Equistar Chemicals, LP Clinton - Executive Summary |
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Executive Summary The Equistar Chemicals Clinton Barge Loading Facility consists of a hydrocarbon mixture storage tank and dike, an underground sump tank, three pumps, a flare, and truck and barge unloading/loading areas. The chemical handled at the facility is a hydrocarbon mixture called Debutanized Aromatic Compound or DAC. DAC contains the following regulated flamable substances: Butane, 1-Pentene, Pentane, and Propane. The facility has no full time employees, but is associated with the Equistar Chemicals Clinton Complex, which has a separate RMP. It is the policy of the Equistar Chemicals Clinton Complex to act responsibly in the prevention of accidental releases of highly hazardous chemicals. Appropriate emergency responses are in effect for dealing with the release of toxic and/or flammable chemicals. An Equistar Chemical Corporation RMP Policy has been created to provide a management system for implementing the Rule at covered corporate sites. The general accident al release prevention program for this site is the OSHA Process Safety Management Program, which has been implemented and is in effect. IN addition, operation and evergency response procedures were developed and are followed per Coast Guard regulations for the handling and loading of hazardous materials. The chemical-specific precaution steps for this facility primarily concentrates on the class of chemicals known as flammables. These steps are as follows: Measures to prevent the release of flammables are centered around complying with OSHA's Process Safety Management (PSM) requirements. Using the standards of OSHA PSM and American Petroleum Institute (API), flammables handlers have designed their equipment and procedures to minimize the risk of a release. Preventive measures that can be used to minimize risks are described below. First, there are some general preventive measures dictated by OSHA's PSM standards that are strictly followed to minimize the risk of releases. 1. A complete, in-depth process hazard analysis is completed every five years by qualified personnel as specified by OSHA's PSM standard. 2. Operating procedures are used for directing and training the operators who are requalified every three years. 3. Operators, maintenance, and contractor personnel working with or close to related equipment are trained and qualified to handle it safely. 4. All mechanical work plans are reviewed using critical-service work permits to assure the work is done properly. 5. All critical equipment is set up on a periodic inspection plan to assure proper operating condition. 6. Pre-startup reviews are held prior to starting new or modified equipment to insure that all conditions are satisfied for a safe operation 7. Engineers, operators and maintenance complete a safety checklist prior to making a change in equipment or significant operating condition. 8. Routine audits are conducted to assure safe practices are followed. 9. All incidents are investigated and actions are taken to prevent recurrence. Second, there are additional measures taken to reduce the risk of a release and consequences. 10. Flammable tank truck unloading is closely monitored. 11. Automatic shut-off valves for shutting down the unloading process can be activated by low unloading pressure, leak detection, and manually. One significant accidents has occured in the last five years at the Barge Loading Facility. A temporary storage tank used for cleaning the DAC tank caught fire. The Clinton Fire Department and assisted Equistar personnel in dealing with the incident. No deaths, injuries, hospitalizations, or other medical situations resulted from the incident. No off-site consequences were incurred. On site property damage amounted to approximately $18,200. The emergency response program may be described as follows: A central corporate policy exists with attachments as necessary to address the needs of the particular site. This poli cy generally conforms to the elements of the Emergency Response Procedure and has been communicated to the Local Emergency Planning Commission, Fire Department and Law Enforcement. The worst and alternate case release scenarios for this plant are listed below. Flammables Worst Case Scenario: The spill of the maximum contents of the DAC tank, 4,190,000 lbs of DAC into a diked area to form a pool with a surface area of 26,305 square feet. The DAC could vaporize at a rate of 1203 lbs/min to form a vapor cloud of 12,030 lbs in 10 minutes. The model used to predict the result is the TNT-equivalency method. The 1 psi overpressure radius would extend .18 miles. This release scenario would represent the greatest flammable substance worst-case release scenario held above the threshold quantity. It is predicted using "LandViewIII" software that residential population within the .18 mile radius is 26 people. The Upper Mississippi River Wildlife and Fish Refuge is the sensitive environme ntal receptor within this radius. A city park and several office buildings are also found inside the .18 mile radius. No other public receptors exist inside the radius. Passive mitigation efforts include an earth dike surrounding the ethylene storage tank. The alternate case scenario for the facility involves an 8-inch pipe shearing off near the bottom of the tank and alowing the contents of the tank to be emptied into the diked-in area. Essentially all of the contents of the tank would be released since there would be no feasable way to detect and stop the release when no employees are present. The resulting pool would have a surface area of 26,305 square feet. An ignition source would cause a pool fire which would have a radiant heat flux of 5 kW/m^2 at a distance of 0.13 miles. At this endpoint, a 40-second exposure could cause a second degree burn. The estimated residential population within this radius is 14 people. Several office buildings are also found inside the 0. 13-mile radius. Passive mitigation efforts include a polyethylene lined dike surrounding the DAC storage tank. PROCESSES COVERED BY THE RULE AT PROGRAM 2 The Equistar Chemical Corporation Clinton Barge Loading Facility has determined that the following processes are subject to Program 2: Storage and Barge and Truck Loading/Unloading of Flamable Hydrocarbon Mixture. CERTIFICATION Program 2 Process Certification Based on the criteria in 40 CFR 68.10, to the best of the signer's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. 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