary to insure maximum cooperation between the Operations group and Contractors in the plant for instrument related construction projects and new work assigned to the E/C. The primary objective is to assure quality and production schedules are met and to administer the contracts. Civil Upstream areas include new work and construction related projects in the plant associated with assigned work to E/C on structural, concrete, building, etc. Civil acts as an intermediary to insure maximum cooperation between the Operations group and the Contractors in the plant. The primary function is to administer the contracts and insure quality and production schedules are met through field inspections. Residential areas include new work and construction related projects outside the plant associated with work involved in housing, apartments, etc. Residential grou p has no direct responsibility with Operations group in this area. COVERED PROCESSES High Density Polyethylene (HDPE) Description of the Process The HDPE plant uses a low-temperature, low-pressure slurry process employing a Ziegler-Natta catalyst. There are two identical production trains. The total production capacity will be 440 million pounds per year of high-density polyethylene, with the capability of producing twenty different grades of product for various end uses. This process has been licensed to Formosa by Nippon Petrochemicals of Japan. The following is a brief process description. The raw materials for preparing catalyst are milled in a vibration mill to produce the high-activity Ziegler-Natta catalyst. The catalyst, made from titanium tetrachloride (the active component), aluminum ethoxide and magnesium chloride, is slurried in hexane in a mixing tank. Ethylene, hydrogen, hexane solvent and, for most grades, propylene or Butene- I as co-monomer, are fed to th e reactor system along with the catalyst slurry. A co-catalyst, triethylaluminum dissolved in hexane, is also fed to the reactor system to protect the catalyst from poisons. The polymerization reaction occurs in a series of loop reactors and agitated vessel reactors. The reactor conditions do not exceed 220 psig or 176 ( F. The resulting polyethylene slurry is depressurized in the flash tank, where unreacted ethylene, hydrogen and co-monomer and some hexane are flashed from the slurry. The vent gas is condensed to recover hexane. The non-condensed gas is compressed and recycled back to the reactors to increase yield. The polyethylene slurry is then pumped to the "Hexane Removal and Drying" section. The slurry is passed through two steam strippers in series to remove the hexane. The stripped hexane is condensed and sent to the hexane refining area. From the steam strippers, the polyethylene (now slurried in water) is sent through an inched rotating screw separator and a centrifuge in o rder to remove most of the water that had been added during the steam stripping. The remaining water is removed in a fluidized bed dryer. The dried powder is then pneumatically conveyed to the pelletizing area. In the pelletizing area, the powder, additives and stabilizers are injected into the extruder. The resulting stabilized polymer melt is then fed to an underwater cutting chamber, where the polyethylene is cut into pellets. The pellets are separated from the water in a centrifugal dryer. The pelletizing water blowdown is sent to wastewater treatment. The pellets are collected in a hopper, then air conveyed to the blending and product storage silos. The condensed hexane from the steam strippers is sent to T-502/2T-502. This "wet" hexane is then dehydrated in C-501/2C-501. The dry hexane is then pumped to the dehydrated hexane tanks, T503/2T-503 from which it is pumped back to the reactors. When the catalyst type must be changed, the leftover catalyst, slurried in hexane, is sent to V-502, the waste hexane stripper. Waste hexane from pumps and lines is routed via a chemical sewer system to V-502. A batch steam stripping operations is carried out periodically in V-502 and the recovered hexane is sent to T-502/2T-502. The waste water is sent to waste water treatment. All the non-condensed process vents from the process are routed to a header and sent to the incinerator for combustion. The exhaust air from the dryers is used as the combustion air in the incinerator. A standby incinerator is available for switchover of the vent streams when needed. Hazards of the Process The NAICS code for the unit is 325211. The process uses or stores I-Butene, ethylene, hydrogen, propylene and titanium tetrachloride. The hazards associated with the chemicals used in the process requires the unit to comply with OSHA's Process Safety Management rule (29 CFR 1910.119), NFPA 58 (Storage- and handling of liquified petroleum gases), Spill Prevention Control & Countermeasure progr am, and other applicable Resource Conservation & Recovery Act rule (RCRA). The equipment installed in the unit was designed based on either ASTM, ANSI, or ASME standards. Before starting the unit, a process hazard analysis (PHA) as required by OSHA regulation 29 CFR 1910.119 was completed. The methodology used was the Hazards and Operability study. Since the last PHA study, process parameters have been changed, and additional process controls, process detection systems and mitigation systems have been installed. During the study, the PHA Team evaluated major hazards like, toxic gas release; fire; explosion; runaway reaction; polymerization; overpressurization and overfilling tanks, reactors, etc; equipment failure; and loss of cooling, heating, electricity and instrument air. Based on the hazards, the Team insured that there were adequate process controls like, vents; relief valves and rupture disks to insure that holding vessels do not fail in case of overfilling or overpressurizat ion; check valves to insure that the chemicals do not flow back into equipment containing incompatible materials; flares in case of gas release; manual/ automatic shutoffs and excess flow device to prevent unwanted discharges; alarms and procedures for the operator to take action in case of a process upset; interlocks to insure that the system shuts down in case of an emergency; emergency air and power supply for equipment to keep functioning until the system can been shut down during utility failure; and process area detectors to warn the unit in advance of the impeding danger of a gas release. In case there was an incident, the Team also evaluated the mitigation systems like sprinkler and water deluge systems to either dilute or keep below the explosion point of a gas release; and dikes to insure that the release does not spread and contaminate the surrounding ground. Ion Exchange Membrane (IEM) Description of the Process Well brine is fed to the IEM plant as raw material from brine well via a pipe. The well brine is purified in the Brine Treatment section to meet the requirements of cell feed. The brine in the anode chambers and water in the cathode chambers of ion-exchange electrolyzers are disassociated by direct current and form caustic soda, chlorine gas and hydrogen gas. The depleted brine from the electrolyzers is dechlorinated and saturated in the Brine Treatment section and chlorine gas from the electrolysis section is washed with water, cooled with chilled water and dried with sulfuric acid. The gas is then compressed and sent to Vinyl Chloride Monomer (VCM) and Ethylene Dichloride (EDC) plant by pipeline. Hydrogen gas from the Electrolysis section is washed with water and cooled with chilled water. Then the gas is compressed and sent to power plants. Hydrochloric Acid Synthesis section is installed to produce hydrochloric acid consumed in the IEM plant. Waste chlorine absorption and destruction system is provided to absorb off chlorine gas gene rated in the IEM plant at start up, emergency and normal operation and to insure safety against environment. The caustic soda generated from the Electrolysis Section is concentrated from 32 weight % to 50 weight % in the caustic concentration section and loaded to tank trucks, rail cars, barge and ships as products. A part of 32 weight % caustic is used as chemical in the IEM plant and other plants after diluted to 20 weight %. Cooling water, chilled water and plant air consumed in the IEM plant are prepared in the IEM plant. The cooling water and the plant air prepared in the IEM plant are also supplied to the EDC plant. Low pressure steam is produced in the IEM plant by reducing the pressure and temperature of the middle pressure steam. Utilities other than cooling water, chilled water, plant air and low pressure steam necessary for the IEM plant are supplied to the IEM plant from the utility station in the complex by pipe lines. Chemical waste water generated in each section is c ollected in the Waste Water Treatment Section and discharged to the central waste water treatment facility in the complex after neutralized. Storm water in the IEM plant is collected in the Storm Water Storage Tank and discharged to the Central Waste Water Treatment Section. Ethylene Dichloride Unit The Ethylene Dichloride (EDC) Unit utilizes the Stauffer process to produce liquid ethylene dichloride by the liquid phase chlorination of ethylene in the presence of a ferric chloride catalyst. The EDC unit contains a reactor section, water wash and caustic wash section, fractional distillation section, waste water treatment section and gas incinerator section. Reactor Section Ethylene (1) and chlorine (2) are added to the EDC Reactor through spargers and completely mixed. The chlorine concentration in the crude EDC overflow is maintained at 0.03% to 0.05% by weight. Ferric chloride is present within the reactor due to the reaction between the chlorine and the carbon steel ferrule i n the reactor and acts as a catalyst for the process. The reactor product overflows to the Water Wash Decanter in the Water Wash and Caustic Wash Section. Non-condensable vent gases flow to the gas incinerator. Water Wash and Caustic Wash System The reactor product (crude EDC) is washed with the acidic water in the Water Wash Decanter. The water washed EDC which contains traces of HCI and C12, is fed to the Caustic Wash Decanter, mixed with caustic and separated into phases. Washed water from the Water Wash Decanter is sent to the wastewater treatment system. The neutral EDC is stored in the Wet Crude EDC Storage Tank. The spent caustic solution overflows the Caustic Wash Decanter and gravity flows to the waste water treatment system. Vent gases from the decanters are combined, scrubbed, and sent to the gas incinerator. Fractional Distillation The wet, neutral crude EDC is pumped from the Wet Crude EDC Storage Tank to the Light End., Column. The preheated feed enters near the top of the column. A small quantity of 5% caustic solution is added into the overhead condenser to neutralize the HCL by product. The overhead condensate flows by gravity to the LE Column Reflux Accumulator where phase separation takes place. The organic (lower) phase is returned to the column and the aqueous (upper) phase is recirculated and added to the overhead condenser. The excess wastewater flows from the accumulator to the Wastewater Storage Tank. Uncondensed vapor from the LE Column accumulator is demisted and sent to gas incinerator. The dry underflow from the fight ends column is pumped to the heavy ends column. The feed enters near the bottom of the column. The overhead vapor is condensed and flows by gravity to the HE Column Reflux Accumulator. A portion of the condensate is returned to the column as reflux. The remaining portion of the overhead condensate is pumped from the accumulator to the HCI Stripper. The bottoms from the Heavy Ends Column is stored in the Heavy En ds Hold Tank, and then sent to the EDC recovery column. Product from the EDC Recovery Column is returned to the Heavy Ends Column. The underflow material from the EDC Recovery Column is a by-product of the EDC process. This material is transported by tank truck to various end users (customers) for reprocessing. EDC from the Heavy Ends Column is stripped in the HCI Stripper to purge the residual HCI in the EDC to 2 ppm. Bottom product from the HCI Stripper is pumped out through a product cooler to product storage. The overhead condensate from the HCI Stripper is collected in a receiver and fed by gravity back to the Water Wash Decanter. Non-condensable gases from the stripper are sent to the gas incinerator system. Wastewater Treatment All process wastewater streams within the EDC Unit are collected in a totally enclosed system, then pretreated prior to discharge to the Wastewater Treatment Plant (WWTP). Wastewater streams are combined, neutralized and sent to the Wastewater Storag e Tank. EDC contained in the wastewater settles to the bottom of the storage tank, is separated from the water in the tank and returned to the Water Wash Decanter. The wastewater is sent to the Steam Stripper. Steam is sparged into the bottom of the column, and strips EDC from the wastewater. The condensate from the Steam Stripper Condenser flows by gravity to the Caustic Wash Decanter. Wastewater from the bottom of the stripper contains less than 0.4 ppm of EDC and is pumped to the overall wastewater treatment system. Gas Incinerator Dry waste gases and wet waste gases from process equipment and tanks are fed to the gas incinerator system. The incinerator system will handle waste gas from both the existing EDC train (train A) and the proposed EDC train (train B). The incinerator system is designed to provide 1.5 seconds average residence time with an operating temperature of 1600(F to 1800( F. The combustion products from the incinerator enter the waste heat boiler to produce 100 psig steam and reduce the gases to approximately 450(F. The gases then enter the absorber, where 96% of the HCI is removed. The exit gas from the absorber passes into a caustic scrubber where the HCI is reduced to 7.5 ppmv (parts per million by volume) and the Cl. is reduced to 7.4 ppmv before discharge to the atmosphere. Marine Terminal Facility - EPN 8FD02 The incinerator/scrubber system will handle all EDC loading vapors. This system consists of an incinerator, quench tank, and caustic scrubber. The vendor has guaranteed a destruction efficiency of 99.99% of EDC vapor. The unit will be in service only when EDC is being loaded and during testing and maintenance. It will not remain on hot standby when not in use. If for any reason the incinerator is down, the loading of EDC will not occur. The incinerator will bum the waste gas at approximately 1900(F (average combustion temperature) and have a minimum residence time of 1.5 seconds. After the combustion is completed, the flue gas i s quenched to about 200(F and then flows through a packed caustic scrubber. In the scrubber, residual HCI is removed from the flue gas by circulating caustic through the scrubber. The flue gas is then vented to the atmosphere. The combustion temperature within the incinerator is maintained by a natural gas fired burner and is regulated by adding quench water to the combustion chamber. Caustic make-up water is introduced at the top of the column to remove HCL Caustic is added on pH control. If the pH is too low (too much acid in the bottoms), a valve will be opened allowing caustic to be discharged to the pH control tank. The incinerator/scrubber system has been designed to handle a maximum flow rate of 43,300 standard cubic feet per hour. This is based on a maximum EDC loading rate of 5,400 gpm. Vessels may be loaded individually or in groups of two barges at once, one ship and one barge simultaneously, or two ships at once. The emissions are based on the vendor guarantee. Emissions of EDC are based on 99.00% destruction efficiency. Hazards of the Process The NAICS code for the unit is 325181. The process manufactures chlorine and hydrogen gas. The hazards associated with the chemicals used in the process requires the unit to comply with OSHA's Process Safety Management rule (29 CFR 1910.119), NFPA 58 (Storage and handling of liquified petroleum gases), Spill Prevention Control & Countermeasure program, and other applicable Resource Conservation & Recovery Act rule (RCRA). The equipment installed in the unit was designed based on either ASTM, ANSI, or ASNIE standards. Before starting the unit, a process hazard analysis (PHA) as required by OSHA regulation 29 CFR 1910.119 was completed. The methodology used was Hazard and Operability method. Since the last PHA study, additional mitigation systems, process detection systems and perimeter monitoring systems have been installed. During the study, the PHA Team evaluated major hazards like, toxic gas release; fir e; explosion; runaway reaction; overpressurization and overfilling tanks, reactors, etc; contamination of the chemical; corrosion of pipes; equipment failure; and loss of cooling, heating, electricity and instrument air. Based on the hazards, the Team insured that there were adequate process controls like, vents; relief valves and rupture disks to insure that holding vessels do not fail in case of overfilling or overpressurization; check valves to insure that the chemicals do not flow back into equipment containing incompatible materials; flares in case of gas release; manual and automatic shutoffs to prevent unwanted discharges; alarms and procedures for the operator to take action in case of a process upset; interlocks to insure that the system shuts down in case of an emergency; emergency air and power supply for equipment to keep functioning until the system can been shut down during utility failure; and process area detectors and perimeter monitors to warn the unit in advance of the impeding danger of a gas release. In case there was an incident, the Team also evaluated the mitigation systems like sprinkler and water deluge systems to either dilute or keep below the explosion point of a gas release; dikes to insure that the release does not spread and contaminate the surrounding ground; and neutralization system to insure that the released chemical becomes non-hazardous to the environment. Linear Low Density Polyethylene (LLDPE) Description of the Process LLDPE (Linear Low Density Polyethylene) is one of the newest plastics and is the newest addition to the family of the Formosa Plastics Industrial Park. The LLDPE plant consists of seven units which are RSU (Reagent Receiving & Storage), CPU (Catalyst Preparation and Elutriation), PPU` (Prepolymerization), PU (Polymerization), APU (Additives and Pelletization), SRU (Solvent Recovery) and the UT (Utilities). Reagent Receiving and Storage (RSU): There are eight main reagents used in producing the LLDPE catalyst and one reagent used in Butyl chloride destruction. These will be received by keg, drum, portable container, and tank truck. The liquid reagents will be transferred to their storage vessel using nitrogen or a pump, and the solid reagents will be stored in buildings. Three of the chemicals used are a serious fire hazard. Two of the liquid chemicals are of the aluminum alkyl family which are pyrophoric (spontaneously igniting in air). These will be diluted with a solvent (hexane) when they are received. Once diluted, they are no longer pyrophoric. The third chemical, magnesium powder is also a fire and explosion hazard. It will be stored in an explosion proof building and handled using special procedures. Catalyst Preparation and Elutriation (CPU): The purpose of the catalyst preparation unit is to produce with repeatability a catalyst particle of particular size and reactivity. This process is planned so that critical stages can be monitored and adjusted to guarantee this rep eatability. The catalyst is prepared batchwise in a jacketed stirred tank reactor. The reaction required heating for initiation, then cooling for temperature control of the exothermic reaction. The result of this process is a slurry of small reactive catalyst particles which must then be elutriated for catalyst "fines" removal. Quantities of the reacting are controlled by the use of pipettes which accurately measure amounts through level control. The reaction is started on the surface of treated magnesium in a hexane solvent solution. Iodine with other minor chemicals are used to remove oxides from the surface of the magnesium. The catalyst reaction is initiated by the reaction of butyl chloride with the treated magnesium metal to form an organomagnesium compound. Once initiated, two titanium based chemicals, titanium tetrachloride and titanium propoxide are reacted with the magnesium compound to produce the catalyst. The progress of the reaction is monitored by the increase of butane in the gas phase composition. The rate of reaction is controlled by the metered addition of butyl chloride to the reactor. Once this charge is completed, there is a timed delay, then a very small charge of water is made. For production of an HDPE catalyst, dimethyl formamide is also added. These last two charges are for adjustments to the catalyst reactivity. Once the catalyst slurry has been produced and its reactivity adjusted, the concentration of the catalyst particles in the solvent is adjusted to a recipe concentration. A small quantity of surfactant is added to break apart any particle clumps, then the slurry is fed through an Elutriation system which uses the buoyancy differences in particles of different sizes to separate "fines" from the desired size range of catalyst particles. The catalyst slurry is fed to a hydro-cyclone. The lighter, more buoyant "fines" are carried out of the cyclone, and the larger, heavier catalyst particles fall into F 1/2-061. Once complete, the el utriated catalyst slurry is ready for pre-polymer production. The used hexane solvent is sent to the solvent recovery unit for purification. Pre-polymerization (PPU): The primary purpose of this unit is to improve the catalyst particle's receptiveness to hydrocarbons, to increase the particle size of the catalyst particle by the reaction with ethylene, and finally the drying of the prepolymer powder. The catalyst is first reacted with a co-catalyst, tri-octyl aluminum, in a hexane solvent solution. This co-catalyst replaces a chlorine atom on the catalyst molecule with an octyl group to make it more receptive to ethylene and hydrogen. As this new "receptive" catalyst is produced, ethylene gas is introduced into the reactor to produce small polyethylene particles. Also, a small influx of hydrogen is introduced for molecular weight or melt index control. The reaction is carried out in a hexane solvent primarily for control of the particle temperature. Because of the reactivity of the catalyst particles, a gas phase reaction would result in hot spots and particle agglomeration. Once the pre-polymer "seed" production is completed, the slurry is transferred to a dryer. The solvent is then vaporized and recovered. Finally, the dried pre-polymer powder is transferred by nitrogen downstream for subsequent metering into the polymerization reactor. Polymerization Unit (PU): In the polymerization unit, ethylene and a co-monomer are reacted with injected prepolymer powder in a fluid bed reactor to produce the LLDPE. This product is continuously withdrawn via a lateral withdrawal system for degassing and downstream process. Fluidization of the prepolymer and polymer particles is achieved by the reactor recirculation gas loop. The component concentration of the gas loop are measured by an in-line gas chromatograph and adjusted by a continuous vent purge and make-up of ethylene, co-monomer, hydrogen and nitrogen. As in the prepolymer reactor, the hydrogen is used to control the product molecular weight or melt index. Also the heat of reaction is removed by primary and secondary coolers on the gas loop. Primary control parameters of the reaction include the temperature which is controlled by the coolers on the gas loop, the gas phase composition, and the reactor bed level which is controlled by the prepolymer injection and product withdrawal systems. Product withdrawn via the lateral withdrawal system is degassed and deactivated before transfer to the pelletization unit. The recovered gas is compressed and returned back to the reactor gas loop. Additives and Pelletization (APU): In the additives and pelletizing unit, the virgin powder from the polymerization unit is received and blended with special additives for extrusion and pelletization. The product pellets are then pneumatically transferred to the product storage area. A portion of the virgin powder is blended with various additives batch-wise in a solids mixing tank or blender. These additives pro tect the product during extrusion and improve various characteristics of the customer's finished product. The blended powder is fed with virgin powder to an extrusion unit which heats and compresses the powder until it is liquefied. The liquefied polyethylene is forced out of the extruder through a die plate to the pelletizing unit. The die is composed of a steel plate with many small holes. As the liquefied plastic passes through this die, it forms a spaghetti-like shape, which is almost immediately frozen, or solidified, by cooling water which is circulated on the downstream side of the die. These spaghetti-like shapes are chopped in to 1/8" lengths with cutter blades located very close to the plate. The circulation of the cooling water carries these cut pellets to a water separation and drying process. The pellets are then pneumatically transferred to storage. Solvent Recovery (SRU): The solvent used in the catalyst and prepolymer production areas are collection, treated and puri fied in the solvent recovery unit. This unit also supplies the process with clean solvent. There are three main operations done in this area: * Solvent throughout the process that contains catalyst fines or butyl chloride (wash solvent is received to the solvent dryer. Prior to evaporation, the butyl chloride is destroyed in a reaction with tri-ethyl aluminum and catalyst fines. The solvent is then vaporized and subsequently condensed for purification. * The residue from the dryer which is primarily catalyst fines and residual solvent is transferred to a hydrolizer unit for catalyst activity destruction and neutralization. This destruction is exothermic and is accomplished by the addition of water. The hydrolizer unit is jacketed for reaction heat removal. After activity destruction, the slurry is neutralized with caustic. The water and solids are then transferred to the waste water stripping sections, and the remaining solvent is transferred to the heavy ends tank for further proces sing. * Solvent recovered from the dryer and processed recovered solvent that did not contained butyl chloride or catalyst fines are collected and purified in a fractionating column which separates heavy ends and water from the clean solvent. Utilities (UT): Operations of the LLDPE plant requires several utilities which include an incinerator, cooling tower, steam, nitrogen, etc. Hazards of the Process The NAICS code for the unit is 325211. The process uses or stores ethylene, I-Butene and titanium tetrachloride. The hazards associated with the chemicals used in the process requires the unit to comply with OSHA's Process Safety Management rule (29 CFR 1910-119), NFPA 58 (Storage and handling of liquefied petroleum gases), Spill Prevention Control & Countermeasure program, and other applicable Resource Conservation & Recovery Act rule (RCRA). The equipment installed in the unit was designed based on either ASTK ANSI, or ASME standards. Before starting the unit, a process hazard ana lysis (PHA) as required by OSHA regulation 29 CFR 1910-119 was completed. The methodology used was Hazard and Operability method. Since the last PHA study, additional mitigation systems have been installed. During the study, the PHA Team evaluated major hazards like, toxic gas release; fire; explosion; runaway reaction; over-pressurization and overfilling tanks, reactors, etc; contamination of the chemical; corrosion of pipes; equipment failure; loss of cooling, heating, electricity and instrument air; and natural disasters like floods, tornado and hurricanes. Based on the hazards, the Team insured that there were adequate process controls like, vents; relief valves and rupture disks to insure that holding vessels do not fail in case of overfilling or over-pressurization; check valves to insure that the chemicals do not flow back into equipment containing incompatible materials; flares in case of gas release; manual/ automatic shutoffs and excess flow device to prevent unwanted disch arges; alarms and procedures for the operator to take action in case of a process upset; interlocks to insure that the system shuts down in case of an emergency; emergency power supply for equipment to keep functioning until the system can been shut down during utility failure; quench system to cool heat generating reactions; purge system to insure that gas release does not cause an explosion and process area detectors to warn the unit in advance of the impeding danger of a gas release. In case there was an incident, the Team also evaluated the mitigation systems like sprinkler and water deluge systems to either dilute or keep below the explosion point of a gas release; dikes to insure that the release does not spread and contaminate the surrounding ground; and enclosure to insure that the released chemical remains within the building. Marine Terminal Description of the Process Operations Area - Traffic Traffic is composed of five areas within the Department; Inland I, Inland II , Inland III, Marine Traffic, and Administration Traffic (Polyolefins, PVC, & Railroad operations). Inland I is responsible for bagging and bulk loading of all PVC resins. Inland I interfaces with the originating process units in order to receive resin to be shipped. Inland I is not a manufacturing facility. Inland II responsibilities are identical to those of Inland I except that II handles Polyolefins resins which include PP, PE and LLDPE. Inland III is responsible for railroad operations which include switching cars, bringing in empty cars and shipping out the loaded cars. Inland III interfaces with each other area within traffic for scheduling and shipping purposes. Marine Traffic is responsible for the storage, loading and unloading of all bulk liquid products and feedstock by rail, truck, barge and ship. Marine interfaces with the related originating production units for shipping and scheduling. Administration Traffic is the coordinating entity for all of the Department's a ctivities. Hazards of the Process The NAICS code for the unit is 49319. The process stores n-butane, 1-Butene, i-butane, raw condensate (i-pentane, 55%), and 1, 3-Butadiene. The hazards associated with the chemicals used in the process, requires the unit to comply with OSHA's Process Safety Management rule (29 CFR 1910.119), NFPA 58 (Storage and handling of liquefied petroleum gases), Spill Prevention Control & Countermeasure program, and other applicable Resource Conservation & Recovery Act rule (RCRA). The equipment installed in the unit was designed based on either ASTM, ANSI, or ASME standards. Before starting the unit, a process hazard analysis (PHA) as required by OSHA regulation 29 CFR 1910.119 was completed. The methodology used was Hazard and Operability method. Since the last PHA study, additional mitigation systems have been installed. During the study, the PHA Team evaluated major hazards like, toxic gas release; fire; explosion; over-pressurization and overfilling tanks ; equipment failure; and loss of cooling, heating, electricity and instrument air. Based on the hazards, the Team insured that there were adequate process controls like, vents; relief valves to insure that holding vessels do not fail in case of overfilling or over-pressurization; check valves to insure that the chemicals do not flow back into equipment containing incompatible materials; manual shutoffs to prevent unwanted discharges; alarms and procedures for the operator to take action in case of a process upset; and emergency power supply for equipment to keep functioning until the system can been shut down during utility failure. In case there was an incident, the Team also evaluated the mitigation systems like sprinkler and water deluge systems to either dilute or keep below the explosion point of a gas release; and dikes to insure that the release does not spread and contaminate the surrounding ground. Other hazards considered were: the possibility of train derailments creating fire, explosion, or spill hazards, and possibility of fire, explosion or spill in the tank farms or on navigable waters. Olefin Process Description of the Process Nine pyrolysis furnaces crack a range of feedstocks (propane, butane, naphtha, and an ethane/propane mixture) at approximately 16000F. The cracked feedstock is first quenched in a direct contact oil scrubber and then further quenched in a direct contact water scrubber, cooling the outlet gases from the cracking process and removing oil, gasoline, and water. The cracked gas stream is sent to a series of five centrifugal compression stages. This increases the cracked gas pressure to approximately 570 psig, enabling efficient separation. Compressed process gas undergoes drying in molecular sieves before proceeding to the chilling system of the plant. The dry process gas and liquids are chilled using a combination of ethylene/propylene refrigeration and auto-refrigeration from cold product streams to allow separation in th e purification process. (Temperatures approach -250 0 F.) The purification process separates the process gases into the desired products (ethylene, propylene, mixed C4's, pyrolysis gasoline, hydrogen, and tail gas). Hazards of the Process The NAICS code for the unit is 32511. The process uses, stores or manufactures n-butane, ethane, ethylene, hydrogen, i-butane , raw condensate, naphtha, pyrolysis fuel oil, flux oil, wash oil, propane, propylene, 1, 3-Butadiene and methane. The hazards associated with the chemicals used in the process, requires the unit to comply with OSHA's Process Safety Management rule (29 CFR 1910.119), N-FPA 58 (Storage and handling of liquefied petroleum gases), Spill Prevention Control & Countermeasure program, and other applicable Resource Conservation & Recovery Act rules (RCRA). The equipment installed in the unit was designed based on either ASTM, ANSI, or ASME standards. Before starting the unit, a process hazard analysis (PHA) as required by OSHA regu lation 29 CFR 1910.119 was completed. The methodologies used were Hazard and Operability methods. Since the last PHA study, additional mitigation systems have been installed. During the study, the PSM Team evaluated major hazards like: toxic gas release; fire; explosion; runaway reaction; polymerization, over-pressurization and overfilling tanks, reactors, etc; contamination of the chemical; corrosion of pipes; equipment failure; loss of cooling, heating, electricity and instrument air; and natural disasters like floods, tornado and hurricanes. Based on the hazards, the Team insured that there were adequate process controls like: vents; relief valves and rupture disks to insure that holding vessels do not fail in case of overfilling or over-pressurization; check valves to insure that the chemicals do not flow back into equipment containing incompatible materials; flares in case of a gas release; manual/ automatic shutoffs and excess flow device to prevent unwanted discharges; alarms and procedures for the operator to take action in case of a process upset; interlocks to insure that the system shuts down in case of an emergency; emergency power supply for equipment to keep functioning until the system can been shut down during utility failure; quench system to cool down heat generating reactions; purge system to ensure that a gas release does not cause an explosion and process area detectors to warn the unit in advance of-the impending danger of a gas release. In case there was an incident, the Team also evaluated the mitigation systems like: sprinkler, foam and water deluge systems to either dilute or keep below the explosion point of a gas release; dikes to ensure that the release does not spread and contaminate the surrounding ground; and neutralization system to ensure that the released chemical becomes non-hazardous to the environment. Polypropylene (PP) Description of the Process The PP plant utilizes the BASF gas phase process to produce a total of 224 ,000 metric tons per year of Polypropylene pellets. The additional equipment consists of an extruder plus the downstream processing equipment: dryer, pellet deodorizer, cooling and additional pellet silos per line. The first step in the process is the purification of all raw materials. Propylene, ethylene, butylene, hydrogen, heptane and nitrogen are purified and dried in molecular sieves. Propylene is the main raw material and is used as the pellet monomer. Ethylene and butylene are used as co-monomers in the pellet production. Heptane is used as the solvent catalyst carrier and nitrogen is used as the conveying gas. The process utilized two catalysts: titanium trichloride and diethylaluminumchloride (DEAC). The two catalysts are suspended in heptane. The catalyst solution is sealed with a nitrogen pad in the day tanks and fed into the reactors. The monomers, co-monomers and catalyst solutions are continuously fed into the reactors. The reactor is operated at between 183 0F and 203 0F and at a pressure of between 400 psig and 450 psig. Hydrogen is introduced into the reactor to control the molecular weight of the polymer. A recycle line of propylene and hydrogen is continuously fed into the reactor. The heat generated by the polymerization reaction is removed from the reactor by recycle gas. In the event of an upset, the gas within the reactor will vent to the flare. Immediately following the reactor, a mixture of unreacted monomer, co-monomers and polymer powder is discharged to the powder degassing vessel where the majority of the unreacted monomer and co-monomers are separated from the powder and recovered. The powder is then discharged to the powder purge vessel where more unreacted monomer and co-monomers are purged out of the powder. This is a stirred vessel which is purged with nitrogen. In this vessel the monomer and comonomer residues are stripped out by a continuous addition of nitrogen. From the purge vessel the powder is sent to the powder buffer s ilos, via nitrogen conveying system, where it is metered into the extrusion process. The extrusion process consists of a twin-screw extruder with 12 barrels (there are 3 extruders, one per line). The first barrel is cooled with water to a temperature of 98 0F so that no semi-molten sticky material is obtained in the extruder throat. In barrels 2 and 3, the powder is melted by electrical heating. Between barrels 3 and 4, propylene oxide and demineralized water are injected. In barrels 4 and 5, the catalyst is decomposed by the water and the HCl is reacted with the propylene oxide (PO). In barrels 6 and 7, degassing of the Polypropylene melt occurs. Propylenechlorohydrin (PCH), a compound formed by HC1 and PO and excess PO together with heptane, water, propylene, nitrogen and small amounts of the co-monomers are sucked off into two degassing screws on the extruder. This stream is cooled then separated. The oily condensate is transferred to the liquid extruder. This stream is cooled then separated. The oily condensate is transferred to the liquid organic waste drum and the non-condensable gas is vented to the incinerator. Between barrels 11 and 12, other liquid additives and anti-static agents are added to the melt. From the extrusion process the cooled melt is cut into small pellets in an underwater pelletizer (rotary knife-like device). The pellets are then introduced into the rotary dryer where the pellets are dried. Air is introduced at the top of the rotary drier as the drying medium. The dry pellets fall into a sieve where they are separated by size. The pellets are then discharged to the pellet deodorization process. This step is necessary in order to strip out traces of odorous substances (residual VOC). The deodorized grades of Polypropylene pellets are needed for food applications. In the deodorizer a counter-flow stream of steam is used to strip the pellets of residual VOC. The VOC stripped out of the pellets accumulate in the steam; therefore, a slip stre am of steam is continuously taken out of the steam recycle loop of the deodorizer. The steam, which contains some hydrocarbons, is cooled down. The oily water is discharged to a separator where the liquid hydrocarbon is recycled back to the process, the water is discharged to wastewater treatment, and the desorbed waste gas is discharged to the incinerator. The pellets leaving the deodorizer are cooled in a continuously fluidized bed with air. The air is filtered prior to discharge to the atmosphere. Finally, the pellets are air conveyed to the pellet storage silos. The conveying air is separated from the pellets in the corresponding silos and is filtered prior to discharge to the atmosphere. From the product silos the pellets are transferred with air to the Traffic Department for packing and shipment to our customers. Hazards of the Process The NAICS code for the unit is 325211. The process uses or stores anhydrous ammonia and propylene. The hazards associated with the chemicals us ed in the process requires the unit to comply with OSHA's Process Safety Management rule (29 CFR 1910.119); Storage and handling of anhydrous ammonia (29CFR1910.111); NFPA 58 (Storage and handling of liquefied petroleum gases); Spill Prevention Control & Countermeasure program; and other applicable Resource Conservation & Recovery Act rule (RCRA). The equipment installed in the unit was designed based on either ASTM, ANSI, or ASME standards. Before starting the unit, a process hazard analysis (PHA) as required by OSHA regulation 29 CFR 1910.119 was completed. The methodology used was the What-If Method. Since the last PHA study, process parameters have been changed, additional process controls, process detection systems and mitigation systems have been installed. During the study, the PHA Team evaluated major hazards like, fire; explosion; runaway reaction; over-pressurization and overfilling tanks, reactors, etc; equipment failure; loss of cooling, heating, electricity and instrument air; and natural disasters like floods, tornado and hurricanes. Based on the hazards, the Team insured that there were adequate process controls like, vents; relief valves and rupture disks to insure that holding vessels do not fail in case of overfilling or over-pressurization; check valves to insure that the chemicals do not flow back into equipment containing incompatible materials; flares in case of a gas release; manual and automatic shutoffs to prevent unwanted discharges; alarms and procedures for the operator to take action in case of an unforeseen accident; interlocks to insure that the system shuts down in case of an emergency; emergency air and power supply for equipment to keep functioning until the system can been shut down during utility failure; quench system to cool heat generating reactions; purge system to insure that gas release does not cause an explosion and process area detectors to warn the unit in advance of the impeding danger of a gas release. In case there was an incident, the Team also evaluated the mitigation systems like water deluge systems to either dilute or keep below the explosion point of a gas release; dikes to insure that the release does not spread and contaminate the surrounding ground; and sectional alarm to alert the employees in case of an emergency. Polyvinyl Chloride Description of the Process The hot mix area is where chemicals are stored and mixed for consumption in the PVC process. These chemicals consist of dispersing agents for particle size, catalysts for reaction initiation, reactor chemical coating to inhibit scaling and the additive to stop reaction of polymerization. The reactor area is the main process area for producing PVC. The process is a batch by batch polymerization (reaction) of VCM dispersed in deionized water, using an organic peroxide as an initiator, in a reactor. The reaction process is an exothermic (heat producing) reaction. The reactor is heated, cooled and chilled using water as nee ded to control the temperature/pressure. The stripping area strips vinyl chloride monomer from the PVC slurry. The stripping is done in columns using steam and sieve trays. The columns operate under a vacuum. The stripped VCM gas is transferred to a gas holder and later liquefied and reused. The recovery area receives recovered VCM gas from the reactor, stripping and VCM T/C unloading areas. The gas is liquefied and reused in the reactors with fresh VCM. VCM from the VCM plant and from the VCM tank car unloading area is received in charge tanks and then charged to the reactors. The dryer area separates most of the water from the PVC slurry. The slurry is then dried in fluid bed and cyclone dryers. The powder is pneumatically transferred to silos for shipping. The VCM tank car unloading area is where imported VCM tank cars are emptied to two large spheres for use in the plant. The VCM from the spheres is pumped to the charge tanks located in the recovery area. The refrigeration area is for chilling water used in the reactor jackets, dryers, jacketed vessels in the hot mix area and heat exchangers. There are two storage tanks in this area for refrigerated water. Hazard of the Process The NAICS code for the unit is 325211. The process uses or stores anhydrous ammonia and vinyl chloride monomer. The hazards associated with the chemicals used in the process requires the unit to comply with OSHA's Process Safety Management rule (29 CFR 1910.119), Storage and Handling of ammonia (29 CFR 19 10. 111), NFPA 5 8 (Storage and handling of liquefied petroleum gases), Spill Prevention Control & Countermeasure program, and other applicable Resource Conservation & Recovery Act rule (RCRA). The equipment installed in the unit was designed based on appropriate standards that apply such as ASME, ANSI, or ASTM standards. A process hazard analysis (PHA) as required by OSHA regulation 29 CFR 1910.119 was completed. The methodology used was Hazard and Operability method. Since the la st PHA study, additional mitigation systems, process detection systems and perimeter monitoring systems have been installed. During the study, the PHA Team evaluated major hazards like, toxic gas release fire; explosion; runaway reaction; polymerization; over-pressurization and overfilling tanks, reactors, etc; contamination of the chemical; corrosion of pipes; equipment failure; and loss of cooling, heating, electricity and instrument air. Based on the hazards, the Team insured that there were adequate process controls like, vents; relief valves and rupture disks to insure that holding vessels do not fail in case of overfilling or over-pressurization; check valves to insure that the chemicals do not flow back into equipment containing incompatible materials; manual/ automatic shutoffs and excess flow device to prevent unwanted discharges; alarms and procedures for the operator to take action in case of an unforeseen accident; interlocks to insure that the system shuts down in case o f an emergency; emergency air and power supply for equipment to keep functioning until the system can been shut down during utility failure; and process area detectors to warn the unit of a gas release allowing action to be taken to minimize effect. Utilities Description of the Process The Utilities Area manages and supplies water and power resources of the Formosa Plastics Industrial facility at Point Comfort, Texas. Utilities is subdivided into two (2) areas as follows: Power Department handles incoming water, i.e., raw water from Lake Texanna, water purification for industrial and ultra-pure uses, electrical power production/distribution, and steam production/distribution. Water Department treats and manages water LEAVING the facility through permitted outfalls. Additionally this department is involved in water reuse development. Power Department Raw water is received from Lake Texanna by pipeline managed by the Lavaca-Navidad, River Authority (LNRA) to the Raw Water Pond(s ) where it can be stored for future use and retained for emergency (fire) purposes. Diesel and electric pumps located at each Raw Water Pond ensure that the "firewater" system pressure is maintained at the specified level. Additional pumps transfer water from the pond(s) to the purification plant for the removal of suspended particulate through clarification and filtration. As the water is transferred to the clarifiers, it is treated with CHLORINE, a highly hazardous chemical when stored/used in quantities greater than 1500 pounds, and with a polymer. Water leaving the clarifiers is filtered in deep bed gravity filters before being stored as "industrial water" for use in cooling towers, some processes, general water use, and for the feed to the demineralizer units for the production of ultra pure water. Ultra pure water is produced through the use of "resin exchange" technology to remove dissolved ions, cations and anions, from the water. This technology uses an inert resin which is "activated" by treatment with weak hydrochloric acid or caustic, depending on the ion to be removed charge. Once "activated" through the deposition of either hydrogen or sodium ions, the resin "exchanges" these ions for like charged ions in the water thus removing the dissolved contaminates from the water. Ultra pure water is used primarily for the generation of high pressure steam, but also has use in some processes. Cogeneration Cogeneration utilizes natural gas fired turbines and steam turbines for the production of electricity for use within and export from the Formosa Plastics Industrial park. Distribution of the electricity at either 15 kV or 69 kV is also managed by this group. As a function of the gas turbine operation, superheated steam at 1325 psig and 300 psig are generated using ultra pure water. The 1325 psig steam is used in the steam turbines for power production and "let-down" to 600 psig, 300 psig, and 150 psig for use in the Formosa Plastics Industrial Park for hea ting and power purposes. The superheated 300 psig steam generated by the HRSGs is consumed within the gas turbine combustion section for the control of compounds of NOx. Water Department Combined Water Treatment Plant (CWTP) The CWTP processes all process waste water and process area storm waters; prior to discharge to Lavaca Bay. This facility can be subdivided into four (4) treatment processes as follows: Biological Treatment: This treatment area processes all waters which contain organic compounds, those containing carbon, for the removal of these compounds to acceptable levels as designated by the TNRCC and EPA permits. This area utilizes acids, 5% hydrochloric, 60% sulfuric, and 93% sulfuric, and 20% caustic for pH adjustment. Polymers are added to the water to assist in the removal of suspended particulate. Additionally, purchased bacteria, in freeze dried state, are added to the process to insure contaminate destruction. Physical Treatment: This treatment area processes th ose waters which do not contain organic compounds such as demineralizer regeneration waters, Chlor/Alkali waste water and cooling tower blowdown. These waters only require pH adjustment and clarification prior to commingling with biologically treated water for discharge. This area utilizes acids, 5% hydrochloric, 60% sulfuric, and 93% sulfuric, and 20% caustic for pH adjustment. Polymers are added to the water to assist in the removal of suspended particulate. Sanitary Treatment: This treatment area processes those waters generated from toilets, showers, and kitchen areas WITHIN the Formosa Plastics Industrial Park. These waters are treated through the use of a standard package type sanitary treatment unit utilizing aerobic destruction, clarification, filtration, and chlorination. All waters exiting this treatment unit are recycled for reuse within the Formosa Plastics Industrial Park. Solids Handling: This treatment area processes the sludges, concentrated solids, removed from the r aw water and from the CWTP treatment processes. Solids are segregated by source of generation. This segregation produces a de-watered cake for disposal, which is transported to a Class II Non-Hazardous landfill. This treatment process utilizes polymers for separation of the suspended solids form the entrained waters. Hazards of the Process The NAICS code for the unit is 221320. The process uses and stores hydrochloric acid with concentration greater than 30%. The hazards associated with the chemicals used in the process requires the unit to comply with OSHA's Process Safety Management rule (29 CFR 1910.119); and Spill Prevention Control & Countermeasure program. The equipment installed in the unit was designed based on either ASTM or ASME standards. Before starting the unit, a process hazard analysis (PHA) as required by OSHA regulation 29 CFR 1910.119 was completed. The methodology used was Hazard and Operability method. Since the last PHA study, no additional mitigation systems hav e been installed. During the study, the PHA Team evaluated major hazards like, toxic gas release; fire; runaway reaction; over-pressurization and overfilling tanks, reactors, etc; contamination of the chemical; corrosion of pipes; equipment failure; and loss of cooling, heating, electricity and instrument air. Based on the hazards, the Team insured that there were adequate process controls like, check valves to insure that the chemicals do not flow back into equipment containing incompatible materials; manual shutoffs to prevent unwanted discharges; and alarms and procedures for the operator to take action in case of a process upset. In case there was an incident, the Team also evaluated the mitigation systems like, sprinkler systems to either dilute or keep below the explosion point of a gas release; and dikes to insure that the release does not spread and contaminate the surrounding ground. Vinyl Chloride Monomer Description of the Process The Formosa Plastics Vinyl plant loc ated at Point Comfort, Texas, produces vinyl chloride monomer (VCM). The process begins by producing 1,2 Dichloroethane (EDC). The EDC is produced by two processes. The first process is direct chlorination, where ethylene and chlorine are reacted together to form EDC. The other process is oxychlorination, which involves reacting ethylene with hydrogen chloride gas and oxygen. The EDC produced by these two processes is then thermally cracked to form VCM. The VCM is then sent to the PVC plant. Hazards o the Process The NAICS code for the unit is 32511. The process uses, stores or manufactures anhydrous ammonia, anhydrous hydrogen chloride gas and vinyl chloride. The hazards associated with the chemicals used in the process requires the unit to comply with OSHA's Process Safety Management rule (29 CFR 1910.119), NFPA 58 (Storage and handling of liquefied petroleum gases), OSHA's Storage and Handling of anhydrous ammonia (29 CFR 1910.111); Spill Prevention Control & Countermeasure progra m, and other applicable Resource Conservation & Recovery Act rule (RCRA). The equipment installed in the unit was designed based on appropriate standards that apply such as ASTM, or ASME and ANSI standards. A process hazard analysis (PHA) as required by OSHA regulation 29 CFR 1910.119 was completed. The methodology used was Hazard and Operability method. Since the last PHA study, additional process controls, process detection systems and perimeter monitoring systems have been installed. During the study, the PHA Team evaluated major hazards like, toxic gas release; fire; explosion; over-pressurization and overfilling tanks, reactors, etc; corrosion of pipes; equipment failure; loss of cooling, heating, electricity and instrument air; and natural disasters like floods, tornado and hurricanes. Based on the hazards, the Team insured that there were adequate process controls like, vents; relief valves and rupture disks to insure that holding vessels do not fail in case of overfilling or over-pressurization; check valves to insure that the chemicals do not flow back into equipment containing incompatible materials; manual/ automatic shutoffs and excess flow device to prevent unwanted discharges; alarms and procedures for the operator to take action in case of a process upset; interlocks to insure that the system shuts down in case of an emergency; emergency power supply for equipment to keep functioning until the system can been shut down during utility failure; and process area and perimeter detectors to warn the unit of a gas release allowing action to be taken to minimize effect. In case there was an incident, the Team also evaluated the mitigation systems like sprinkler system to either dilute or keep below the explosion point of a gas release; dikes to insure that the release does not spread and contaminate the surrounding ground; and blast walls to isolate explosions in one area. |