Borden Chemicals and Plastics, OLP - Geismar - Executive Summary |
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RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1138 LDEQ Facility ID Number Borden Chemicals and Plastics Operating Limited Partnership (BCP) owns and operates a chemical manufacturing plant in Geismar, Louisiana. As required by 40 CFR 68.155, BCP is including with the Risk Management Plan Submission the following Executive Summary. Accidental Release Prevention and Emergency Response Policies BCP has a long-standing commitment to protection of the health and safety of its employees and the general public. It is BCP policy to provide the safest workplace possible for our employees while also minimizing to the fullest extent practical any impact on the neighboring community, which includes striving to eliminate accidental releases. This commitment is demonstrated by the resources invested in accident prevention, such as emphasizing safety in the design, installation, operation, and maintenance of our processes; providing proper training to personnel; having up-to-date operating proc edures; and implementing an effective maintenance and mechanical integrity program. Our policy is to implement appropriate controls to minimize the potential for releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release in order to minimize to the fullest extent any possible impact on the neighboring community. Stationary Source and Regulated Substances The BCP facility is located in Sections 3, 49, and 50 of Township 9 South, Range 2 East and Section 11 of Township 10 South, Range 2 East in Ascension Parish. The site is approximately 22 miles southeast of Baton Rouge, Louisiana at the intersection of Louisiana Highways 73 and 30 near the rural town of Geismar, LA. The BCP facility has been in operation since 1961. The BCP complex has plants which produce acetylene, anhydrous ammonia, ethylene dichloride, formaldehyde, anhydrous hydrogen chloride, industrial gases (carbon monoxide and hydrogen), methan ol, polyvinyl chloride, urea, urea-formaldehyde concentrate, vinyl chloride, and air separation products (oxygen, nitrogen, and argon). BCP also produces steam and electricity for internal consumption by cogeneration. The plant uses or produces the following RMP regulated substances in quantities above the threshold quantities listed in 40 CFR 68.130: Toxics: Ammonia, chlorine, formaldehyde and hydrogen chloride Flammables: Hydrogen, propylene, vinyl chloride, and methane Worst-case and Alternative Release Scenarios NOTE: BCP has numerous controls to minimize the potential for releases and to manage their consequences, however, as required by rule, no credit for administrative controls or passive mitigation measures was taken into account in evaluating worst-case scenarios for toxic or flammable substances. Toxic Worst Case Scenario The worst case scenario (WCS) associated with toxic substances at the plant is a catastrophic failure of the 130-ton chlorine storage vess el, resulting in a release of the entire contents over a ten-minute period. The maximum distance to the toxic endpoint of 0.0087 milligram per liter of chlorine for this WCS is 16.0 miles as determined by using EPA's RMPComp modeling program. The potential population impact by such a release was determined to be 217,000 based on MAPInfo program using 1990 census blocks. Due to the sizeable area potentially impacted, all of the noted public receptors are included (schools, residences, hospitals, prisons/correction facilities, recreation areas, and major commercial, office, and industrial areas). Toxic Alternative Case Scenarios As noted in the prior section, BCP has four chemicals that meet the criteria for inclusion in the RMP as toxics. The chemicals are ammonia, chlorine, formaldehyde, and hydrogen chloride. The alternative release scenario (ARS) for ammonia is a two-hour release of ammonia through a leaking flange near the bottom of a large ammonia storage tank. The quant ity released is assumed to be 36,200 pounds (or 302 pounds per minute release rate). The maximum distance to the toxic endpoint of 0.14 milligram per liter of ammonia for this ARS is 0.2 miles as determined by RMPComp. Though this scenario does reach off-site, there are no public receptors located within the modeled area of concern. The alternative release scenario (ARS) for chlorine is a 5-minute release through a pressure relief valve located on the chlorine storage tank. The quantity released is assumed to be 875 pounds (or 175 pounds per minute release rate). The maximum distance to the toxic endpoint of 0.0087 milligram per liter of chlorine for this ARS is 0.3 miles as determined by RMPComp. While this scenario also reaches off-site, there are no public receptors located within the modeled area of concern. The alternative release scenario (ARS) for formaldehyde is a 2-minute release through a rupture disc failure on an outlet reactor bank header. The quantity released is assumed to be 264 pounds (or 132 pounds per minute release rate). The maximum distance to the toxic endpoint of 0.012 milligram per liter of formaldehyde for this ARS is 0.6 miles as determined by RMPComp. This scenario's area of concern does impact on one public receptor (major industrial area - a nearby petrochemical plant), but does not impact on any residences, schools, hospitals, or recreational areas. The alternative release scenario (ARS) for hydrogen chloride is a 5-minute release through a pressure relief valve located on a process vessel. The quantity released is assumed to be 2700 pounds (or 540 pounds per minute release rate). The maximum distance to the toxic endpoint of 0.030 milligram per liter of hydrogen chloride for this ARS is 0.9 miles as determined by RMPComp. The potential population impact by such a release was determined to be 12 based on an enumeration of houses and dwellings within the 0.9-mile area of concern. In addition to residences, a major commerci al and industrial area is also potentially impacted. Note that there are no schools, hospitals, prisons/correction facilities, or recreation areas within this area of concern. Flammable Worst Case Scenario The flammable worst case scenario (WCS) associated with a release of flammable substances at the plant is a vapor cloud explosion (VCE) involving the full inventory of two co-located vinyl chloride storage spheres. Both spheres are considered because of their proximity to each other, and represent the largest quantity of Vinyl Chloride stored or involved in a process. No administrative controls are considered in place to limit the storage inventory in the tank; therefore, the full tank inventories of approximately 6,660,000 pounds is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is 1.1 miles as determined by RMPComp. The potential population impact by such an event was determined to be 204 based on an enumeration of houses and dwellings within the 1.1-mile area of concern. In addition to residences, a major commercial and industrial area and a recreational area are also potentially impacted. Note that there are no schools, hospitals or prisons/correction facilities within this area of concern. Flammable Alternative Case Scenario The ARS for flammable substances at the plant is a VCE resulting from a release of the entire contents of two co-located vinyl chloride spheres. The difference between the worst case scenario and the alternative case scenario is more favorable meteorological conditions than were used for the worst case, and that a lesser portion of the contents contribute to the VCE. The maximum distance to the 1-psi endpoint for this ARS is 0.5 miles as determined by RMPComp. This scenario's area of concern does impact on one public receptor (major industrial area - nearby petrochemical plant), but does not impact on any residences, schools, hospitals, or rec reational areas. Accidental Release Prevention Program and Chemical Specific Prevention Steps The following is a summary of the general accident prevention programs in place at BCP's Geismar facility. Because the processes at the plant regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Please note that due to time constraints, BCP addressed the request for the "last date" on which a particular activity was completed by entering the most recent date for completion of that respective activity as of the final version of that section of this report. Employee Participation BCP employees participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees are involved in the writing of procedures and development of the training materials that accompany them. Employees have access to all information created as part of the plant accident prevention program. Specific ways that employees are involved in the process safety management program are documented in an employee participation plan that is maintained at the plant and addresses each process safety program element. In addition, the plant has a number of initiatives under way that addresses process safety and employee safety issues. Teams made up of employees and contractors meet on a regular basis to review and develop safety procedures, training programs, emergency response procedures, investigate process safety related incidents and report to the plant management safety team. Process Safety Information BCP has a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information. Employees have been advised of the location of the process safety information and trained in how to use the information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known hazards such as those associated with the inadvertent mixing of chemicals. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Anal ysis (PHA) BCP has a comprehensive program to ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify potential process safety hazards and ensure that adequate controls are in place to manage these hazards. The facility primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted by a team comprised of individuals who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures. Suggestions for additional prevention and/or mitigation measures are made when the team finds such measures are necessary. To ensure that the process controls and/or process hazards do not eventually deviate sig nificantly from the original design safety features, BCP updates and revalidates the hazard analysis results at least once every five years for the life of the process. The results and findings from these updates are documented and forwarded to management for consideration, and the final resolution is documented and retained. Operating Procedures BCP maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) shutdown, and (4) initial startup of a new process. Temporary and emergency operating procedures are developed for each case prior to commencement of the operation. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. Procedures are reviewed annually. Training BCP has implemented a com prehensive training program for all employees involved in operating a process. New employees receive basic training in both safety issues and plant operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After an operator demonstrates (e.g., through tests, skills demonstration) adequate knowledge to perform the duties and tasks in a safe manner, the operator can work independently. In addition, all operators receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least once every three years. All training is documented for each operator, including, the means used to verify that the operator comprehended the training. Contractors BCP routinely employs contractors to work on or near process equipment. Additional contractor work force is present during periods of increase d maintenance or construction activities. Contractors are provided both plant-wide and unit-specific training using computer based training programs. The program includes a written test that requires an 80% passing score. In addition, craftsmen must complete the eight-hour safety-training program for industrial workers provided by industry through the local safety council. The training is maintained through annual refresher training. The long-term contractors participate along with Borden Chemicals and Plastics employees as members of the safety teams tasked with the development of procedures, audits, accident investigation and training. Additionally, Borden Chemicals and Plastics also provides monthly safety training for the contractor supervision. In addition to the safety training, procedures are in place to ensure that contractors perform their work in a safe manner; have the appropriate knowledge and skills; are aware of the hazards in their workplace; understand what they should do in the event of an emergency; understand and follow site safety rules; and inform plant personnel of any hazards that they find. Each contractor employee is provided with a process overview and information about safety and health hazards, emergency response plan requirements, and safe work practices prior to beginning work. BCP evaluates contractor safety programs and performance during the contractor selection process. Plant personnel monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSR's) BCP conducts a Pre-Startup Safety Review (PSSR) for any new facility or major facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that necessary training, safety features, procedures, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construc tion is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity BCP has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service, as appropriate, or Management will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment until the actions are completed. Another integral part of the mechanical integrity program is quality assurance. BCP incorporates quality assurance measures (e.g., purchasing spe cifications and inspection procedures) into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices BCP has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (2) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (3) a permit and procedure to control spark-producing activities (i.e., hot work), and (4) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change BCP has a comprehensive system to mana ge changes to processes. This system requires that changes to items such as process equipment, chemicals, procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, and equipment information, as well as procedures and drawings are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. The management of change program is designed to allow anyone in the system, operations or maintenance, the ability to initiate a MOC. Employees have been trained concerning the various elements that would constitute a change such as parts, procedures, operating conditions, etc. The change form provides an abbreviated version of the pre-startup review. Management of the documents and approval to proceed are controlled at the department level. Incident Investigation BCP promptly investigates all process safety related incidents. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. When necessary, short-term interim measures are taken until the permanent fix is implemented. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained on file for at least five years to supplement the haz ard analysis records for the affected areas, and are reviewed during PHA's and PHA revalidations. A team of employees are permanently tasked with identifying opportunities to improve the investigation system for the over all benefit of BCP and associated industries. Compliance Audits To help ensure that the process safety program is functioning properly, BCP periodically undergoes an audit to determine whether the procedures and practices required are being implemented. Compliance audits are conducted at least every three years. Both hourly and management personnel participate in the audits. The audit team develops findings that are forwarded to the plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained on file. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at BCP have hazards that must be ma naged to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and/or human errors. In addition to the accident prevention program activities, BCP has safety features to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used where appropriate: Release Detection -- Hydrocarbon detectors with alarms Release Containment/Control -- Process relief valves that discharge to a flare to capture and incinerate episodic releases -- Scrubber to neutralize chemical releases -- Valves to permit isolation of the process (manual or automated) -- Automated shutdown systems for specific process parameters (e.g., high level, high temperature) -- Vessel to perm it partial removal of the process inventory in the event of a release (e.g., dump tank) -- Curbing or diking to contain liquid releases -- Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) -- Atmospheric relief devices Release Mitigation -- Fire suppression and extinguishing systems -- Deluge systems for specific equipment -- Trained emergency response personnel -- Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) Five-year Accident History There have been four accidents which meet the criteria established under RMP that have occurred at BCP's Geismar facility during the past five years. A synopsis of each accident is listed below: 1) August 22, 1996 - An overpressure situation in the Vinyl Chloride Monomer via Ethylene (VCM-E) plant resulted in a release of vinyl chloride and hydrogen chloride. The hydrogen chloride mixed with permitted emissions of ammoni a forming an ammonium chloride cloud that drifted over a local highway. There is litigation related to this incident due to a minor traffic accident that allegedly resulted due to the limited visibility associated with the haze. Though there was an alleged off-site impact due to the car accident, there were no deaths, evacuations, shelter-in-place or environmental damage associated with the release. There is also litigation related to this incident based on alleged exposure by parties that were not present in the haze nor downwind of the incident. 2) July 7, 1997 - A plant-wide power outage occurred as a result of a lightning strike to the facility's main electrical substation. Releases of ammonia and vinyl chloride were encountered as a result of the power outage. As a precautionary measure, the Local Emergency Planning Commission (Ascension Parish Sheriff's Office) sounded the community sirens to alert the citizenry to the releases. There is litigation related to this incident based on alleged exposure by parties that were not downwind of the incident. There were no deaths, evacuations, shelter-in-place or environmental damage associated with the release. 3) December 12, 1997 - A fire in process equipment in the VCM-E plant resulted in the release of hydrogen chloride. Two contractors at BCP were treated and released at a local hospital. There was an alleged impact at a different chemical facility located approximately eight miles away at a location that has been determined to be east of the downwind path of the release. Several individuals at this facility went to a local hospital for observation and were released. There were no hospitalizations associated with this release. There is litigation related to this incident based on alleged exposure by parties that were not downwind of the incident. In addition, there were no deaths, evacuations, shelter-in-place or environmental damage on-site or off-site associated with the release. 4) July 2, 1998 - A flash fire occurred during maintenance activity in BCP's Ammonia plant. The fire occurred during maintenance on a hydrogen line. Four individuals received burns with one individual requiring hospitalization. In addition, there were no deaths, evacuations, shelter-in-place or environmental damage on-site or off-site associated with the release. BCP investigates every incident that meets RMP criteria very carefully to determine ways to minimize the potential for similar incidents from occurring in the future. While our goal is to eliminate the occurrence of such events, BCP recognizes that they may occur and therefore we also work to ensure proper response to minimize and mitigate any potential impact on our employees and the neighboring community. Emergency Response Program BCP's Geismar facility maintains a written emergency response program to protect workers and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is reviewed annually and updated when necessary based on modifications made to plant processes or other plant facilities. Emergency response program changes are administered such that informing an d/or training affected personnel is accomplished prior to implementation of the change. The overall emergency response program for the Geismar facility is coordinated with the Geismar Area Mutual Aid (GAMA) network which is comprised of local industries and the Ascension Parish Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Geismar facility has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response. In addition to periodic GAMA meetings, the Geismar facility conducts periodic emergency drills. Planned Changes to Improve Safety The Geismar facility addresses each recommendation resulting from process hazard analyses . Some recommendations result in modifications to the process. The following types of changes are planned: Revision of personnel training programs. Reviewing instrumentation schemes. Addition of chemical release detection systems. Improve HazMat supply's and personnel protection. Revise facility-wide core safety procedures. Revise accident investigation program and provide investigation training. Upgrading Emergency Communication systems and procedures both on and off-site. |