Lyondell Chemical - Bayport Plant - Executive Summary
EXECUTIVE SUMMARY |
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
At the Lyondell - Bayport Plant , we are committed to operating and maintaining our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:
- A description of our facility and use of substances regulated by EPA's RMP regulation
- A summary of results from our assessment of the potential off site consequences from accidental chemical releases
- An overview of our accidental release prevention programs
- A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
- An overview of our emer
gency response program
- An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public and the environment.
STATIONARY SOURCE AND REGULATED SUBSTANCES
Our facility produces a number of products that include propylene oxide (PO), tertiary butyl alcohol, propylene glycols, propylene glycol ethers, and tertiary butyl hydroperoxide. These units/processes use the following chemicals that the EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release:
Propylene Oxide (PO): Approximately 35.4 million lbs are produced, stored and used on-site. PO is the major product of the facility and is also a feed stock for the propylene gylcols and propylene gylcol ethers.
Propylene: Approximately 1,800,000 lbs are stored and used on-site. Propylene is a primary feed stock for the three PO Units
Propane: Approximately 325,000 lbs are stored and used on-site. Propane is a chemical used in the production of PO.
Isobutane: Approximately 8,200,000 lbs are stored and used on-site. Isobutane is a primary feed stock for the three PO Units
Isobutylene: Approximately 4,000,000 lbs are stored and used on-site. Isobutylene is used in the production of PO.
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:
Worst-case Scenario - Propylene Oxide
The worst case scenario for propylene oxide (PO) assumes the complete rupture of the largest PO storage tank releasing 13,40,000 pounds of liquid PO into a containment dike, leading to a vapor cloud release. This release would impact off-site public receptors.
Credit was taken for the containment dike (passive mitigation), the entire contents of the tank were contained, reducing the amount of PO released to the atmosphere.
Alternative Release Scenario - Propylene Oxide
The alternative release scenario for propylene oxide assumes failure of a 6" loading hose or loading arm. This release scenario also assumes the release would not be controlled for 15 minutes and all active safety systems fail including the emergency shutdown. The total release would be 20,700 pounds of PO, the vapor cloud would extend past the fence line and impact adjacent industrial sites.
Credit was not taken for safety systems in place that would minimize the
release. These systems include:
- Emergency shutdown switches
- Drains that lead to a chemical sump
- Water spray/sprinkler system
- Deluge system
- Remote isolation valves
- Emergency Team response
REGULATED FLAMMABLE CHEMICALS
Worst-Case Scenario - Isobutane
The worst case scenario for flammables assumes the complete rupture of an isobutane storage sphere, releasing 1,800,000 pounds of isobutane, leading to a vapor cloud explosion and overpressure. The overpressure would extend past the fence line and impact industrial and residential neighbors.
Alternative Release Scenario - Propylene
The alternative release scenario for flammables assumes a flange separation on an 8" propylene recycle line. This release scenario also assumes the release would not be controlled for 15 minutes and all active safety systems fail. The total release would be approximately 163,000 pounds of propylene, leading to a vapor cloud explosion and overpressure. The overpressure would extend slig
htly past the fence line and could impact the nearest industrial facility at the fence line.
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases.
GERNERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including:
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
Process Safety Information: Chemical hazard, process technology, and equipment information is documented, maintained up-to-date, and available to operating personnel.
Process Hazard Analysis: A rigorous practice of reviewing new processes or change to existing processes at the design stage to identify and mitigate potential safety, health, and environmental
issues before the process is installed and operated. Scheduled process hazard/risk reviews are conducted to revalidate initial process hazard reviews on a periodic basis. Process hazard analyses are conducted every five years to identify major process hazard scenarios and to recommend corrective action(s) needed to prevent their occurrence.
Operating Procedures: Operating procedures provide detail on how to safely operate a process and are maintained up-to-date. Operating procedures are based on process hazard/risk reviews. The procedures include emergency shutdown and safe start-up methods.
Operator Training/Certification Program: The plant has a training and testing program which provides operators with the proper skills and knowledge prior to allowing them to independently operate a process. Operator recertification is required.
Maintenance Procedures: The plant has specific procedures for maintaining process equipment so that is operates safely. Plant and unit specific
procedures for servicing operating equipment are in place, including preventative maintenance and reliability programs.
Maintenance Training: The plant trains and tests mechanics and craftsmen who perform routine or complex maintenance tasks on process equipment and inspections on operating equipment to ensure they have the required knowledge and skills.
Mechanical Integrity Program: Vessels (including shipping containers) and other process equipment are periodically tested and inspected to ensure safe operation of process equipment, following recognized standards and/or government requirements. this program includes testing, inspection and maintenance of critical equipment, including pressure relief devices, hoses, piping, instruments, and shutdown systems.
Quality Assurance: The plant has a system to ensure that purchased equipment and materials meet established engineering standards and specifications.
Process Change Authorizations (Management of Change): The plant has a ma
nagement system to ensure that modified facilities and processes are safe for operation. Design and pre-startup safety reviews are conducted for facility or process changes before the changes are implemented.
Pre-Startup Safety Reviews: Reviews are conducted just prior to start up to ensure that modified facilities and processes are safe for operation.
Incident Investigation: The plant has a program to ensure accidents, incidents, and near miss events are properly investigated to determine the Root Cause(s) and Contributing Cause(s), and to implement corrective action(s) that are needed to prevent recurrence.
Employee Participation: The plant has a program to involve employees in prevention program elements.
Hot Work Permit: Protects employees and property by preventing fires and explosions. It ensures, among other things, that no flammable materials are present when an open spark or flame may be present for maintenance activities. The plant has a procedure to ensure that
welding, cutting and brazing are safely performed in areas where flammable or combustible material may be present.
Line Breaking: Requires isolation and draining of lines to be opened, preventing accidental releases or opening the wrong line.
Compliance Audits: Periodic corporate led and plant led audits are conducted to ensure that process operations comply with governmental and Lyondell requirements.
Contractor Safety Program: The plant has a program to ensure that contractors are properly trained and perform their work in compliance with safety requirements. Contractors must meet rigorous safety performance requirements before being allowed to work on process equipment. Contractor employees and regular plant employees must follow all of the same plant safety procedures and requirements.
Equipment Design: Vessels (including shipping containers) and other process equipment are designed according to recognized industry standards and/or governmental requirements.
ng Excellence Standards: Rigorous corporate standards that we follow to ensure that we operate our facilities in a safe and environmentally sound manner. Our compliance to these standards is routinely audited by corporate experts. We have Manufacturing Excellence Standards in the following areas: Environmental, Health and Safety; Technical; Operations; Maintenance; Transportation and Storage; Quality; and Purchasing. Manufacturing Excellence is Lyondell's comprehensive program to ensure that all the elements listed above are implemented and maintained at every Lyondell facility. This program includes accountabilities for timely and proper implementation of the program elements.
These general prevention elements and the chemical specific steps discussed in the previous section are parts of an overall management system to prevent accidental chemical releases. Our company and our employees are committed to the standards that these management systems set. We have specific accounta
bilities and controls to ensure that we are meeting our own high standards for accident prevention.
FIVE-YEAR ACCIDENT HISTORY
There have been no releases of any RMP regulated hazardous chemicals at our facility in the past five years that meet the EPA RMP reporting requirements.
EMERGENCY RESPONSE PROGRAM
We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, were coordinate our plan with the community emergency response plan, through the LaPorte LEPC. We are also participating members of the Channel Industries Mutual Aid (CIMA) Association.
PLANNED CHANGES TO IMPROVE SAFETY
The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond t
o accidental chemical releases:
- Continue the upgrade/replacement of the distributed control systems (DCS) in operating units.
- Continued review and upgrade of the safety interlock system throughout the facility.
- Continued use and implementation of root cause analysis to investigate incidents, to identify causes of process problems, and to develop effective solutions to prevent recurrence.
- Continue conducting revalidation process hazard analyses (PHAs) and completion of open findings.
- Upgrade of facility security systems.
- Completed a turnaround in PO/TBA Unit I in May, complete turnaround in the other operating units as scheduled.
- The relief valve (RV) project to tie RVs into the flare system was completed during the PO/TBA Unit I turnaround.