Bayport Chemical Plant - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at the Goodyear Bayport Chemical Plant are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass manufacture of hydroquinone, a raw material used in the production of a rubber antioxidant. We have 3 regulated substances present at our facility. These substances include Propane, Isopentane [Butane, 2-methyl-] and Propylene [1-Propene]. The regulated subsances at our facilit y are generated from the recovery of light ends from an alkylation process. The maximum inventory of the mixture is 93,780 pounds which consists of approximately 9,378 pounds of Propane, 1,781 pounds of Isopentane, and 1,125 pounds of Propylene with the balance of the mixture consisting of non-regulated materials, benzene and cumene. 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 To evaluate the worst case scenarios, we have used Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance. For alternative release scenario analyses, we have employed the equations provided by the EPA in The RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from the Lig ht Ends Storage Tank, V-404, in the Light Ends process. The scenario involves the release of 93,780 lbs. which contains Propane, Isopentane, and Propylene. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.37 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 3 flammable substances involves a release from the Light Ends Storage Tank, V-404. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 9,180 lbs. of Light Ends, which contain: Propane, Isopentane, and Propylene through a relief valve which is stuck in an open position for 60 minutes. The release is also controlled by active mitigation measures that include a deluge system. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.11 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information The Bayport Chemical Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is HAZOP (Hazard and Operability). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated every five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, the Bayport Chemical Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training The Bayport Chemical Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity The Bayport Chemical Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. 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. Qualified personnel who have been trained in maintenance practices perform maintenance operations. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at the Bayport Chemical Plant to manage changes in process chemicals, technology, equipment and procedures. Process op erators, 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 Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at the Bayport Chemical Plant. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits The Bayport Chemical Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation The Bayport Chemical Plant promptly investigates any incident that has resulted in , or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the incident from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation The Bayport Chemical Plant truly believes that process safety management and accident prevention is a team effort. Company 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 of the RMP rule, including information resulting from process hazard analyses in particular. Contractors 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. The Baypo rt Chemical Plant 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 all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History The Bayport Chemical Plant has had an excellent record of preventing accidental releases over the last 5 years. No releases have occurred during this period. 6. Emergency Response Plan The Bayport Chemical Plant has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promp tly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. The La Porte, Morgan's Point, Shore Acres LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety The Bayport Chemical Plant has been concentrating their efforts in analyzing and correcting any safety deficiencies found in the plant. This work is done in preparation for making application to OSHA for VPP Star Status. 8. Certification Statement 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. Name: Michael R. Lockwood Signature: Title: Plant Manager Date signed: |