Lyondell Chemical R&D Facility - Executive Summary |
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Lyondell Chemical Company Research & Development Facility Newtown Square, Pa. EPA RMPlan Executive Summary INTRODUCTION: SITE HISTORY Lyondell is one of the world's largest chemical companies. The Lyondell enterprise is comprised of the former ARCO Chemical Company, acquired by Lyondell in 1998. Lyondell also has major ownership positions in Equistar Chemicals, Lyondell-Citgo Refining and Lyondell Methanol Company. In total, Lyondell operates in 15 countries and has approximately 11,000 employees worldwide. The Newtown Square Research & Development (R&D) Facility was opened by Atlantic Richfield Company in 1980. Since then, the Newtown Square facility has operated as a research and development center for ARCO Chemical Company (ACC). Beginning in 1987, the site also became ACC's world-wide corporate headquarters. In July of 1998, Lyondell Chemical Company purchased ARCO Chemical Company and is in the process of relocating its corporate headquarters to Houston. The site is and will continue to serve as the primary R&D location for Lyondell Chemical Company. 1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Lyondell Newtown Square R&D Facility is committed to operating and maintaining all of our laboratories and processes in a safe and responsible manner. We have implemented a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public, as well as to protect the environment. These programs are designed to meet or exceed governmental requirements such as the Environmental Protection Agency's (EPA) Risk Management Program (RMP) rule (40 CFR Part 68) and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 CFR Part 1910.119). This document is intended to satisfy the RMP Plan requirements of the RMP rule and to provide the public with a description of the risk managem ent program at the facility. 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility is not a manufacturing site. The Lyondell Chemical Company R&D Facility operates laboratory and pilot plant operations designed to support company manufacturing sites as well as develop new processes. Processes supported include propylene oxide and it's derivatives. In our research and development processes, we use the following chemicals that the EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release: Toxics The Lyondell R&D facility stores and handles only one chemical in quantities exceeding the EPA defined threshold quantity: propylene oxide. The Polyols Pilot Plant uses propylene oxide to prepare experimental samples of intermediate urethane chemicals. Propylene oxide is used as a reaction component to make polyols which Lyondell's customers use to make foam seating and mattresses, sneaker soles, coatings, adhesives, sealants, elastomers and other consumer products. Flammables The Lyondell Chemical Company R&D Facility does not handle or store any listed flammables in excess of the threshold quantity. Management systems are in place to ensure that the site optimizes the amount of chemicals on site by: * ordering chemicals in minimum quantities * maintaining accurate inventory records and sharing chemicals between different users in order to avoid duplicate inventories * designing projects to minimize sample sizes * working with vendors to provide "just in time" delivery. 3.0 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS RMP PROGRAM LEVEL The Lyondell Chemical Company Newtown Square Research and Development Facility is classified as a Program 1 Process under the EPA's Risk Management Program rule 40 CFR 68. Program 1 Process designation indicates that although the site handles and uses a listed chemical above the threshold quantity, the distance to endpoint f or the worst case accidental release scenario is less than the distance to the nearest public receptor. Additionally, the process has not had any accidental releases in the past five years resulting in an on-site death, injury, or property damage; or an off-site death, injury, evacuation, shelter-in-place, property damage, or environmental damage as outlined in the risk management program rule (40 CFR 68.10 (b)(1)). Lyondell Newtown Square performed off-site consequence analyses to estimate the potential for an accidental release of a regulated substance that may affect the public or the environment. The USEPA - RMP Offsite Consequence Analysis Guidance Document (OCA Guidance), dated May 24 1996, was utilized. EPA Off-Site Consequence Analysis (OCA) Guidance Tables were used for evaluating the worst case scenarios and alternative release scenarios for flammable and toxic materials. The following is a brief summary of the worst case scenario for the only covered chemical at our site, propylene oxide. Key administrative controls and mitigation measures implemented to limit the exposure distances are included with the scenario description. Worst-Case Release Scenario - Regulated Toxic Chemical : Propylene Oxide The propylene oxide worst case scenario assumes 'instantaneous' failure of a Polyol Pilot Plant propylene oxide tank. When full, the tank holds 2600 pounds of propylene oxide. The tank contents would be contained within a concrete dike area with a vapor release resulting from the evaporation of the liquid pool within the dike. The release and corresponding distance to endpoint (derived from EPA method) remains within the site fence line and does not affect any public receptors. The following 'Passive Mitigation' measure was used in this analysis: * Concrete Dike: the concrete, secondary containment dike contains the propylene oxide release and minimizes propylene oxide evaporation to the atmosphere. Active Mitigation: By de finition, the worst case analysis does not allow credit to be taken for active mitigation systems. However, the Polyols Pilot Plant has in place many layers of protection designed to prevent and if necessary, detect and respond to any spills or leaks of propylene oxide. These active controls include but are not limited to the presence of OSHA PSM certified operators during all operating hours, the design and use of multiple automatic shutdown systems (that have been confirmed to be Y2K compliant) and the presence of automatic leak detection and fire suppression systems throughout the complex. In addition to the active mitigation systems described above, we maintain: * emergency responders and emergency management organization members on 24 hr. call * integrated process control and alarm systems to alert operating personnel in the process area and central security * highly-trained emergency management personnel * fire-safety officers that are trained as Emergency Medic al Technicians * more than adequate supply of emergency and spill response equipment Worst-Case Release Scenario(s) - Regulated Flammable Chemicals The Newtown Square R&D facility does not use or store any listed flammable chemicals in excess of the threshold quantity. Even though we do not use or store any listed flammable chemicals in excess of the threshold quantity, each process area in which listed chemicals are used and stored was evaluated. This information is used to help ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 4.0 ACCIDENTAL RELEASE PREVENTION PROGRAM The Newtown Square R&D facility maintains programs to help prevent accidental releases and ensure safe operation. These individual elements of our prevention program collectively help prevent accidental chemical releases. The accident prevention programs in place include, but are not limited to: * Written Safety Policies and P rocedures * Employee Training and Qualification Programs * Safety Reviews that use hazard evaluation methodologies for all new projects * Operational changes to existing processes that are evaluated using risk assessment and hazard evaluation methods. * Experiments and pilot process units that are designed and built with appropriate levels of safety redundancy, reflecting the hazards present. These include such things as equipment interlocks and automatic emergency shutdown systems. * Incident / accident reporting and investigation procedures. * Employee 'near miss' event reporting / resolution system. * Regular housekeeping and safety inspections that are conducted for all operating areas. 5.0 FIVE - YEAR ACCIDENT HISTORY The site has not had any releases which resulted in an on-site death, injury, or serious property damage; or an off-site death, injury, evacuation, shelter-in-place, property damage, or environmental damage during the past five years. In fa ct, since we opened this facility, in 1980, we have not had any chemical releases with off site consequences. 6.0 EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program, referred to as the 'Comprehensive Emergency Management Plan' or CEMP, provides the essential planning and training for effectively protecting the workers, the public, and the environment during emergency situations. Lyondell Newtown Square management coordinates our plan with the community emergency response plan through the Director of Emergency Services, County of Delaware, Pennsylvania. Other community organizations with whom we share and coordinate the emergency plan are: * Newtown Square Volunteer Fire Company * Newtown Township Manger * Newtown Township Supervisors 7.0 PLANNED CHANGES TO IMPROVE SAFETY As a member of the Chemical Manufacturers As sociation, Lyondell Chemical supports a continuing effort to improve the industry's responsible management of chemicals. It is a policy of Lyondell (and formerly of ACC) to strive for continuous improvement in performance in the areas of environmental, health, and safety. For the Newtown Square site, the primary means for continuous improvement is a program of corporate Technical Center Standards, which consists of rigorous performance requirements in the areas of Process safety, Occupational Safety and Health, Environmental Compliance and Incident and Emergency Management. These standards reflect the requirements of a R&D operating environment and help ensure superior performance and continuous improvement. A system of audits to measure performance against these standards with resulting recommendations and follow up actions are in place to assure continuous improvement in safely managing our operations, safety and health performance, environmental compliance and incid ent / emergency response capabilities. 8.0 CERTIFICATIONS [Certification executed with cover letter accompanying this RMPlan submittal.] Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst- case accidental release scenario for the following process is less than the distance to the nearest public receptor: * Polyols Pilot Plant Within the past five years, the process has had no accidental release that caused offsite impacts provided in the risk management program rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process, entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMP. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. _________________________ Charles W. Ruoff, Facility Manager June 21, 1999 9.0 RMP DATA ELEMENTS Additional information about our risk management program that EPA's RMP rule has asked us to provide is included as requested in the attached data file. |