Equistar Chemicals, LP - Bayport Plant - Executive Summary |
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Risk Management Plan Executive Summary Equistar Chemicals, LP Bayport Plant 1.Accidental Release Prevention and Emergency Response Policies Equistar 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 our processes. 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. We are also coordinated with Channel Industries Mutual Aid which provides additional emergency response expertise. 2.The Stationary Source and the Regulated Substances Handled Equistar's primary activities encompass ethylene oxide and ethylene oxide derivatives manufacturing and polymer and resins m anufacturing. We manufacture or utilize 6 regulated substances at Equistar; ethylene oxide, anhydrous ammonia, propylene, ethylene, propane, and butene. 3. The Worst Case Release and Alternative Release Scenarios Methodology given in the RMP Offsite Consequence Analysis Guidance by the EPA using tables and equations has been employed 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 catastrophic release from the ammonia storage in the amines refining and manufacturing process. The scenario involves the release of 430,000 pounds of ammonia. It is assumed that the entire quantity is released as a vapor. Under worst case weather conditions, the maximum distance of approximately 7.3 miles is obtained corresponding to an endpoint of 0.14 mg/l. The worst case release scenario submitted for Program 3 flammable substan ces as a class, involves a catastrophic release from propylene storage in the polypropylene manufacturing process. The scenario involves the release of 305,000 pounds of 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 approximately 0.5 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 3 toxic substances involves a release from ethylene oxide storage in the ethylene oxide manufacturing process. The release is assumed to result from a broken line in the storage area. The scenario involves the release of approximately 290,000 pounds of ethylene oxide in 60 minutes. Passive mitigation controls such as dikes are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distan ce of approximately 3.3 miles is obtained corresponding to a toxic endpoint of 0.09 mg/l. The alternative release scenario submitted for Program 3 flammable substances involves a release from propylene storage in the polypropylene manufacturing process. The release is assumed to result from a broken line in the storage area. The scenario involves the release of approximately 50,000 pounds of propylene in 10 minutes. Passive mitigation controls such as dikes are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance of approximately 0.3 miles is obtained corresponding to an endpoint of 1 psi overpressure. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Equistar 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 strict engineering standards and the fac ility is subject to the OSHA Process Safety Management standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program in place at Equistar. Process Safety Information Equistar maintains a record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with the process. Process Hazard Analysis Equistar conducts studies to ensure that hazards associated with the process are identified and controlled efficiently. The methodology used to carry out these analyses is referred to as a unit Process Hazard Analysis (PHA). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated on an as needed basis, but at a minimum every five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting operations activities, Equ istar 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 with the processes. Training Equistar has a training 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 as needed . Mechanical Integrity Equistar carries out documented maintenance checks to ensure process equipment is functioning properly. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent syste ms, emergency shutdown systems, controls and pumps. Maintenance is carried out by qualified personnel with 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 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 are trained 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. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into opera tion. Compliance Audits Equistar conducts audits on a regular basis to verify the provisions set out under the PSM and RMP rules are being implemented. These audits are carried out at least every 3 years and corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Equistar investigates any incident that has resulted in, or could reasonably result in, an employee injury or a catastrophic release of a hazardous material. These investigations are undertaken to identify the root cause of the incident as well as any corrective actions to prevent the incident from reoccurring. Investigation reports are retained for a minimum of 5 years. Employee Participation Equistar 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 to the RMP rule, particularly information resulting from process hazard analyses. The Bayport plant has attained the highest level of recognition in the Voluntary Protection Program (VPP), the OSHA STAR. 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. Contractors 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. Equistar has a strict policy of informing the contractors of known potential hazards related 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 There have been no accidental releases of sub stances regulated by the RMP rule during the last five years. 6. Emergency Response Plan The Bayport plant maintains a written emergency response plan to minimize the effects of any unforeseen accidental releases of hazardous materials. The plan includes many 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. The facility's emergency response plan has bee coordinated with the LaPorte and Pasadena Local Emergency Planning Committee (LEPC). To ensure proper functioning, emergency response equipment is regularly inspected and serviced and our emergency response team conducts regular training and drills. In addition, the plan is updated to reflect any pertinent changes taking place within our process that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and fin dings have resulted from the implementation of the various elements of our accidental release prevention program. A hydrocarbon detection system is planned for installation in and around selected process areas to provide early warning for gas leaks. This system will allow the facility to promptly detect and respond to gas leaks before they become serious. Over-blast protection is planned for the Polypropylene Control Room to protect personnel and control equipment in the event of an explosion. This will provide personnel the opportunity to maintain control of the process in the event of emergency. |