Equistar Chemicals, LP - Tuscola Plant - Executive Summary |
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RISK MANAGEMENT PLAN EXECUTIVE SUMMARY Tuscola Plant Equistar Chemicals, LP (Equistar), a limited partnership formed by Lyondell Petrochemical, Millennium Chemical, and Occidental Petroleum Corporation, operates an ethanol and polymers manufacturing facility, the Tuscola Plant, in Tuscola, IL. The facility is located at 625 E. US Highway 36. Equistar employs approximately 137 full time employees at the plant site. 1. Accidental release prevention and emergency response policies at the stationary source (' 68.155a): Equistar is committed to operating the plant in a manner that is safe for its workers, the public and the environment. As part of this commitment, Equistar has established a system to help ensure safe operation of the processes at the Tuscola Plant. One component of this system is a risk management program (RMP) that helps manage the risks at the plant and that complies with the requirements of the Environmental Protection (EPA's) regulation 40 CFR part 68, Acci dental Release Prevention Requirement Risk Management Programs (the RMP rule); and the Occupational Safety and Health Administration's (OSHA), Process Safety Management (PSM) Standard (29 CFR 1910.119). This document is intended to satisfy the RMP Plan requirements of the RMP rule and to provide the public with a description of the risk management program at the Plant. Although the risk management program at the Tuscola Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at the Plant. In fact, the Plant has a comprehensive safety program in place, establishing many levels of safeguards against a release of a hazardous substance, as well as injuries and damage from a release of a hazardous substance. It is our policy to adhere to all applicable federal, state and local rules and regulations, industry standards and best practices. To effectively implement these policies, Equistar has est ablished a management system headed by the Health, Safety and Environmental (HSE) Department to oversee safety and environmental-related activities. Equistar's policy on the use of hazardous substances: Before using a hazardous substance, less hazardous alternatives are considered. When a hazardous substance is used, the chemical must be approved by the Chemical Control Committee by undergoing an environmental and safety analysis on the chemical to consider the potential for this substance to adversely affect the plant workers, the public and the environment. Any adverse effects must be addressed before the chemical is approved. Equistar strives to prevent accidental releases of the hazardous substances used at the facility: Equistar is committed to the safety of workers, the public and the preservation of the environment through the prevention of accidental releases of hazardous substances. Equistar implements reasonable controls to prevent foreseeable releases of haza rdous substances. When a hazardous substance is used, the equipment is carefully designed, built, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, installation and operation of the equipment. Equistar uses Fire, Safety and Environmental (FS&E) Guidelines when designing new or modifying existing processes. Each project is thoroughly reviewed before approval. In addition, Equistar requires the documentation of standard operating procedures and the training of affected employees with regard to these procedures as part of the management of change process. Equistar's mechanical integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances. The Tuscola Plant also participates in auditing processes to measure and enhance its prevention program. Equistar's goal is to minimize impact from an accidental release: In the event of an accidental release, the Tuscola Plant controls and contains the release in a manner that will be safe for workers and will prevent impact to the public and the environment. Equistar provides response training to its personnel, designates an emergency response coordinator to oversee response activities, conducts regular drills to review response activities and coordinates response efforts with area industry and the local emergency response agencies. Equistar trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs. In addition, Equistar works with the area industry, the local fire department and the Local Emergency Planning Committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur. Response activities have been discussed with the Local Emergency Planning Committee and the Douglas County Mutual Aid Association. Equistar is an active participant in the community: The Tuscola Plant actively participates in and is committed to the Chemical Manufacturers Association's Responsible Care. initiative. The plant, in conjunction with local emergency responders, conducts emergency drills to ensure community wide preparedness in case of an incident at the plant. The plant also hosts an annual Responsible Care. Day to communicate our progress on the Responsible Care. initiatives to local government officials, media, responders, members of the regulatory community and others. Every second year, the plant holds a community open house with plant tours, demonstrations, exhibits and an opportunity for anyone to stop by and talk to plant management and other employees. Finally, anyone is welcome, at anytime, to call the plant and discuss anything of concern. Through the above outreach efforts, as well as other community involvement, the plant stays abreast of community concerns and works to address them. 2 . The stationary source and the regulated substances handled (' 68.155 b): Equistar's Tuscola Plant is located on an 800-acre site and began operations in 1953. The stationary source consists of ethanol and ether production, alcohol denaturing, specialty polymers, and support facilities. The Tuscola Plant's key products are ethyl alcohol, ethyl ether, powdered polyethylene and polypropylene (Microthene-F) and a compounded polyethylene product. The plant also receives vinyl acetate monomer (VAM) and acetic acid for repackaging and shipment to customers. The feedstock used for ethanol and ether is ethylene. The feedstock for the powders and compounds is pelletized polymer produced at other Equistar sites. All feedstock arrives at the facility by pipeline, railcar and/or truck. The following facilities (processes) at the Tuscola Plant are covered under the RMP Rule: Denaturing Plant (includes Chemical Loading Area), Alcohol Plant (includes Synthesis and Finishing, Ether Purif ication Unit, and Tank Farm). The Tuscola Plant handles one regulated toxic - vinyl acetate monomer - and three flammable substances - ethyl ether, ethylene, and acetaldehyde - in sufficient quantity to be covered by the RMP rule and falls under the Level 3 Program. 3. The worst-case release scenarios and the alternate release scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario (' 68.155c): The Tuscola Plant performed off-site consequence analysis to estimate the potential for accidental release of a regulated substance that may affect the public or the environment. The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario " (WCS) and an "alternative release scenario" (ARS) for each toxic and one for all flammables. In reality, however, Equistar does not expect a worst-case release scenario to ever occur. The alternative release scenarios are developed to help the LEPC improve the community emergency response plan. EPA Look-Up Tables were used for evaluating the worst and alternate case release scenarios for flammable and toxic materials. The EPA recommended Landview program was utilized to estimate the number of people living within this distance from the location of the covered processes. United States Geological Survey (USGS) maps were utilized to identify the public and environmental receptors located within this distance. Specific scenario information along with public and environmental receptor data has been provided in data elements portion of EPA's RMP Submit Program. 4. The general accidental releas e prevention program and chemical specific prevention steps (' 68.155d): The facility complies with the EPA's Accidental Release Prevention Rule (40 CFR part 68) and OSHA's Process Safety Management Rule (29 CFR 1910.119). Program 3 is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment outside the plant's fenceline. The Tuscola Plant's Program 3 prevention program consists of the following 12 elements: A) Process Safety Information The Tuscola Plant maintains a variety of technical documents that are used to help ensure safe operation of the plant processes. These documents address (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant and (3) design basis and configuration of the equipment at the plant. Equistar ensures that this process safety information is available to all employees, the LEPC, the local fire department, the ar ea hospital and the county sheriff's office. Material safety data sheets (MSDSs) document the physical properties of the hazardous materials handled at the plant, including regulated substances in covered processes. The information available for each hazardous substance typically includes: Toxicity information and permissible exposure limits Physical data (e.g., boiling point, melting point, flash point) Reactivity and corrosivity data Thermal and chemical stability data Hazards of mixing substances in the process MSDSs for hazardous substances handled in the process are located throughout the facility so that the employees have ready reference to this information. In addition, key MSDSs are provided to the LEPC and the fire department for use in helping formulate emergency response plans. The engineering design documents include the operating parameters and the design basis and configuration of the equipment in the covered process. The availabl e information includes: Operating parameters Block flow or simplified process flow diagrams Process chemistry Maximum intended inventories Safe upper and lower limits for parameters such as temperature, pressure, or flow Consequences of deviations from established operating limits Design basis and configuration of equipment Piping and instrumentation diagrams, including materials of construction Electrical classification Safety systems Applicable design codes and standards Design basis for relief and ventilation systems When important information was not available, from the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analyses of the process. Many of the operating parameters are included in the operating procedures to help with the safe operation of the process. These documents are used to (1) train employees, (2) perform process hazards ana lyses and (3) help maintain the equipment. B) Process Hazard Analysis The Tuscola Plant performs and periodically updates process hazard analyses (PHAs) of the covered process to help identify process hazards and generate recommendations that might improve the safe operation of the process. A team composed of personnel with engineering and process operating experience and a leader with process hazard analysis experience is assembled to analyze the hazards of the process. The plant primarily uses the HAZOP and "what-if checklist" techniques to perform this analysis. The PHA team prepares a written report describing the results of the analysis, including a list of recommendations. Responsibility to resolve the recommendations is assigned to unit personnel and, as appropriate, changes to enhance the safety of the process are implemented. C) Operating Procedures Tuscola Plant engineers, operators and supervisors work together to develop and maintain operating procedure s to define how tasks related to process operations should be safely performed. The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: Steps for safely conducting activities Applicable process safety information, such as safe operating limits and consequences of process deviations Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. D) Training The Tuscola Plant trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process and (3) a detailed review of the process operating procedures and safe work practices. Oral reviews and written tests are used to verify that an employee understands the training material before the employee can work in the process. The operators are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed and changes to the training program are implemented as appropriate. E) Mechanical Integrity The Tuscola Plant maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public or the environment. The mechanical integrity program includes (1) an inspection and testing program to hel p identify equipment deterioration and damage before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes. The mechanical integrity program includes: Specifications for inspection and testing of process equipment Specifications for replacement parts and equipment Procedures for inspecting, testing, and maintaining process equipment Procedures for safe work practices such as Lock-out / Tag-out; Hot Work; Confined Space Entry; and Line Breaking Training of maintenance personnel Documentation of maintenance activities F) Management of Change The Tuscola Plant management of change program evaluates and approves all proposed changes to chemicals, equipment and procedures for a covered process to help ensure that the change does not negatively affect safe operations. Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that all consequences of process changes are evaluated, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. G) Pre-startup Review The Tuscola Plant performs a safety review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely. This review confirms that: Construction and equipment are in accordance with design specifications Adequate safety, operating, maintenance and emergency procedures are in place Employee training has been completed For a covered process that management of change requirements have been completed. A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed. H) Compliance Audit The Tuscola Plant audits the covered process to be certain that the prevention program is effectively addressing the safety issues of operating the plant. The plant assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. I) Incident Investigation The Tuscola Plant investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public or the environment so similar incidents can be prevented in the future . The plant trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved and appropriate process enhancements are implemented. J) Employee Participation The Tuscola Plant developed a written employee participation program for the covered process to help ensure that the safety concerns of the plant's workers are addressed. The plant encourages active participation of personnel in the prevention program activities at the plant. Employees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHAs and operating procedures. K) Hot Work Permits The Tuscola Plant established a hot work permit program to control spark or flame producing activities that could result in fires or explosions in covered processes at the plant. The plant revi ewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The Shift Supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation. L) Contractors The Tuscola Plant follows the Equistar Chemicals corporate contractor safety procedures to help ensure that contractor activities at the plant are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that the plant only hires contractors who can safely perform the desired job tasks. The plant explains to the contract supervisors the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant's emergency response procedures. The plant requires that the contractor supervisors' train each of their employees who will work at the plant before that worker can begin work at the plant site. The plant periodically reviews contractor's training documents, work performance, and performs assessment audits of the contractor's operations to help ensure that safe practices are followed. 5. The five-year accident history (' 68.155e): The facility experienced an accidental release of Ethylene from a process pipeline on January 2, 1999. The release resulted in the replacement and upgrading of the existing equipment. Revisions were made to the equipment design specifications, the mechanical integrity program, operating procedures, mitigation systems, and the emergency response plan as a result of the incident. The release resulted in a vapor cloud explosion which summoned off-site assistance, yet the incident was controlled by our on-site teams before off-site assistance arrived. Off-site impacts included structural damage to a neighboring chemical plant's building, and broken windows at a few residences due to the explosion's overpressure. Chemical Estimated Release Date Time Released Quantity Type 01/02/99 1030 Ethylene 22,000 Lbs. Gas Release/Explosion 6. The emergency response program (' 68.155f): The Equistar Tuscola Plant emergency response plan has been developed to meet the emergency planning, response and notification requirements of the following regulations: OSHA 29 CFR 1910.38 (a) - Employee Emergency Action Plans OSHA 29 CFR 1910.119 (n) - Process Safety Management Of Highly Hazardous Chemicals OSHA 29 CFR 1910.120 (p) and (q) - Hazardous Waste Operations and Emergency Response (HAZWOPER) OSHA 29 CFR 1910, Subpart L - Fire Protection EPA 40 CFR Part 302.6 - Notification Requirements EPA 40 CFR Part 355.30 - Facility Coordinator and Emergency Response Plan E PA 40 CFR Part 355.40 - Emergency Planning and Release Notifications EPA 40 CFR Part 112 - Spill Prevention, Control and Countermeasures Plan EPA 40 CFR Part 68 - Risk Management Programs for Chemical Accidental Release Prevention EPCRA section 302 - List Of Extremely Hazardous Substances The emergency response strategy for the Tuscola Plant is to prevent and/or control emergency situations via the use of engineering, design and fixed fire protection systems. Fixed fire protection systems are designed to National Petroleum Refiners Association (NPRA) guidelines. The plant has an Emergency Response Team on each shift, available 24 hours per day, to respond and initiate response actions to contain, control and if possible mitigate the release. The team has access to on site emergency equipment, which are appropriate for the anticipated emergency situations and capabilities of Equistar personnel. The following is a listing of some of the equipment, wh ich is available for emergency response: 1250 gallon per minute Pumper Truck equipped w/ 1000 gallons of water HAZMAT Truck Rescue Trailer 8,500 gallon per minute Firewater System Ambulance Drills are conducted to assess and evaluate the emergency response effort at the Tuscola Plant and include participation of various public emergency response organizations such as fire departments, Hazmat teams, Douglas County Emergency Management Agency, sheriff's department, and the appropriate LEPC organizations. If assistance is required during an emergency response, the following Mutual Aid Association could be activated and requested to provide additional resources as necessary: Douglas County Mutual Aid Association The Tuscola Plant is an active participant in the community planning process with the Douglas County Local Emergency Planning Committee. A copy of the plant's Emergency Response Plan has been forwarded to the Office of Emergency Prep aredness as per the requirements of 40 CFR 355. The Tuscola Plant is an active member of the Chemical Industries Council of Illinois. The Tuscola Plant is an active participant in and is committed to the Chemical Manufacturers Association's Responsible Care. initiative conducting annual assessments of the Plant's compliance effort. 7. Planned changes to improve safety (' 68.155g): The Tuscola Plant constantly strives to improve the safety of the processes at the facility through the auditing process, the suggestion process and incident investigation process. 8. Processes not covered by the rule: The Equistar Chemicals, LP, Tuscola Plant has determined that the following processes are not covered by the Rule at this facility: Water and Waste Water Treatment Plants (WWTP), Black Compounding and Microthene F. These manufacturing units do not manufacture or use any regulated chemicals above the threshold quantity. |