Borden Chemicals and Plastics, OLP - Illiopolis - Executive Summary |
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RISK MANAGEMENT PLAN EXECUTIVE SUMMARY Borden Chemicals and Plastics Operating Limited Partnership (BCP) owns and operates a chemical manufacturing plant in Illiopolis, Illinois. As required by 40 CFR 68.155, BCP is including with the Risk Management Plan Submission the following Executive Summary. Accidental Release Prevention and Emergency Response Policies BCP has a long-standing commitment to protection of the health and safety of its employees and the general public. It is BCP policy to provide the safest workplace possible for our employees while also minimizing to the fullest extent practical any impact on the neighboring community, which includes striving to eliminate accidental releases. This commitment is demonstrated by the resources invested in accident prevention, such as emphasizing safety in the design, installation, operation, and maintenance of our processes; providing proper training to personnel; having up-to-date operating procedures; and implementing an effe ctive maintenance and mechanical integrity program. Our policy is to implement appropriate controls to minimize the potential for releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release in order to minimize to the fullest extent any possible impact on the neighboring community. Stationary Source and Regulated Substances BCP's Illiopolis, IL facility is located just west of the township of Illiopolis, IL in Sangamon County at Cantrell Road and Old Route 36. There are no residential dwellings located in the immediate vicinity of the facility. The facility has been in operation since the early 1950's. The facility is a manufacturer of polyvinyl chloride. The plant uses or produces only one RMP regulated flammable and one regulated toxic substance in quantities above the threshold quantities listed in 40 CFR 68.130. The regulated RMP listed flammable is vinyl chloride. The regulated RMP listed to xic is vinyl acetate. Worst-case and Alternative Release Scenarios NOTE: BCP has numerous controls to minimize the potential for releases and to manage their consequences, however, as required by rule, no credit for administrative controls or passive mitigation measures was taken into account in evaluating worst-case scenarios for vinyl chloride and vinyl acetate. Toxic Worst Case Scenario The worst case scenario (WCS) associated with the regulated toxic substance at the plant is a catastrophic failure of the largest storage vessel for vinyl acetate, resulting in a release of the entire contents (199,606 pounds) over a ten-minute period. The maximum distance to the toxic endpoint of 75 ppm of vinyl acetate for this WCS is 1.01 miles as determined by using the Process Hazard Analysis Software Tools (PHAST) modeling program. The potential population impact by such a release was determined to be 328 based on an enumeration of houses and dwellings within the 1.01-mile area of con cern. Note that there are no schools, hospitals, recreation areas, prisons/correction facilities, or major commercial and industrial facilities within this area of concern. Toxic Alternative Case Scenarios The alternative release scenario (ARS) for vinyl acetate is a reactor relief valve lifting due to an overpressure situation. The quantity released is assumed to be 7,646 pounds. The maximum distance to the toxic endpoint of 75 ppm of vinyl acetate for this ARS is 0.646 miles as determined by PHAST. The potential population impact by such a release was determined to be 16 based on an enumeration of houses and dwellings within the 0.646-mile area of concern. Note that there are no schools, hospitals, recreation areas, prisons/correction facilities, or major commercial and industrial facilities within this area of concern. Flammable Worst Case Scenario There are two worst case scenarios (WCS) for the storage of vinyl chloride. The first WCS associated with a release of flammab le substances at the plant is a vapor cloud explosion (VCE) involving the full inventory of the largest vinyl chloride storage sphere. No administrative controls are considered in place to limit the storage inventory in the vessels; therefore, the full inventory of approximately 305,000 gallons (2,309,680 pounds) is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is 0.08 miles as determined by the Multi-Energy modeling program. The second worst case scenario is the release of the total contents of a rail car of vinyl chloride stored on a rail spur that results in a vapor cloud explosion (VCE). No administrative controls are considered in place; therefore, the full inventory of approximately 196,891 pounds is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is 0.03 miles as determined by the Multi-Energy modeling program. This scenario's area of concern does not impact on any residences, schools, hospitals, recreational areas, prisons or correctional facilities, or major commercial or industrial facilities. Flammable Alternative Case Scenario The alternative release scenario (ARS) for flammable substances at the plant is a VCE resulting from a relief valve lifting from a process reactor vessel due to an overpressure situation. The quantity released is assumed to be 40,480 pounds. The maximum distance to the lower flammability limit of 3.6% of vinyl chloride for this ARS is 0.01 miles as determined by the Multi-Energy model. This scenario's area of concern does not impact on any residences, schools, hospitals, or recreational areas but does potentially impact a neighboring industrial facility. Accidental Release Prevention Program and Chemical Specific Prevention Steps The following is a summary of the general accident prevention programs in place at BCP's Illiopolis facility. Because the processes at the plant regulated by the EPA RMP regulation are also subject to the OSHA 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 due to time constraints, BCP addressed the request for the "last date" on which a particular activity was completed by entering the most recent date for completion of that respective activity as of the final version of that section of this report. Employee Participation BCP employees participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees are involved in the writing of procedures and development of the training materials that accompany them. Employees have access to all information created as part of the plant accid ent prevention program. Specific ways that employees are involved in the process safety management program are documented in an employee participation plan that is maintained at the plant and addresses each process safety program element. In addition, the plant has a number of initiatives under way that addresses process safety and employee safety issues. Teams made up of employees and contractors meet on a regular basis to review and develop safety procedures, training programs, emergency response procedures, investigate process safety related incidents and report to the plant management safety team. Process Safety Information BCP has a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date proce ss safety information. Employees have been advised of the location of the process safety information and trained in how to use the information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known hazards such as those associated with the inadvertent mixing of chemicals. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) BCP has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify potential proc ess safety hazards and ensure that adequate controls are in place to manage these hazards. The facility primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. A team comprised of individuals who have operating and maintenance experience as well as engineering expertise conducts the analyses. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures. Suggestions for additional prevention and/or mitigation measures are made when the team finds such measures are necessary. To ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, BCP updates and revalidates the hazard analysis results at least once every five years for the life of the process. The results and findings from these updates are documented and forwarded to management for consideration, and the final resolution is documented and retained. Operating Procedures BCP maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) shutdown, and (4) initial startup of a new process. Temporary and emergency operating procedures are developed for each case prior to commencement of the operation. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. Procedures are reviewed annually. Training BCP has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in both safety issues and plant operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After an operator demonstrates (e.g., through tests, skills demonstration) adequate knowledge to perform the duties and tasks in a safe manner, the operator can work independently. In addition, all operators receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least once every three years. All training is documented for each operator, including, the means used to verify that the operator comprehended the training. Contractors BCP routinely employs contractors to work on or near process equipment. Additional contractor work force is present during periods of increased maintenance or construction activities. Contractors are provided both plant-wide and unit-specific training using computer based training programs. The program includes a written test that requires an 80% passing score. In addi tion, craftsmen must complete the eight-hour safety-training program for industrial workers provided by industry through the local safety council. The training is maintained through annual refresher training. The long-term contractors participate along with Borden Chemicals and Plastics employees as members of the safety teams tasked with the development of procedures, audits, accident investigation and training. Additionally, Borden Chemicals and Plastics also provides monthly safety training for the contractor supervision. In addition to the safety training, procedures are in place to ensure that contractors perform their work in a safe manner; have the appropriate knowledge and skills; are aware of the hazards in their workplace; understand what they should do in the event of an emergency; understand and follow site safety rules; and inform plant personnel of any hazards that they find. Each contractor employee is provided with a process overview and information about safety a nd health hazards, emergency response plan requirements, and safe work practices prior to beginning work. BCP evaluates contractor safety programs and performance during the contractor selection process. Plant personnel monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSR's) BCP conducts a Pre-Startup Safety Review (PSSR) for any new facility or major facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that necessary training, safety features, procedures, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the con struction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity BCP has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe m anner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that 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 into service, as appropriate, or Management will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment until the actions are completed. Another integral part of the mechanical integrity program is quality assurance. BCP incorporates quality assurance measures (e.g., purchasing specifications and inspection procedures) into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Wor k Practices BCP has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (2) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (3) a permit and procedure to control spark-producing activities (i.e., hot work), and (4) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change BCP has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology, procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes a re 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, and equipment information, as well as procedures and drawings are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. The management of change program is designed to allow anyone in the system, operations or maintenance, the ability to initiate a MOC. Employees have been trained concerning the various elements that would constitute a change such as parts, procedures, operating conditions, etc. The change form provides an abbreviated version of the pre-startup review. Management of the documents and approval to proceed are controlled at the department level. Incident Investigation BCP promptly investigates all process safety related incidents. The goal of each investigation is to determine t he 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 plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. When necessary, short-term interim measures are taken until the permanent fix is implemented. 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 on file for at least five years to supplement the hazard analysis records for the affected areas, and are reviewed during PHA's and PHA revalidations. A team of employees are permanently tasked with identifying opportunities to improve the investigation system for the o ver all benefit of BCP and associated industries. Compliance Audits To help ensure that the process safety program is functioning properly, BCP periodically undergoes an audit to determine whether the procedures and practices required are being implemented. Compliance audits are conducted at least every three years. Both hourly and management personnel participate in the audits. The audit team develops findings that are forwarded to the 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 reports are retained on file. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at BCP have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the facility. Collectively, these prevention program activities help preve nt potential accident scenarios that could be caused by equipment failures and/or human errors. In addition to the accident prevention program activities, BCP has safety features 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 where appropriate: Release Detection -- Hydrocarbon detectors with alarms Release Containment/Control -- Process relief valves that discharge to a flare to capture and incinerate episodic 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., uninterruptible power supply for process control system, backup firewater pump) -- Atmospheric relief devices Release Mitigation -- Fire suppression and extinguishing systems -- D eluge systems for specific equipment -- Trained emergency response personnel -- Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) Five-year Accident History There have been no accidents over the past five years that meet the criteria established under 40 CFR 68 criteria. If an incident meeting RMP criteria were to occur, BCP would investigate each incident very carefully to determine ways to minimize the potential for similar incidents from occurring in the future. While our goal is to eliminate the occurrence of such events, BCP recognizes that they may occur and therefore we also work to ensure proper response to minimize and mitigate any potential impact on our employees and the neighboring community. Emergency Response Program BCP's Illiopolis facility maintains a written emergency response program to protect workers and public safety as well as the environment. The program consists of procedures for responding to a release o f 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. In addition, the plant has procedures that address maintenance, inspection and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is reviewed annually and updated when necessary based on modifications made to plant processes or other plant facilities. Emergency response program changes are administered such that informing and/or training affected personnel is accomplished prior to implementation of the change. The overall emergency response program for the Illiopolis facility is coordinated with the Local Emergency Planning Committee (LEPC), the local Sheriff's office, the local fire department and area hospitals. In addition to periodic meetings, the Illiopolis facility conducts periodic emergency drills. Planned Changes to Improve Safety The Illiopolis facility addresses each recommendation resulting from process hazard analyses. Some recommendations result in modifications to the process. The following types of changes are planned: Revision of personnel training programs Reviewing instrumentation schemes Improve HazMat supply's and personnel protection Revise facility-wide core safety procedures. Revise accident investigation program and provide investigation training. Upgrading Emergency Communication systems and procedures both on and off-site. |