Shell Chemical Company - Executive Summary

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The Shell Chemical Company facility at Deer Park, referred to as Shell Deer Park Chemical Plant (SDPCP), is a base chemicals manufacturing facility owned by Shell Chemical Company, part of the global Shell Chemicals Limited.  The facility is located on Highway 225 in Deer Park, Texas.  SDPCP sells base chemicals to other chemical companies that transform them into thousands of consumer products ranging from plastics to building materials.  About 900 full-time employees work at the site. 
 
Accidental Release Prevention and Emergency Response Policies 
 
SDPCP is committed to operating the plant in a manner that is safe for our workers, the public, and the environment.  It is our policy to adhere to all applicable Federal, State and local rules and regulations.  As part of this commitment, SDPCP has established a system to help ensure safe operation of the processes at this facility that includes the prevention of accidental releases of hazardous substances.  One component of this system is 
a risk management program (RMP) that provides the basis for managing risks at the site.  The RMP complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirement Risk Management Programs (the RMP rule), and Occupational Safety and Health Administration (OSHA) 1910.119.  This document is intended to satisfy the RMP plan requirement of the RMP rule and to provide the public with a description of the risk management program at the Shell Deer Park Chemical Plant. 
 
The Risk Management Program at the SDPCP consists of the following three elements: 
 
7 A hazard assessment to (a) help the facility and community understand the potential off-site consequences of hypothetical accidental releases and to (b) provide information to the public regarding accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances) 
 
7 A prevention program 
to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes) 
 
7 An emergency response program to help respond to accidental releases of regulated substances from covered processes 
 
Information further describing these elements is provided in this RMP Plan. 
 
Although the risk management program at the SDPCP helps ensure that the facility is maintained and operated in a safe manner, it is only one component of our safety and environmental programs.  In fact, SDPCP has a comprehensive safety and environmental program in place, establishing many levels of safeguards against release of a hazardous substance as well as injuries and damage from such a release. 
 
SDPCP policy on the use of hazardous substances: Before using a hazardous substance at the plant, less hazardous alternatives are considered.  When a hazardous substance needs to be used, plant personnel review the potential for an accidental release of this s 
ubstance that could adversely affect plant workers, the public and the environment, and takes steps to prevent any such effects.  This is accomplished through the facility's Management of Change (MOC) and Process Hazard Analysis (PHA) procedures that are followed for all new installations or modifications of existing processes. 
 
SDPCP strives to prevent accidental releases of the hazardous substances used at the facility by implementing reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used, the equipment is carefully designed, installed, operated and maintained to reduce the likelihood of an accidental release.  Industry and government standards are closely adhered to in the design, construction and operation of the equipment.  SDPCP also uses the Shell Corporate Engineering Guides and Standards (EGS) when designing new or modifying existing processes.  Each project is thoroughly reviewed before approval. In addition, the facili 
ty requires the documentation of standard operating procedures and training of affected employees with regard to these procedures as part of the MOC procedure.    The facility mechanical integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances. 
 
SDPCP'S goal is to minimize impacts from accidental release should they occur.  In the event of an accidental release, plant operators and emergency responders work together closely to control and contain the release in a manner that will be safe for workers and will minimize the impact to the public and the environment.  The facility maintains an active Emergency Response Team that is on call at all times to respond to accidental releases of any hazardous chemical handled at SDPCP.  In addition, SDPCP has a leadership role in Channel Industries Mutual Aid (CIMA).  This is a state chartered non-profit mutual-aid cooperative combining  
the fire fighting, rescue, hazardous material handling and emergency medical capabilities to its members in the Houston Ship Channel area. Along with the CIMA organization, the plant takes an active role in the local emergency planning committee for Deer Park.  The facility promotes the use of the CAER Phone Hotline number to inform citizens of any unusual plant event and actively works with the Deer Park Citizen's Advisory Council. 
 
A SDPCP Emergency Response Plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, and EPA regulations, as well as Shell's corporate guidelines.  This plan outlines the responsibilities and actions required to control an emergency within the boundaries of the facility.  If the emergency extends beyond or could potentially extend beyond the plant boundaries, the Deer Park Local Emergency Planning Committee (LEPC) is notified and a statement of the type of emergency and any community protection fac 
tors are recommended. 
 
To effectively implement these policies, SDPCP has established a management system lead by the Plant Manager with support from the Health and Safety (H&S) Department and the Environmental Department to oversee safety and environmental-related activities.  
 
2. Shell Deer Park Chemical Plant and Regulated Substances Handled (' 68.155(b)) 
 
Shell Deer Park Chemical Plant (SDPCP) is a base chemicals manufacturing facility owned by Shell Chemical Company, part of the global Shell Chemicals company.  The facility is located on Highway 225 in Deer Park, Texas.  SDPCP manufacturers and sells base chemicals to other chemical companies that transform them into thousands of consumer products ranging from plastics to building materials. 
 
The following RMP listed toxic and flammable chemicals are handled at SDPCP: 
 
7 Regulated Toxic Substances:  Methyl mercaptan, Epichlorohydrin, and Chlorine 
 
7 Regulated Flammable Substances:  1, 3-butadiene, 1,3-pentadiene, 1-butene, 1-pent 
ene, 2-butene-cis, 2-butene-trans, 2-methyl-1-butene, 2-pentene (E), 2-pentene (Z), 3-methyl-1-butene, ethane butane, ethylene, ethyl acetylene, hydrogen, isobutane, isoprene, isopentane, methane, propane, propylene, pentane,  
 
 
3.   The Worst-Case Release Scenario(s) and the Alternate Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario (' 68.155(c)) 
 
The facility performed off-site consequence analyses of accidental releases of regulated substances to estimate potential affects to the public or the environment.  The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario" and an "alternate release scenario".  SDPCP does not expect a worst-case release scenario to ever occur given the multiple levels of protection in place to prevent such a scenario.  The alternative release scenarios that have been developed are based on more likely potential accidental releases.  These  
have been shared with the Local Emergency Planning Committee (LEPC) to assist them in improving the community emergency response plan.   
 
SDPCP participated with local industry in delivering the risk management plan message to a broad-base of the community through industry open houses, speakers programs, newspaper stories and newspaper advertisements.  SDPCP continues to address RMP with the local emergency planning committees. 
 
Distances to toxic and flammable endpoints were calculated based on the EPA RMP Offsite Consequence Analysis Guidance.  The meteorological data used for the modeling was the EPA standard for the worst case scenario and EPA suggested values for the alternative release scenario. The Landview. III program was utilized to estimate the number of persons living within this distance from the location of the potential release point.  USGS maps were used to identify the public and environmental receptors located within this distance.  The following information summarize 
s the off-site consequence analysis performed by SDPCP: 
 
3.1 Methyl mercaptan - an RMP toxic chemical worst-case and alternate release scenario 
 
The "worst-case scenario" involving a toxic substance at this facility would involve the catastrophic failure of the methyl mercaptan storage tank.  This scenario assumes a maximum inventory of methyl mercaptan would be released and evaporates within a 10-minute period.  Under the EPA defined worst weather conditions, the methyl mercaptan gas cloud could potentially travel 6.7 miles before the concentration diminished below the ERPG-2 concentration of 25ppm.  No credit is taken for passive or active mitigation in the analysis. Potential public receptors include schools, residences, recreation areas, and industrial areas.  Environmental receptors within this distance include a state park. 
 
An "alternate release scenario" for methyl mercaptan involves a 1=-inch hole in the piping of the methyl mercaptan tank.  It is estimated that a normal inven 
tory of methyl mercaptan would be released over a 13-minute period.  Active mitigation accounted for in the analysis includes operator intervention to shut-off the pump and isolate the leak.  No credit is taken for passive mitigation.  Under the EPA alternate release weather conditions, the normal inventory of methyl mercaptan could potentially travel 0.8 miles before the concentration diminished below the ERPG-2 concentration of 25 ppm. Potential public receptors include schools, residences, and industrial areas. There are no environmental receptors within this distance from the release point. 
 
3.2 Epichlorohydrin - an RMP toxic chemical alternate release scenario 
 
An "alternate release scenario" for epichlorohydrin (ECH) involves the overfilling of the ECH tank.  It is estimated that a few barrels would be released over a 10-minute period.  Active mitigation accounted for in the analysis includes high level alarms, and operator intervention to shut-off the pump that stops the product 
spill. Credit is taken for passive mitigation (e.g. the dike walls).  Under the EPA alternate release weather conditions, the release could potentially travel 0.19 miles before the concentration diminished below the ERPG-2 concentration of 20ppm. There are no public receptors or environmental receptors within the area potentially affected by the spill. 
 
 
3.3 Chlorine - an RMP toxic chemical alternate release scenario 
 
An "alternate release scenario" for chlorine involves the failure of a =-inch transfer hose connected to a chlorine cylinder.  The expected amount discharged would be released over a 10-minute period.  Active mitigation accounted for in the analysis includes operator intervention to close the valve(s) and isolate the leak.  No credit is taken for passive mitigation.  Under the EPA alternate release weather conditions, the expected amount of chlorine discharged could potentially travel 0.1 mile before the concentration diminished below the ERPG-2 concentration of 3ppm. Th 
ere are no public or environmental receptors within this distance from the release point. 
 
 
3.4 1,3-Pentadiene - an RMP flammable chemical worst-case and alternate release scenario 
 
The "worst-case scenario" involving a flammable substance at this facility would involve the catastrophic failure of the 1,3-pentadiene storage tank.  This flammable substance release scenario assumes the entire contents of the tank is released and vaporizes to form a vapor cloud that subsequently ignites.  In this scenario, a pressure of 1-psi over normal atmospheric pressure is used as the endpoint for a vapor cloud explosion.  No credit is taken for active or passive mitigation. Under the EPA defined worst weather conditions, the 1,3-pentadiene explosion could potentially travel 1.7 miles before the pressure diminished below the 1-psi endpoint. Potential public receptors include schools, residences, and industrial areas. There are no environmental receptors within this distance from the release point. 
 

n "alternate release scenario" for 1,3-pentadiene involves the failure of a gasket in a tank truck loading line.  For this scenario, the gasket failure causes the leak of 1,3-pentadiene which flashes/pools, and is ignited, resulting in a pool fire.  The endpoint of 5 Kw/m2 for 40 seconds which can cause 2nd degree burns was used. Under the EPA alternate release weather conditions, the heat could potentially travel 341 feet to reach an adjacent off-site roadway; however, public receptors are not expected to be affected. There are no environmental receptors within this distance from the release point. 
 
 
4.  The General Accidental Release Prevention Program and the Specific Prevention Steps (' 68.155(d)) 
 
Under the EPA RMP criteria for establishing a prevention program, a Program 3 prevention program is required for all SDPCP covered processes.  A Program 3 prevention program is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environ 
ment beyond the plant's boundaries.  The following sections briefly describe the 12 elements of SDPCPlant's Program 3 prevention program that address EPA's RMP rule prevention program requirements. 
 
4.1    Process Safety Information  
SDPCP maintains technical documents that are used to help ensure safe operation of the plant processes. These documents address (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant and (3) design basis and configuration of the equipment at the plant.  The facility ensures that this process safety information is up-to-date and available to all employees.  Information pertaining to hazardous chemicals in the process is documented in the Material Safety Data Sheets (MSDSs).  The information available for each hazardous substance typically includes: 
7 Toxicity information and permissible exposure limits  
7 Physical data (e.g., boiling point, melting point, flash point)  
7 Reactivity and  
corrosivity data  
7 Thermal and chemical stability data  
7 Hazards of mixing substances in the process 
 
Information pertaining to the technology and equipment in the process is documented in design manuals, process description manuals, process flow diagrams, engineering drawings, and equipment files.  These documents are used to (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment.  The available information includes: 
7 Applicable design codes and standards 
7 Design basis and configuration of equipment 
7 Design basis for relief and ventilation systems 
7 Piping and instrumentation diagrams, including materials of construction 
7 Process chemistry 
7 Operating parameters 
7 Maximum intended inventories 
7 Safe upper and lower limits for parameters such as temperature, pressure, or flow 
7 Configuration of equipment 
7 Electrical classification 
7 Safety systems 
 
4.2    Process Hazard Analysis 
SDPCP performs and updates process hazard analyses (PHAs) of the  
covered process to help identify potential process hazards and generate considerations to improve the safe operation of the process.  PHAs are revalidated at least every five years by a team made up of individuals with engineering, and process operating experience.  One member of the team is knowledgeable in PHA methodology and serves to facilitate the PHA.  Potential hazards identified during the PHA are risk-ranked to ensure that highest priority is given to those having the highest consequence and likelihood of occurrence. After management review of the identified potential hazards and confirmation of proposed considerations, a written PHA report is prepared describing the results of the analysis.  Approved considerations are assigned and tracked to completion using a Mitigation Tracking System. 
 
4.3    Operating Procedures 
Operating procedures have been developed for each process area. Operating procedures are reviewed annually by unit operators and engineers and certified as being co 
rrect.  The procedures include steps for safe operation during all phases of operation, including initial startup, normal startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations, as applicable.  Within the operating procedures are: 
7 Steps for safely conducting work activities  
7 Applicable process safety information, such as safe operating limits and consequences of process deviations 
7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs 
 
4.4     Training 
SDPCP has implemented an effective training program to administer training activities.  The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) safety, health, and environmental topics, (3) process-specific training on the properties and hazards of the substances in the pro 
cess and (4) job-specific requirements.  This training is provided in both a classroom and on-the-job setting.  A combination of oral reviews and written tests are used to verify that an employee understands the training material. In addition, a training matrix has been prepared that defines the specific training courses required of each job function.  An electronic training management system, "TRIM", is utilized to ensure that employees receive the necessary training as defined by the training matrix. 
 
4.5    Mechanical Integrity 
SDPCP maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment.  Inspectors that have been qualified to API, AWS, and ASNT standards perform inspections and tests of mechanical equipment.  Qualified instrument and electrical technicians perform inspections and tests of instrumentation and electrical equipment.  The mechanical integrity program includes: 
(1) an administr 
ative procedure that defines the inspection and testing program 
(2) equipment inspection procedures that defines methods of inspection, acceptance criteria, and inspector qualifications 
(3) specific non-destructive inspection procedures 
(4) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes 
 
4.6    Management of Change 
SDPCP Management of Change procedure defines the requirements for review and approval of all proposed changes to chemicals, equipment, and procedures for processes to ensure that safety, health and environmental affects of changes are considered.  The Management of Change system ensures that the affected employees are notified of the changes, training is provided, and that process safety information and procedures are updated accordingly.  Plant personnel receive training on how to identify potential changes and the types of changes that are covered by the Management of Chang 
e procedure. 
 
4.7     Pre-startup Review 
SDPCP performs a Pre-startup Safety Review (PSSR) for all new/modified facilities,and facilities being restarted following a maintenance turnaround before they are put into service to help ensure that the process is safe to operate, procedures are in place, and affected personnel are adequately trained to operate or maintain the process.  Startup of the applicable process or equipment cannot commence until all Priority 1 issues identified by the Pre-startup Safety Review are complete, and the Production manager gives final authorization. 
 
Specific items that the PSSR confirms are: 
7 Construction and equipment are in accordance with design specifications 
7 Adequate safety, operating, maintenance, and emergency procedures are in place 
7 Management of Change (MOC) recommendations have been considered and completed as appropriate 
7 Affected employees are trained before they can be affected by the change 
 
4.8    Compliance Audit 
SDPCP conducts a self-audit 
of covered processes every 3 years to be certain that the prevention programs are effectively implemented at the plant.  Audit teams conduct internal audits of the prevention program.  These teams include people who are knowledgeable in the process and who have been trained in the auditing process.  The audit teams evaluate whether the prevention program satisfies the requirements of the PSM & RMP rules and whether the prevention program is effectively implemented.  The results of these audits are documented, recommendations are assigned to individuals to be resolved, and appropriate enhancements to the prevention program are implemented.  
 
4.9    Incident Investigation 
SDPCP investigates incidents, including near misses, that could reasonably have resulted in a serious injury to personnel, the public, or could have caused damage to the environment so that similar incidents can be prevented in the future.  The plant trains employees to identify and report any incident requiring investiga 
tion.  An investigation team is assembled, and the investigation is initiated within 48 hours of the incident.  The results of the investigation are documented, recommendations are assigned to people to be resolved, and appropriate process or system enhancements are implemented.  The facility has a formal program in place for reporting incidents, conducting incident investigations, report generation, and tracking of actions resulting from incidents.  
 
4.10    Employee Participation 
SDPCP has a written employee participation program for the facility to help ensure that the safety concerns of the plant's workers are addressed.  The facility encourages active participation of personnel in prevention program activities at the plant.  Some examples in which employees participate include development of prevention programs and documentation, process hazard analysis, development of operating procedures, development of alternate release scenarios, and incident investigations.  Employees are consul 
ted on and informed about all aspects of the RMP rule prevention program. 
 
4.11    Hot Work Permits 
SDPCP has a hot work permit program to control spark or flame-producing activities that could result in fires or explosions in all processes at the plant.  The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and developed a Hot Work Permit procedure to comply with these requirements.  Personnel who are to perform hot work are required to receive a Hot Work Permit.  Qualified individuals who issue hot work permits receive specialized training in the procedure and activities related to hot work.  Refresher training on hot work is required every three years. 
 
4.12    Contractors 
SDPCP has established a Contractor Safety Program to help ensure that contractors who perform work in the facility are competent and responsible.  SDPCP requires that contractors undergo a qualification process before being allowed to work at the facility. Contractors are required t 
o submit information regarding their safety, health, and environmental programs and performance.  This information is evaluated to ensure that the plant only hires contractors who can perform the desired job tasks in a safe and environmentally sound manner.  All contractor employees are required to take a Basic Safety and Hazard Communication course offered by the area contractors' safety council, followed by a plant orientation and test on the plant's safe work practices and emergency alarm system.  Area-specific orientations are given to contractor employees to ensure that they understand the hazards of the process on which they will work and the area emergency response procedures.  Depending on the type of work to be performed, contract personnel may be required to have additional training.  The plant conducts frequent evaluations of contractor performance.  All contractors must be re-qualified annually to continue working in the facility.  
 
5.   Five-year Accident History (' 68.155 
(e)) 
 
SDPCP experienced one incident in 1997 that had off-site impacts.  Citizens of nearby communities were asked, as a precautionary measure, to shelter-in-place, and a public road was closed for a time. 
 
 
6.  The Emergency Response Program (' 68.155(f)) 
 
The Shell Deer Park Chemical Plant maintains a written emergency response program to protect worker 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.  
 
All plant personnel are trained in the plant alarm system, sheltering 
-in-place, and evacuation procedures. 
 
The written emergency response plan complies with the following federal and state contingency plan regulations: 
7 OSHA 29 CFR 1910.38(a) - Employee Emergency Action Plans 
7 OSHA 29 CFR 1910.119 (n) - Process Safety Management of Highly Hazardous Chemicals 
7 OSHA 29 CFR 1910.120(p) and (q) - Hazardous Waste Operations and Emergency Response  
7 OSHA 29 CFR 1910, Subpart L - Fire Protection 
7 EPA 40 CFR 302.6 - Notification Requirements 
7 EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Plan 
7 EPA 40 CFR 355.40 - Emergency Planning and Release Notifications 
7 EPA 40 CFR 112 - Spill Prevention, Control and Countermeasures Plan 
7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention 
 
SDPCP maintains an emergency response team trained in the Emergency Response procedures, and is available around-the-clock to respond to in-plant chemical emergencies. The facility's offsite transportation response team is calle 
d the Response Action Team.  The team maintains a mobile hazardous materials vehicle with the necessary equipment to respond to chemical emergencies. In addition, SDPCP 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 chemical processes or other chemicl facilities.  The emergency response program is reviewed annually by all employees. 
 
The SDPCP emergency response program is coordinated with the Deer Park, Texas - 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.  SDPCP has 24 hour a day communications capability with appropriate LEPC officials, municipal emergency response o 
rganizations, and industrial mutual aid emergency response organizations.  SDPCP conducts periodic emergency drills that involve the Deer Park LEPC, local municipal fire departments, and the Channel Industries Mutual Aid Organization. 
 
7.  Planned Changes to Improve Safety (' 68.155(g)) 
 
SDPCP constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, process hazard analysis, joint union and management health and safety committee, and a program for soliciting health, safety and environmental suggestions from plant employees.  
 
8.   Certification (' 68.185) 
 
To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. 
Signed by J. D. Johnson*, Shell Deer Park Chemical Plant Manager, on June 21, 1999. 
 
*  The Certification with original signature is included with this RMP submittal.
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