Shell Chemical Company - Executive Summary |
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17631 LDEQ FACILITY ID NUMBER RISK MANAGEMENT PLAN SHELL CHEMICAL COMPANY GEISMAR, ASCENSION PARISH, LA 1. EXECUTIVE SUMMARY The Shell Chemical Company is committed to operating in a manner that is safe for Shell Chemical Company workers, the public, and the environment. As part of this commitment, Shell Chemical Company has established systems to ensure safe operation of the facility. One part of this system is the Risk Management Program (RMP) that complies with the Environmental Protection Agency's regulation 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a Risk Management Plan (RMPlan) describing the risk management program at Shell Chemical Company. This document is intended to satisfy the RMPlan requirements and to provide the public with a description of the risk management program at Shell Chemical Company in Geismar, LA. The dates provided for Prevention Program items in RMP Submit will generally be either 6/21/99 (RMP due date) or blank. The reason for this is that although these process safety programs have been active under Process Safety Management (PSM), they have not been required under RMP until the 6/21/99 submittal and compliance date. Therefore, placing any data in these fields that is before the RMP compliance date would not represent RMP compliance activities but activities that were performed for PSM compliance only. Programs will be fully functional under RMP and PSM as of the 6/21/99 compliance date. 1.1 Accidental Release Prevention and Emergency Response Shell Chemical Company implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, our trained personnel respond to control and contain such releases as appropriate. Each situation is evaluated individually and appropriate measures are taken to protect the employees and the community. Shell C hemical Company, the Local Emergency Planning Committee (LEPC), and neighboring industry have established a program to warn the community if an accident occurs that could threaten the community. A local siren warning system is in place and tested routinely. 1.2 The Shell Chemical Company and Regulated Substances Shell Chemical Company handles many substances regulated by the RMP rule in sufficient quantities to be covered by the RMP rule. The information below indicates the processes as defined by the rule and the regulated substances therein: - AOID-1&2 - Alpha and internal olefin production - Program 3: 1-butene, 2-butene-cis, 2-butene-trans, ethane, methane, ethylene, 1-pentene, propylene, and chlorine. - EOEG - Ethylene oxide and ethylene glycol production - Program 3: methane, ethylene, and ethylene oxide. - K-2/3/4 - Detergent range alcohol production - Program 1: Hydrogen. - PDO-1 - 1,3-propanediol production - Program 3: Acetaldehyde, hydrogen, methane, and ethylen e oxide. - PK-1 - Polyketones production - Program 3: Propylene and ethylene - Utilities Chlorine and Ammonia - Chlorine and ammonia used in water treatment processes in the Utilities system - Program 3: Ammonia and chlorine 1.3 Offsite Consequence Analysis Shell Chemical Company performed an offsite consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. The OCA consists of evaluating both worst-case scenarios (WCSs) and alternative release scenarios (ARSs). Shell Chemical Company does not expect a worst case scenario to ever occur. An ARS represents a release that might occur during the lifetime of the facility like Shell Chemical Company. ARSs help the LEPC improve the community response plan. Below is a summary of the WCSs and ARSs for the Shell Chemical Geismar facility. - Worst Case (Program 3 processes) Toxics / Ethylene Oxide: 375,000 lb EO storage vessel - gas release - (adm inistrative controls limit maximum inventory to 75% capacity). - Worst Case (Program 3 processes) Flammables / 1-butene: 870,000 lb Butene storage vessel - vapor cloud explosion - Worst Case (Program 1 process) Flammable / Hydrogen: 11,600 lb Hydrogen mixture in a reactor - vapor cloud explosion - Alternative Release (Program 3 processes) Toxics / Ethylene Oxide: 8,830 lb EO storage vessel vent valve - gas release - Alternative Release (Program 3 processes) Toxics / Ammonia: 8,020 lb Ammonia loading vent line left open - gas release - Alternative Release (Program 3 processes) Toxics / Chlorine: 1,520 lb Chlorine cylinder fusible plug failure - gas release - Alternative Release (Program 3 processes) Flammables / 1-butene: 150,000 lb Butene storage vessel - boiling liquid expanding vapor explosion (BLEVE) The EO worst-case scenario radius of potential impact includes residential areas, institutions and neighboring industrial plants. All other cases, worst and altern ate, do not encompass any residential areas or institutions in their potential radius of impact. For these scenarios, only other industrial sites are impacted. Radii of potential impact for all release scenarios were determined using guidance in the RMP rule and the lookup tables from the EPA's RMP Offsite Consequence Analysis Guidance document, dated May 24, 1996. 1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps The following is a summary of the general accident prevention program in place for the Program 3 processes at the Shell Chemical Company Geismar Plant. Because the processes at the Shell Chemical plant that are regulated by the EPA RMP rule are also subject to the Process Safety Management (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 the dates provided in the RMPlan represent the compliance dates for each e lement under RMP, not the compliance dates for the element under PSM. Therefore, the dates that are identified or not supplied for various elements are reported that way because until June 21, 1999, many of these prevention program pieces were not in place under RMP requirements). Process Safety Information The Shell Chemical Company keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments and individuals in the plant are assigned responsibility for maintaining up-to-date process safety information. A database summarizing the data elements of process safety information, the responsible party, and their location is maintained by the HSEGT Process Safety Committee. This is available to employees as part of the written employee par ticipation plan to help employees locate any necessary process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in the Material Safety Data Sheets (MSDSs). Process Hazard Analysis The Shell Chemical Company Geismar Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each covered process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Geismar plant primarily uses the hazard and operability (HAZOP) technique to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. They ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, Shell Chemical Geismar periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at the specified frequency until the process ceases to operate. The results and fi ndings from these updates are documented and retained. Again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures The Shell Chemical Geismar plant maintains written procedures that address various modes of process operation such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and maintained current by revising them as necessary to reflect changes made through the Management of Change process. Training To complement the written procedures for process operations, Shell Chemical Geismar has implemented a training program for all employees involved in operating a process. To be qualified to perform a particula r job, the Technician must complete the training for that job. Initial and refresher training records for each employee involved in operating a covered process are maintained in the Shell Training and Recordkeeping System (TRIM), which is maintained by the Training Section of the Human Resources Department. Contract employees are not involved in operating covered processes. Training records include the name of the employee and the date of the training. Where applicable, copies of tests and other means used to verify that the employee understood the training are maintained. The training places an emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the job. Contractors The Shell Chemical Company uses contractors regularly and to supplement the workforce during periods of high activity. Because some contractors work on or near process equipment, Shell Chemical Company has procedures in place to ensure contractors have the proper knowledge of and training on plant systems, procedures, and processes before they go to work at the site. Safety performance constitutes a major factor in the overall evaluation of contractor performance and Shell performs periodic evaluations of contractor compliance with Shell and regulatory requirements. Pre-startup Safety Reviews (PSSR) Shell Chemical Company conducts a PSSR for any new facility or facility modification that requires a change in process safety information. In addition, all major projects, major turnarounds, and minor turnarounds require a PSSR to be performed. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment in service. This review provides one additional check to make sure construction is in accordance with design specifications and that all supporting systems are operationally ready. The PSSR review team creat es an Expected State of Readiness Document, which is used to verify all aspects of the organization's readiness. Mechanical Integrity The Shell Chemical Company has well-established practices and procedures to maintain the integrity of pressure vessels and storage tanks, piping systems, relief and vent systems, controls, pumps, and emergency shutdown systems. The basic aspects of the mechanical integrity program include (1) training for process maintenance activities, (2) inspection and testing of process equipment, (3) correction of identified equipment deficiencies as appropriate, and (4) quality assurance in construction, installation and spare parts. Maintenance personnel are knowledgeable of the safety and health hazards of the work areas, applicable maintenance procedures, emergency response plans, and applicable safe work practices to help ensure they can perform their job in a safe manner. Inspection and tests are performed to help ensure that process equipment function s as intended, and to verify that this 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 in service, or the Mechanical Equipment Team (MET) or the Pressure Systems Team (PST) will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Safe Work Practices Shell Chemical Company has long-standing safe work practices in place to help ensure worker and process safety. Examples include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for the safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that a dequate precautions are in place before entry into a confined space. These procedures (and others), along with the training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Shell Chemical Company has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), 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, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessar y training on the change. Incident Investigation Shell Chemical Company promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, significant toxic gas release, major property damage, environmental loss, or personal injury. 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 Shell Chemical Company management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. 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 for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Shell Chemical Company conducts an audit to determine whether the procedures and practices required by the accident prevention program are in place. Compliance audits are conducted at least every three years. Both hourly and management personnel participate as audit team members. The HSEGT Process Safety Committee membership is responsible for developing and conducting these audits in conjunction with the tri-annual Process Safety Management prevention program (PSM) audits required by OSHA on the same frequency. The audit team develops findings that are forwarded to Shell Chemical Company 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 re ports are maintained. Chemical-specific Prevention Steps The processes at Shell Chemical Company have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all Program 3 EPA RMP covered processes at the plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. In addition to the accident prevention program activities, the Shell Chemical Company has safety features on many units 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 in various processes: Release Detection - Stationary ethylene oxide monitors with alarms - Process alarms - Personal exposure monitors Release Containment/Control - Process relief valves that discharge to a flare to capture and incinerate episodic releases - Scrubbers to neutralize/minimize 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) - Curbing or diking to contain liquid releases - Redundant equipment and instrumentation (e.g., uninterruptable power supply for process control systems, backup firewater pump) - Atmospheric relief devices designed for safe dispersion of chemicals Release mitigation - Fire suppression and extinguishing systems - Deluge system for specific equipment - Trained emergency response personnel on-site at all times - Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) - Blast-resistant buildings to help protect personnel and control systems 1.5 Five Year Accident History The Shell Chemical Company Geismar Plant maintains a five-year accident history that fulfills the requirements of the RMP Rule. This history indicates a good record of accidental release prevention over the past five years. No releases of regulated substances have occurred from Shell Chemical Company Geismar within the last five years that have resulted in off-site consequences. The following incidents at the plant within the last five years did result in on-site property damage. - A release of hydrocarbon gases (including hydrogen) from a piping failure in the K units resulted in a fire on 12/16/97. The release was isolated and the fire brought under control with no personnel injuries, environmental damage, or offsite protective measures being necessary. There was, however, significant on-site property damage to equipment, which makes this event an RMP reportable incident. 1.6 Emergency Response Program The Shell Chemical Company Geismar plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a re gulated 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 exposure, 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 Shell Chemical Company has procedures that address maintenance, inspection, and testing of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to the Shell Chemical Company plant processes or other plant facilities. The emergency response program changes are administered through the management of change process, which includes informing and/or tra ining affected personnel in the changes. The overall emergency response program for the Shell Chemical Company Geismar plant is coordinated with the Ascension parish LEPC. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Shell Chemical Company has around the clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., local fire department). There is also a community siren warning system for public notification of a significant event. These systems provide a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, Shell Chemical Company conducts periodic emergency drills that involve the LEPC and emergency response organizations. 1.7 Planned Changes to Improve Safety Shell Chemical Company Geismar plant strives to improve the safety of plant processes through periodic safety reviews, the incident investigation program, proactive safety campaigns, and a safety meeting system for soliciting feedback from employees. Shell Chemical Company resolves all findings from PHAs, some of which result in modification to the process. NMS - 5/24/1999 |