Equistar Chemicals, LP Clinton Plant - Executive Summary |
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Executive Summary 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. The Clinton Complex has the following facilities that are covered by this Rule: High Density and Low Density Polyethylene production, and Ethylene production areas. An Equistar Chemical Corporation RMP Policy has been created to provide a management system for implementing the Rule at covered corporate sites. The toxic substances handled in those areas may be as follows: Ammonia (conc. 20% or greater) and Vinyl acetate monomer. The flammable substances handled in those areas may be as follows: 1,3-Butadiene, Butane, Ethane, Ethylene, Hydrogen, Isobutane, Isopentane, Pentane, Propane, and Propylene. The general accidental release prevention program for this site is the OSHA Process Safety Managemen t Program, which has been implemented and is in effect. Auxiliary programs such as Spill Prevention Control and Countermeasures and Stormwater Pollution Prevention Plan are in place and effective. The Spill Prevention Control and Countermeasures procedure establishes the proper course of action in the event of the discharge of a hazardous substance or oil. Additionally, preventive measures and precautions pertaining to specific hazardous substances handled and stored at Equistar are described. 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 comp lete 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 accidental releases and consequences. 10. Flammable tank car unloading is closely monitored. In some cases, gas detection alarms are used and will quickly identify a leak. 11. Automatic shut-off valves for shutting down the unloading process can be activated by low unloading pressure, leak detection, and manually from different plant locations. 12. Flammable unloading station can be isolated from other operations to reduce exposure to any fires or other accidents. 13. Water deluge systems can be used to displace flammable gas vapors if a leak should occur. Also water deluge systems are used to cool vessels and pipelines during a fire situation. 14. Critical pro cesses can be computer controlled to ensure continuous monitoring of all operating parameters and immediate shutdown of the production units. 15. Flammable gases are stored under two types of conditions. One is under high pressure at ambient temperature and the other is low-pressure low temperature. High-pressure tanks are constructed with up to one inch thick steel walls. The low-pressure tanks use refrigeration to store the product. Both types of tanks are 100% inspected by X-ray before going into service. All tanks, both high- and low-pressure, are on timetables to come out of service and be fully re-inspected. 16. Flammable gas sensors are located strategically in the plant to provide advance warning of even low levels of flammable gases in the air. 17. Emergency systems are designed to quickly control leaks in tanks and pipelines. 18. Safety relief valves are installed on tanks and pipelines to protect them from over pressure. 19. Flares are used, in a first line d efense, to burn off excess product in a high-pressure situation before the relief valves vent the product to the air, except in cases where the extremely cold temperature generated would produce metallurgic changes threatening structural integrity. The past five years have not included any significant accidents on or off site for the Clinton Complex. 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. The elements of the local plant Emergency Response Procedure have been communicated to the Local Emergency Planning Commission, Fire Department and Law Enforcement. The following are some of the process changes that are planned to improve safety at the Equistar Chemicals Clinton site: -Install concrete curbing and properly designed sump in py gas loading area to prevent spills. -Tie routinely used atmospheric vents in the tank farm into the flare header. -Re-d irect a vent valve outlet to prevent impingement of exhausted gas or steam on any equipment or manifold in the area. -Connect a suction drum drain lines to the normal-butyl acrylate waste tank to eliminate risk of exposure or discharge of normal-butyl acrylate to the atmosphere. The worst and alternate case release scenarios for this plant are listed below. Toxic Worst Case and Alternative Case Scenarios: Liquid spill and vaporization of 394,000 pounds of Vinyl Acetate Monomer from the largest VA storage tank associated with this plant. The material would form a pool of liquid within the existing dike structure. The liquid would then evaporate at a rate of 1170 lbs/min. The distance to the toxic endpoint of this spill would be 4 miles. Rural conditions with an atmosphere of class F stability and a wind speed of 1.5 m/s were used to estimate the endpoint. Using "LandViewIII" software it is estimated that 3,851 people could be within the 4 mile radius. Passive mitigation efforts include an earth dike surrounding the tanks. An alternative release case for this tank uses an atmosphere of class D stability and a wind speed of 3.0 m/s. This would result in an evaporation rate of 2000 lbs/min, and a toxic endpoint of 1.2 miles. Alternative Case Scenario for Ammonia: Liquid spill and vaporization of 30,000 pounds of 28% nominal Aqueous Ammonia Solution. The ammonia would form a pool within the existing concrete pit. The liquid would then eveporate at a rate of 19 lbs per minute assuming atmospheric stability class D and a wind speed of 3.0 meters per second. The distance to the toxic endpoint would be less than 0.1 miles. The residential poplutaion affected by the release was estimated using "LandViewIII" software. The estimated population within the 0.1-mile radius is 2 people. Flammable Worst Case: Instantaneous and total release of 2,330,000 pounds fo a flammable C-4 mixture, liquified under pressure, from the largest storage tank associated with thi s material. The material is assumed to vaporize completely and then to detonate. Ten percent of the vapor is assumed to be involved in the explosion. the model used to predict the result is the TNT-equivalency method. the 1-psi overpressure radius would extend 1.1 miles. This release scenario would represent the greatest flammable substance worst case release scenario of a substance held above the threshold quantity. It is predicted using "LandViewIII" software that the residential population within the 1.1-mile radius would be approximately 253 people. This radius also includes a major industrial area. Flammables Aternate Case: An alternate case release scenario would involve a six-inch line breaking from the tank. There would be no feasable way to stop the release before the contents of the tank were expelled. For the atternate case scenario however, it is assumed that only 3 percent of the gas released is involved in the vapor cloud explosion. the model used to predict t he result is the TNT-equivalency method. the 1-psi overpressure radius would extend .65 miles. This release scenario would represent the greatest flammable substance alternate release scenario of a substance held above the threshold quantity. It is predicted using "LandViewIII" software that the residential poplulation affected by this radus would be 148 people. This radius also includes a major industrial area. PROCESSES COVERED BY THE RULE AT PROGRAM 3 The Equistar Chemical Corporation Clinton Complex has determined that the following processes are subject to Program 3: Low Density and High Density Polyethylene production, and Ethylene production. CERTIFICATION Program 3 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. Signature_____________________________Title___________________Date________ |