Fina Bayport - Executive Summary

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RMP Submit Executive Summary 
 
Abstract 
The EPA's RMP regulation applies to the Fina Bayport Plant because of the quantities of titanium tetrachloride, butene, and isobutane we safely handle in the production of high density polyethylene (HDPE).  Long standing safety systems have enabled us to successfully manage the risks associated with these, and other potentially dangerous materials, with zero incidents where there has been an impact to the community or the environment outside the plant. 
 
Background 
The Fina Bayport HDPE plant is located in the Bayport industrial district in Pasadena, TX.  Fina has owned and operated the facility since purchasing the site in 1992.  The facility currently provides jobs for 133 fulltime Fina employees and approximately 100 fulltime contract employees.  The facility consists of two HDPE production units, Bay 1 and Bay 2.  Fina Bayport has maintained an outstanding safety record through a commitment to our operating philosophy. 
 
OUR OPERATING PHILOSOPHY 
 
In the complexity of the ever-changing business world in which we and our competitors operate, assessing the future is often quite difficult. 
 
There are, however, certain time-honored principles that do not change.  We the people of FINA, believe that come what may our Operating Philosophy provides us with a mechanism to successfully meet the challenges of the future. 
 
1. Safety              is number one in the workplace. 
2. Ecology            it is vital to quality of life and must be protected. 
3. Housekeeping  is necessary because clean plants are safe plants. 
4. Quality             is a key factor in satisfying customer needs. 
5. Service            is the foundation of good customer-supplier relations. 
6. Production       is essential.  We can not sell what we do not make. 
7. Cost                 is an important element in maintaining our competitive position. 
 
The people of FINA - Dedicated to producing products that best serve our customers' needs. 
 
Accidental Release Preventio 
n and Emergency Response Policy 
Safety in integrated into all activities of all employees working at the Fina Bayport HDPE plant.  As a member of the Chemical Manufactures Association (CMA) Fina Bayport is committed to the principles of Responsible Care.  Commitment to safety comes from top management, both on site and corporate.  This is demonstrated by both the site operating philosophy above and the corporate Health, Safety, and Environmental policy below. 
 
Fina and its subsidiaries shall conduct operations in a manner designed to protect the environment and the health and safety of its employees, neighbors, customers, and others who may be affected by Company operations of products, and shall comply with all applicable laws, regulations, and legal standards.  Each operating unit shall take all practical steps to eliminate employee exposure to accidental injury or to conditions adversely affecting their health while on the job and shall inform employees concerning off-the-job hazard 
s and ways to minimize such hazards.  Each operating unit will not knowingly engage in procedures which jeopardize or imperil employee or public health or which present undue hazards to the environment. 
 
In support of this policy, each operating unit will: 
 
1. Comply will all applicable laws, regulations, and legal standards and provide self-monitoring to ensure compliance. 
2. Provide employees with a safe and healthful voice. 
3. Design and operate facilities in a manner that optimizes the use of material and energy resources and minimizes, the extent feasible, any adverse impact on health and environment. 
4. Produce, market, and distribute only those products which, when properly used, will not pose an unreasonable risk to human health and the environment.  Communicate to employees, customers, and the public, as appropriate, the known hazards or products and operations. 
5. Communicate to employees, customers, and the public, as appropriate, the known hazards or products and operations 

6. Support and encourage programs and research efforts by trade associations and other organizations which promote good science and seek reasonable solutions to safety and environmental problems. 
 
One tool used to achieve the items of this policy is "Modern Safety Management". Modern Safety Management focuses on "loss prevention" and utilizes the International Safety Rating System (ISRS) as a mechanism of quantifying where an organization is in the process of implementing their risk management system.  Fina Bayport underwent a baseline audit of our risk management system in December of 1997.  In this audit we earned a rating of 7.  A rating this high places Fina Bayport in the top 5% of the thousands of organizations that have undergone such a baseline review.  More important than this prestigious compliment to the systems in place at Fina Bayport for managing risks is the success we have had in actual management of the risks.  As of June 1999, the Fina Bayport plant has gone 3 = yea 
rs with ZERO OSHA recordables, and has had ZERO accidental releases that have impacted the community or the environment outside the plant.  The commitment to the accidental release prevention and emergency response policy is best demonstrated by this success. 
 
Regulated Substances 
The EPA's RMP regulation applies to the Fina Bayport Plant because of the quantities of titanium tetrachloride, butene, and isobutane we safely handle in the production of high density polyethylene (HDPE).  Titanium tetrachloride is on the list of EPA toxic RMP materials and is used in the manufacturing of the catalyst used in our Bay 1 process.  Butene and isobutane are both on the RMP flammables list.  Butene is added to the HDPE polymer as a comonomer to control density.  Isobutane is used as a solvent in the Bay 2 process. 
 
Worst Case Release Scenario and Alternate Release Scenario 
The Worst Case Scenarios (WCS) and Alternate Release Scenarios (ARS) for the Fina Bayport RMP chemicals are summarized below. 
 The WCS's were calculated using EPA guidelines and EPA look-up tables.  The ARS's were chosen as "more likely" scenarios.  "More likely" does not make these Alternate Release Scenarios necessarily likely events, they are just scenarios that "could" occur given the physical properties of the specific materials.   Because the physical properties of butene and isobutane are identical as far as modeling for off site impact, the results of the two scenarios are combined in one summary.  The two scenarios are slightly different, these are also summarized below. 
 
Toxic (titanium tetrachloride) Worst Case Scenario: 
7 instantaneous failure of our 8000 gallon storage tank of titanium tetrachloride 
7 release entire contents (115,000 lbs) in 10 minutes 
7 low, stable wind 
7 endpoint distance of 3 miles 
 
Flammable (butene and isobutane) Worst Case Scenarios: 
7 instantaneous failure of our isobutane or butene storage tank 
7 release entire contents (222,000 lbs isobutane or 237,000 lbs butene) in  
10 minutes 
7 low, stable wind 
7 endpoint distance of 1/2 mile 
 
Toxic (titanium tetrachloride) Alternate Release Scenario: 
7 rupture of 3" loading line 
7 active and passive safety systems work 
7 emergency shutdown system isolates release 
7 weather conditions are normal 
7 total release of 6000 pounds 
7 endpoint distance of  = mile 
 
Flammable (butene and isobutane) Alternate Release Scenarios: 
7 butene - failure of a 4" unloading line, or 
7 isobutane - failure of Bay 2 reactor circulation pump seal 
7 active and passive safety systems work 
7 emergency shutdown system isolates release 
7 weather conditions are normal 
7 total release of 14,000 pounds butene or 134,000 pounds isobutane 
7 endpoint distance of = mile 
 
Accident Prevention Program 
The 14 elements of Process Safety Management (PSM) provide the cornerstone of Fina Bayport's accident prevention program.  We have been in full compliance with the elements of OSHA's PSM regulation since 1992.  The PSM regulation is applicable to our f 
acility because of the quantities of flammable materials we handle (hexane and isobutane).   
1. Employee Participation - all employees at Fina Bayport are involved in safety. 
2. Process Safety Information  (PSI) - PSI is current and available to all employees. 
3. Process Hazard Analysis (PHA) - A PHA has been conducted on each of our operating units.  The 5 year revalidation study of our Bay 1 process has just been performed. 
4. Operating Procedures - We have a complete and detailed set of written instructions to safely perform the steps required to operate the plant.  Fina Bayport is ISO 9000 certified. 
5. Training - Training is continuous.  Operators in the production units are trained and certified to safely perform their jobs. 
6. Contractors - The safety programs and performance of the contractors we choose to work in the plant are reviewed. 
7. Pre-Startup Safety Review - We have a system in place to ensure safety prior to putting new or modified systems into service. 
8. Mechanical 
Integrity - We have a program in place to ensure equipment is mechanically in good condition. 
9. Hot Work Permits - We have a system in place to ensure that work performed in the plant is done safely. 
10. Management of Change - We have a system in place to ensure that any changes to the process are wise and safe. 
11. Incident Investigation - We have a system in place where accidents or incidents, large or small, are thoroughly investigated to identify  and correct the root causes. 
12. Emergency Response - We have a well trained Emergency Response Team to handle an emergency if it does occur. 
13. Compliance Audits - We have a system in place to regularly audit our systems to make sure they are working. 
14. Trade Secrets - We have a system in place to ensure information related to process safety is made available to all employees and contractors. 
 
 
Five Year Accident History 
There have been no releases of RMP materials at the Fina Bayport HDPE Plant in the past five years that have impa 
cted the community, the environment, or in-plant personnel. 
 
Emergency Response Program 
Fina Bayport has been an active member of the Bay Area LEPC since purchasing the plant in 1992.  The planning effort of the LEPC helps ensure our emergency plan is coordinated with that of the local municipalities.  In addition, we are active members of Channel Industries Mutual Aid (CIMA), probably one of the best mutual aid organizations in the world.  The plant procedure on how emergency response is conducted is detailed in our emergency plan.  Our emergency plan outlines how to notify our neighbors if there were to be an event that could affect areas outside the plant.  Hands-on emergency response (fighting fire, controlling spills, providing medical attention, etc.) is performed by a well trained Emergency Response Team (ERT).  Periodic drills are conducted to refine both hands-on skills and the emergency plan itself. 
 
The entire plant is surrounded by an underground fire water header that will 
supply firewater from our 1.2 million gallon firewater storage tank.  In addition, our firewater is also tied into the fire water system of the neighboring plant. This serves both as a backup to our system and offers additional capacity of firewater if needed.  This fire water system supplies protection to numerous deluge systems, above ground fixed monitors, and hydrants.  The plant also has a 75' foam aerial fire truck and a smaller quick attack fire truck that can provide valuable assistance to the ERT if needed. 
 
 
Continuous Improvement 
Continuous improvement is an integral component of our risk management program.  We recognize that even the best system can be improved.  Our management systems seek to learn as much as possible from drills and any unusual incidents.  Within the past two years we have expanded the safety systems around our titanium tetrachloride storage tank and in our Bay 1 process where we have added additional capacity to detect the presence of flammable materia 
ls.  Construction of our Bay 2 plant was completed in December 1998 and was designed with state-of-the-art safety systems.  At our titanium tetrachloride storage tanks we have added a continuous monitoring system that will alarm the control room if even a small release of titanium tetrachloride is detected.  In addition, we have installed a system to apply a barrier fluid between any large spill and the moisture in the air.  It is the reaction between titanium tetrachloride and water in the air that forms hydrochloric acid that makes titanium tetrachloride a potentially hazardous material.  In both our Bay 1 and Bay 2 units we have numerous flammable material detectors installed that will both alarm the control room of a small leak or alarm the control room and activate the deluge system if a larger release is detected.
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