Shell Chemical Company - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
At the Shell Chemical Company Belpre Plant, we are committed to operating and maintaining all of our processes 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 offsite 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 emergency response program 
*  An overview of system 
s used 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 
 
The Shell Chemical Company Belpre Plant produces Kraton(R) and Shellvis(R) thermoplastic elastomers using a variety of chemicals and processing operations.  Our facility includes four polymer production units, a compounding unit and utilities and other support services.  In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: 
 
Toxics 
 
Chemical                         Use         
 
Ammonia                                    processing aid         
 
 
Flammables 
 
Chemical                        Use         
 
1,3-Butadiene                                              raw material              
Ethyl ether[Ethane,1,1'-oxybis-]                         processing aid                  
Hydrogen                                 raw material        
                  
Isoprene [1,3-butadinene, 2-methyl-]              raw material               
 
 
 
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that may be 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 scenarios and alternative release scenarios 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 Release Scenario(s) - Regulated Toxic Chemicals 
 
(It is important to note that the chances of this scenario actually happening are extremely remote.  No such event has occurred in the history of the plant.) 
 
The worst-case toxic release scenario involves an anhydrous ammonia vessel failure resulting i 
n a 20,000 lb release of ammonia.  This scenario assumes ALL ammonia forms a gas cloud within ten minutes and that no control or response measures are activated or used. This scenario would have significant offsite consequences. 
 
 
Alternative Release Scenario(s) - Regulated Toxic Chemicals 
 
 
Even though no realistic scenario would impact property beyond Shell's, the EPA strongly prefers that the alternative release scenario presented reach beyond the Shell property line.   
 
The alternate-case toxic release scenario involves an anhydrous ammonia transfer hose failure resulting in a 1000 lb release of ammonia with offsite consequences.  A trained Incident Commander provides leadership in any emergency release.  The Incident Command Organization includes many trained emergency responders and is supported by skilled personnel who know the equipment and chemicals. 
 
Mitigations already in place to prevent releases include vessel design for higher pressure, manned truck unloading, two indepen 
dent level gauges, a high pressure alarm, excess flow check valves, written operating procedures and employee training.  With these mitigations in place an actual release of 1000 lbs of ammonia is extremely unlikely to occur. 
 
All emergency releases of 100 pounds or more of ammonia are reported to Ohio EPA, the Washington County Local Emergency Planning Committee, and the National Response Center.  No reportable emergency releases of ammonia have occurred at the plant in more than 7 years. 
 
 
 
Worst-case Release Scenario(s) - Regulated Flammable Chemicals 
 
(It is important to note that the chances of this scenario actually happening are extremely remote.  No such event has occurred in the history of the plant.) 
 
The worst-case flammable release scenario involves a 1,3-Butadiene vessel failure resulting in a vapor cloud explosion of 4,950,000 lbs of 1,3-Butadiene.  This scenario assumes a full storage tank release and explosion.  Significant offsite consequences would occur with this sce 
nario.  
 
 
Alternative Release Scenario(s) - Regulated Flammable Chemicals 
 
Even though no realistic scenario would impact property beyond Shell's, the EPA prefers that the alternative release scenario presented reach beyond the Shell property line. 
 
The alternate-case flammable release scenario involves a 1,3-Butadiene relief valve leak resulting in a 30,000 lb release and vapor cloud explosion of 1,3-Butadiene.  A trained Incident Commander provides leadership in an emergency release.  The Incident Command Organization includes many trained emergency responders and is supported by skilled personnel who know the equipment and chemicals.  
 
Mitigation in place to prevent such an actual release event include; vessel design for greater than normal pressure and temperature; remote location; high level indication, alarm and transfer shutdown; vaporizer high pressure control, alarm and shutdown; 1,3-Butadiene sphere  pressure control and vent to flare system; operator surveillance, area monit 
ors,  written operating procedures and employee training.  With these mitigations in place a release of 30,000 lbs of 1,3-Butadiene is unlikely to occur. 
 
All emergency releases of 10 pounds or more of 1,3-Butadiene are reported to the Ohio EPA, the Washington County Local Emergency Planning Committee and the National Response Center.  No reportable emergency releases of 1,3-Butadiene have occurred at Shell's Belpre Plant in over 4 years. 
 
 
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. 
 
GENERAL 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: 
 
*  Process safety information 
*  Process hazard analysis 
*  Operating procedures 
*  Training 
*   
Mechanical integrity 
*  Management of change 
*  Pre-startup safety reviews 
*  Compliance audits 
*  Incident investigation 
*  Employee participation 
*  Hot work permit 
*  Contractors 
 
As part of our prevention efforts, we have implemented the following chemical-specific prevention steps:  
 
A prevention effort specific to this facility is a triple redundancy polymer safety system ("Poly Safety System").  The Poly Safety System is designed to prevent runaway polymerization reactions by ensuring more energy is never placed into a reactor than can be safely contained. 
 
In general, the Shell Chemical Company Belpre Plant is dedicated to continuous safety improvement and all chemicals are treated with equal respect when it comes to release prevention.  Our ongoing training, procedure review, auditing and process improvements are utilized in reaching our goal of an accident and injury-free workplace. 
 
The individual elements of our prevention program work together to prevent accidental  
chemical releases.  Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.   
 
FIVE-YEAR ACCIDENT HISTORY 
 
We keep records for all accidental chemical releases that occur at our facility.  The following is a brief summary of the accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: 
 
 
Chemical Released        Date    Quantity Released     
 
Hydrogen            8/9/98          53 lbs 
 
All significant accidental releases of chemicals are formally investigated to identify and correct the root cause of the events. 
 
 
EMERGENCY RESPONSE PROGRAM 
 
We maintain an Emergency Reponse Plan, a Spill Prevention Control and Countermeasures Plan and a Facility Response Plan to document requirements for emergency response planning.  Our programs provide the essential planning and traini 
ng for effectively protecting workers, the public, and the environment during emergency situations.  Furthermore, we coordinate our plan with the community emergency response plan.   
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
This facility is dedicated to continuous safety improvement and as such there are several ongoing programs to promote continuous safety improvement.  The following is a list of some of the activities the facility uses to continuously improve process safety and prevent and/or better respond to accidental chemical releases: 
 
*  Ongoing, systematic review of safety, environmental and emergency response procedures 
*  Audits of procedures and field practices 
*  Operating departments have safety committees and monthly safety meetings to discuss requirements and issues 
*  Incident and near-miss investigations are completed using systematic root cause analysis techniques 
*  Operating procedures, safety procedures and various process safety information are available on-line to en 
sure easy access and current information 
*  A contractor safety council meets routinely to share information and discuss issues for resolution 
*  Ongoing training of emergency response personnel 
 
In addition to the ongoing activities listed above, the Shell Chemical Company Belpre Plant has also purchased emergency response equipment in the last four years such as a new fire truck, a fire-fighting foam tanker truck, and an Incident Command Vehicle.  This new equipment improves the facilities emergency response capabilities.
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