Equistar Chemicals, LP - Executive Summary |
|
Risk Management Plan Executive Summary Equistar Chemicals, LP Channelview, Texas Facility 1. Accidental Release Prevention and Emergency Response Policies Equistar is committed to employee, public and environmental safety. This commitment is inherent in a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at Equistar. Our policy includes implementation of appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also coordinated with Channel Industries Mutual Aid which provides additional emergency response expertise as needed. 2. The Stationary Source and the Regulated Substances Handled Petrochemical manufacturing activities at the Channelview Complex involve the f ollowing regulated substances: Flammables: 1,3-butadiene, 1,3-pentadiene, 1-butene, 1-pentene, 2,2-dimethylpropane, 2-butene, 2-butene-cis, 2-butene-trans, 2-methyl-1-butene, 2-methyl propene, 2-pentene (E), 2-pentene (Z), 3-methyl-1-butene, acetylene, butane, butene, ethane, ethyl acetylene, ethylene, hydrogen, isobutane, isopentane, isoprene, methane, pentane, propadiene, propane, propylene, and vinyl acetylene Toxics: ammonia (anhydrous and in solution), allyl alcohol, chlorine, chloroform, propylene oxide, and formaldehyde 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario Methodology given in the RMP Offsite Consequence Analysis Guidance by the EPA using tables and equations has been employed by Equistar to perform worst and alternative case release scenarios. The following paragraphs provide details of the chosen scenarios. The worst case r elease scenario submitted for Program 3 flammable substances as a class involves a catastrophic release of a liquid hydrocarbon mixture (containing three listed flammables: pentane, butane, and isopentane) from an olefins 2 unit feed tank (TK4903). The scenario involves the release of 26,600,000 pounds of the mixture. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of approximately 2.4 miles is obtained corresponding to an endpoint of 1-psi overpressure. The alternative release scenario submitted for Program 3 flammable substances involves a release from the propylene compressor section in the olefins 2 unit. The release is assumed to result from a broken line or valve failure on the fourth stage suction drum. The scenario involves the release of approximately 800,000 pounds of propylene in 10 minutes. No passive mitigation controls were taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance of approximately 0.5 miles is obtained corresponding to an endpoint of 1-psi overpressure. There are no RMP-listed toxic chemicals at the Channelview facility in quantities above the reporting threshold. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Equistar has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68. This facility was designed and constructed in accordance with NFPA-58 Standard, (1967 Edition). A number of processes at Equistar are subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program in place at Equistar. Process Safety Information Equistar maintains a record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Equistar conducts studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is referred to as a unit PHA. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated on an as needed basis. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting operations activities, Equistar maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved with the processes. Trai ning Equistar has a training program in place to ensure that employees that are operating processes are competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity Equistar carries out documented maintenance checks on process equipment to ensure proper functions. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified personnel carry out maintenance repair activities with previous training in maintenance practices. Furthermore, these personnel receive specialized training as needed. Equipment deficiencies identified through the mechanical integrity process are corrected in a safe and timely manner. Management of Change Written procedures are in place at Equistar to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Equistar. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Equistar conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and corrective actions required as a result of the audits are undert aken in a safe and prompt manner. Incident Investigation Equistar investigates any incident that has resulted in, or could reasonably result in, an employee injury or a catastrophic release of a hazardous material. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. Investigation reports are retained for a minimum of 5 years. Employee Participation Equistar believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation to the RMP rule in particular information resulting from process hazard analyses. Equistar is a member of the OSHA Voluntary Protection Program. As VPP Star Work Site, this facility has gone above and beyond the normal safety requirements to provide employees with a safe working environment. Contractors Equistar uses contractors to conduct specialized maintenance and construction activities on a regular basis. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Equistar has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History There have been no accidental releases of substances regulated by the RMP rule during the past five years that have had an adverse impact on the community. 6. Emergency Response Plan Equistar carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes many aspects of emergency response including adequate first ai d and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. Our emergency plan has been coordinated and verified with The North Channel Local Emergency Planning Committee (LEPC). Our emergency response equipment is regularly inspected and serviced. In addition, the emergency response plan is updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Improvements to the hydrocarbon detection system in critical areas are underway. Facility siting study findings are being implemented on a prioritized basis. |