Equistar Chemicals, LP - Tuscola Plant - Executive Summary

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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 
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  
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  
Through the above outreach efforts, as well as other community involvement, the plant stays  
abreast of community concerns and works to address them.  

. 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  
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  
    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  
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  
    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  
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 
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  
    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  
    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  
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  
    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 
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  
    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 
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  
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.
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