Equistar Chemicals - Laporte Complex - Executive Summary

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Risk Management Plan Executive Summary 
Equistar Chemicals, LP 
LaPorte Complex 
 
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 
 
The LaPorte plant's primary activities encompass olefins and polymer and resins manufacturing.  The LaPorte plant manuf 
actures or utilizes 7 regulated substances; butadiene, isobutane, butene, butane, ethylene, acetaldehyde, and vinyl acetate monomer.  
 
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 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 vinyl acetate monomer storage in the polymers and resins manufacturing process.  The scenario involves the release of approximately 2,600 pounds of vinyl acetate monomer.  Under worst case weather conditions, the maximum distance of approximately 0.4 miles is obtained corresponding to an endpoint of 0.26 mg 
/l. 
 
The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from a butadiene storage tank in the ethylene manufacturing process.  The scenario involves the release of approximately 3,000,000 pounds of butadiene.  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 1.2 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 vinyl acetate monomer storage in the polymers and resins manufacturing process.  The release is assumed to result from a piping failure.  The scenario involves the release of approximately 10,000 pounds of vinyl acetate monomer in 31 minutes.  Under neutral weather conditions, the maximum dis 
tance of approximately 0.30 miles is obtained corresponding to a toxic endpoint of 0.26 mg/l. 
 
The alternative release scenario submitted for Program 3 flammable substances involves a release from the 1-butene railcar unloading station located in the polymers and resin manufacturing process.  The release is assumed to result from a piping failure.  The scenario involves the release of approximately 55,000 pounds of butene. Under neutral weather conditions, the maximum distance of approximately 0.20 miles is obtained corresponding to an endpoint of 1 psi overpressure.   
 
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
 
The LaPorte plant 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).  A number of processes at The LaPorte plant are subject to the OSHA PSM standard under 29 
CFR 1910.119. 
 
The following sections briefly describe the elements of the release prevention program in place at The LaPorte plant. 
 
Process Safety Information 
The LaPorte plant maintains a record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
 
Process Hazard Analysis 
The LaPorte plant conducts studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is referred to as a unit 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.  Any findings related to the hazard analysis are addressed in a timely manner. 
 
Operating Procedures 
For the purposes of safely conducting operations activities, The LaPorte plant maintains written operating procedures.  These procedures address various modes of oper 
ation 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 
The LaPorte plant 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 at least every three years and more frequently as needed. 
 
Mechanical Integrity 
The LaPorte plant 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 systems, emergency shutdown syste 
ms, 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 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.  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 Audit 

The LaPorte plant conducts audits 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 
The LaPorte plant 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 
The LaPorte plant 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 informatio 
n created as part of the facility's implementation to the RMP rule in particular information resulting from process hazard analyses. 
 
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.  The LaPorte plant 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 substances 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 emergenc 
y 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 been coordinated with the LaPorte 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 
 
The LaPorte plant is committed to employee health and safety and we feel providing a safe work place ultimately results in improved safety for our community.  For this reason our most significant planned safety change is our commitment to the OSHA Voluntary Protection Program.  We plan to submit the VPP application in the 
third quarter of 2000.
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