PD Glycol - Executive Summary
Risk Management Plan Executive Summary |
1. Accidental Release Prevention and Emergency Response Policies
PD Glycol is committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at PD Glycol. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release. The Plant's Emergency Response Team is reinforced with Personnel from the Beaumont Fire Department if needed. We are also coordinated with The Sabine Neches Chiefs Association Mutual Aid which provides additional emergency response expertise.
2. The Stationary Source and the Regulated Substance
PD Glycol's primary activities encompass ethylene oxide which is converted into ethylene glycol. We manufacture or utilize four (4) regulated substances at PD Glycol; ethylene oxide, ethylene, chlorine, and methane.
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario.
Methodology given in the RMP Offsite Consequence Analysis Guidance by the EPA using tables and equations has been employed by PD Glycol to perform worst and alternative case release scenarios. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastropic release from the chlorine storage at the cooling tower of the ethylene glycol manufacturing process. The scenario involves the release of 2,000 pounds of chlorine. It is assumed that the entire quantity is releas
ed as a vapor. Under worst case weather conditions, the maximum distance of approximately 1.3 miles is obtained corresponding to an endpoint of 0.0087 mg/l.
The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastropic release from a failure of a cycle gas rupture disk in the ethylene oxide manufacturing process. The scenario involves the release of 16,000 pounds of 50-50% ethylene methane mix. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of approximately 0.23 miles is obtained corresponding to an endpoint of 1 psi overpressure.
The alternative release scenario submitted for Program 3 toxic substances involves a release of ethylene oxide from a reabsorption column in the ethylene oxide manufacturing process. The release is assumed to be an upset of the reab
sorber column due to overpressure. The scenario involves the release of approximately 8,610 pounds of ethylene oxide in 10 minutes. Passive mitigation controls such as firewater monitors are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance of approximately 0.99 miles is obtained corresponding to a toxic endpoint of 0.09 mg/l.
The second alternative release scenario for a Program 3 toxic substance involves a relelasee of Chlorine from a chlorine cylinder due to a failure at the Glycol Unit cooling tower. The scenario involves the release of approximately 730 pounds of chloring in 10 minutes. Passive mitigation controls such as firewater monitors are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance of approximately 0.20 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/l.
The alternative release scenario submitted for Program 3 flammable substances involves a rel
ease of ethylene in the ethylene oxide manufacturing process. The release is assumed to result from a broken valve at a flow control station. The scenario involves the release of approximately 2,330 pounds of ethylene in 10 minutes. Passive mitigation controls such as sprinkler systems, vapor detectors, and dikes are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance of approximately 0.06 miles is obtained corresponding to an endpoint of 1 psi overpressure.
4. The General Accidental Release Prevention Program and the Chemical Specific Prevention Steps.
PD Glycol has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68. This facility was designed and constructed in accordance with NFPA-58 Standard, (1967 Edition). Two processes at PD Glycol are subject to the OSHA PSM standard under 29 CFR 1910.119.
The following sections briefly describe the elements of the rellease p
revention program in place at PD Glycol.
Process Safety Information
PD Glycol maintains a record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. This information is readily available to all employees including contractors.
Process Hazard Analysis
PD Glycol conducts studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analysis is referred to as a unit PHA. A complete, in-depth process hazard analysis is completed every five years by qualified personnel with expertise in engineering and process operations as specified by OSHA's PSM standard. Any finding related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting operations activities, PD Glycol maintains written operating procedures. These procedures address various modes of operation s
uch as initial startup, normal operations, temporary operations, normal shutdown, and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the process.
PD Glycol has a trainig program in place to ensure that employees that are operating processes are competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at lease every three years and more frequently as needed.
PD Glycol carries out documented maintenance checks on process equipmet to ensure proper functions. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance is carried out by qualified personnel w
ith previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at PD Glycol to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.
Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at PD Glycol. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
PD Glycol conducts audits on a regular basis to d
etermine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at lease every 3 years and corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
PD Glycol investigates any incident that has resulted in, or could reasonably result in, an employee injury or a catastropic release of a hazardous material. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. Investigation reports are retained for aminimum of 5 years.
PD Glycol believes that process safety management and accident prevention is a team effort. All employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation to
the RMP rule in particular information resulting from process hazard analysis.
PD Glycol is a member of the OSHA Voluntary Protection Program. As a VPP Star Work Site, this facility has gone above and beyond the normal safety requirements to provide employees with a safe working environment.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. PD Glycol has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of the procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-year Accident History
PD Glycol has an excellent record of preventing accidental releases over the last 5 years. Due to our release prevention policies, there has been two accidental release
s of substances regulated by the RMP rule during this period. One incident occurred on September 22, 1995 when an operator was checking a compressor knock-out pot spilled approximately one pound of an ethylene oxide-water solution on the employee's foot. There were no off-site injuries and no significant damage. The second event occurred on August 18, 1998 when an operator was preparing a pump for maintenance repair and approximately 200 pounds of ethylene oxide in a 10% solution of water was released. The event lasted for approximately 2 hours and 11 minutes. A neighboring plant downwind elected to evacuate their one employee from the plant during the event as a precautionary measure. There were no off-site injuries and no significant damage.
6. Emergency Response
PD Glycol carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes many aspects of emergency response including adequate first aid and medical treatment, ev
acuations, notification of local emergency response agencies and the public. Our emergency plan has been coordinated and verified with the Jefferson County Local Emergency Planning Committee (LEPC).
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
Planned Changes to Improve Safety
PD Glycol continues to evaluate safety, health and environmental issues and to mitigate risk on an on-going basis as part of our on-going business driven improvement process for a safer plant and community.