Lyondell Chemical Worldwide, Inc. - Executive Summary

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2694 LDEQ Facility Identification Number. 
 
State of Louisiana Department of Environmental Quality - Facility ID number: 27051 
 
Lyondell Chemical Company is one of the world's largest chemical companies - comprising wholly owned businesses operating under the Lyondell name and major ownership positions in Equistar Chemicals, LP, Lyondell-Citgo Refining LP and Lyondell Methanol Company, LP.    In total, the Lyondell enterprise operates in 15 countries and has approximately 20,000 employees.  Lyondell Chemical Company owns and operates the Lake Charles, Louisiana facility.   
 
Throughout the decades, Lake Charles facility employees have enjoyed the cultural and physical environment of Southwest Louisiana.  The Lake Charles facility has been and will continue to be dedicated to maintaining a healthy ecosystem for future generations of the region.  Over the past several years, Lake Charles employees have worked hard to earn the public's trust. They have improved the facility's safety and env 
ironmental performance and have built strong community ties. Today Lake Charles employees are listening to their communities, responding to their concerns, and helping improve their quality of life. 
 
Efforts to reduce pollution and increase safety at the Lake Charles facility focus on several fronts. Lake Charles facility employees strive to develop technologies that minimize waste, install newer equipment that is more environmentally-sound, treat waste streams that are generated by their manufacturing processes, and develop and enhance their systems for analyzing and addressing risks. All of these employee efforts have helped the facility prevent incidents. 
 
Manufacturing Excellence drives Lyondell's progress and achievement.  Manufacturing Excellence, is our own internal program, launched in 1991. It incorporates all of the Responsible Care codes and Lyondell's own standards for improving safety and environmental performance as well as product quality, manufacturing reliability, and  
efficiency. 
 
The Lyondell - Lake Charles family is proud of what it has accomplished, but also understands that more needs to be done.  Lyondell is committed to continually improving its practices to ensure future efforts and programs achieve success for its operations in this community. 
 
 
I. The Accidental Release Prevention and Emergency Response Policies at the Lake Charles Facility 
 
It is the policy of Lake Charles facility to operate in a safe manner, with minimum risk to all workers and visitors and to the surrounding community.  While every effort is made to operate the facility safely, it is recognized that accidents can happen.  In order to provide for a coordinated, effective, and timely response to emergency incidents, the Lake Charles facility has developed and implemented the Lake Charles Plant Emergency Plan. 
 
The Lake Charles facility is implementing a program to consolidate and streamline the Compliance Audit requirements as defined in OSHA's Process Safety Management  
Program (29 CFR 1910.119(o) and the Risk Management Program, 40 CFR 68.79 for various regulated on-site process units.  The consolidation of Compliance Audit Programs is based on minimizing duplication, redundancy, and inconsistency attributed from overlapping state and federal programs. The Lyondell-Lake Charles facility will demonstrate compliance with the two audit programs on an 'overall most stringent compliance audit program' approach.   The 'most stringent overall program' for the regulated process units on-site is defined in the provisions defined in 29 CFR 1910.119(o) - OSHA's Process Safety Management Compliance Audit provisions. 
 
 
II. Lake Charles Facility and the Regulated Substance Handled 
 
The Lake Charles Plant is a 235-acre site located to the south west of Westlake, and to the west of Lake Charles, Louisiana.  The plant is adjacent to Interstate Route 10, a major east-west interstate highway. The plant has three (3) process units that are regulated under the Risk Mana 
gement Program as defined in 40 CFR Part 68. The regulated process units are: 
 
Toluene Diisocyanate (TDI) Complex - The TDI complex consists of units that produce hydrogen and carbon monoxide as raw materials for toluene diamine (TDA) and phosgene, the raw materials for TDI.  TDI is a major component of flexible urethane foam, which is used in furniture cushioning, bedding, carpet underlay and safety padding. The regulated substances handled in the TDI Complex include: 
 
TDI Complex - Stationary Source and Regulated Substances Handled: 
Listed Compounds: Chlorine, phosgene and toluene diisocyanate 
Usage:  
Chlorine is used in water treatment in the Toluene Diisocyanate (TDI) and Toluene Diamine (TDA) Process Units.  It is also used as a raw material in the Phosgene process unit. 
Phosgene is used as a raw material in the TDI process unit.  Phosgene is a finished product from the Phosgene process unit. 
 
Toluene Diamine Process Unit - Stationary Source and Regulated Substances Handled: 
Liste 
d Compound: chlorine. 
Usage: 
Chlorine is used in water treatment in the Toluene Diamine process unit. 
 
Nitric Acid - The Nitric Acid plant produces a high-quality nitric acid.  Nitric acid is used in metal treatment and industrial chemicals. 
 
Nitric Acid Process Unit - Stationary Source and Regulated Substances Handled: 
Listed Compounds: butane, chlorine and ammonia. 
Usage: 
Chlorine is used in water treatment in the Nitric Acid process unit.  Ammonia is used as a raw material. 
Butane is used as a fuel in the start-up of the nitric acid process. 
 
Luxate .  - The Luxate . production facility uses amines and phosgene to produce aliphatic diisocyanates.   Luxate . products are used in high quality paints and coatings for automobiles, appliances, and airplanes 
. 
Luxate Process Unit - Stationary Source and Regulated Substances Handled: 
Listed Compound: phosgene. 
Usage:    Phosgene is used as a raw material in the Luxate process unit. 
 
 
III. The Worst-case Release Scenario(s) and the Alternativ 
e Release Scenario(s) 
 
The Lake Charles facility utilized the USEPA - RMP Offsite Consequence Analysis Guidance (OCA Guidance), May 24, 1996, for determining off-site impact for worst case and alternate release scenarios. While EPA acknowledges that the worst-case scenario is unlikely to occur, other scenarios could occur at the Lake Charles facility. Through the evaluation of these scenarios appropriate emergency response planning discussion can occur. 
 
The USEPA requires that regulated covered stationary sources handling regulated substances identify worst-case scenarios involving the chemicals located on their site and estimate the possible impact from a catastrophic release. Lyondell - Lake Charles facility evaluated a variety of scenarios using USEPA published guidelines to identify our worst-case scenario. This information must be filed with the USEPA and the Calcasieu Parish LEPC. 
 
Planning-case (Alternate Release Scenarios) scenarios differ from worst-case scenarios in several  
important ways. Planning-case scenarios allow the use of both active and passive mitigation to reduce the potential impact of a release on people outside the facility. Further, planning-case scenarios use release estimates based on events, which have happened or are more likely to occur. 
 
According to EPA, the Distance-to-Toxic-Endpoint (DTE) is intended to provide an estimate of the maximum possible area that might be affected under catastrophic conditions. The distance is based on a concentration of the chemical that a person could be exposed to for an hour without suffering irreversible health effects or other symptoms that would make it difficult to escape. It is intended to ensure that potential risks to public health are addressed.   
 
Note: 
Weather conditions significantly affect the distance to end point when a release occurs. For flammables, although an explosion could occur, it is more likely to disperse harmlessly or burn. 
 
Additionally, according to the EPA, after a distance 
of six miles, the evaluation technique becomes especially uncertain when determining distance to end point. 
 
 
Worst case Scenario Toluene Diisocyanate Process Unit: 
At the Lyondell - Lake Charles facility, a liquid phase scenario from the Toluene Dissocyanate process unit was evaluated for the worst case. 
 
For the analysis, a toluene diisocyanate release from the largest finished product storage tank with a capacity of 3,764,000-lbs. capacity was used.   USEPA allows the facility to consider a dike around the tank to limit the exposed surface area of a pool thereby reducing the release of the toluene diisocyanate. 
 
Planning-case (Alternate Release Scenarios) Scenario Toluene Diisocyanate Process Unit: 
For the Planning-case scenario, liquid phase and gas phase scenarios from the Toluene Diisocyanate process unit were used to evaluate the planning-case: phosgene and toluene diisocyanate.   
 
In the first analysis, a phosgene release from process equipment was used. 
 
For the second analy 
sis, a 2,500-pound release of toluene diisocyanate from the overfilling of a finished product storage tank was used. USEPA allows the facility to consider a dike around the tank to limit the exposed surface area of a pool thereby reducing the release of the toluene diisocyanate.   
 
 
 
Worst case Scenario Phosgene Process Unit: 
At the Lyondell - Lake Charles Facility, a gas-phase scenario from the Phosgene process was selected to evaluate for the worst case scenario.  
 
For the analysis, a 360,000-pound chlorine release was selected from the staged catastrophic discharge of a fully loaded railcar interconnected and unloading into a 38,500-gallon storage tank. 
 
Planning-case (Alternate Release Scenarios) Scenario Phosgene Process Unit: 
For the Planning-case scenario, gas-phase scenarios from the Phosgene process unit were used to evaluate for the planning-case scenarios.  The analyses for the two planning-case scenarios for regulated substances are phosgene and chlorine.   
 
For the first a 
nalysis, we selected a phosgene release of 1,000 pounds from a pipe leak.  
 
For the second analysis, we selected a chlorine release of 10,000 pounds from the transfer pipe leak from a staged unloading railcar.   
 
 
 
Worst case Scenario Toluene Diamine Process Unit: 
At the Lyondell - Lake Charles Facility, a gas-phase scenario was selected from the Toluene Diamine process unit to evaluate for the worst case scenarios.  
 
For the analysis, a 2,000-pound chlorine release from a cylinder used for water treatment of the cooling tower.  
 
Planning-case (Alternate Release Scenarios) Scenario Toluene Diamine Process Unit: 
For the Planning-case scenario, a gas-phase scenario from the Toluene Diamine process unit was evaluated. 
 
For the analysis, a chlorine release from the transfer pipe of a 2,000-pound cylinder used for water treatment at the cooling tower was used. 
 
 
 
Worst case Scenario Luxate Process Unit: 
At the Lyondell - Lake Charles Facility, a liquid phase scenario from the Luxate proces 
s unit was evaluated.  The analyses for the single worst case scenario for a regulated substance is phosgene.   
 
For the analysis we selected a 3,663-pound phosgene release from a process vessel was used.  
 
Planning-case (Alternate Release Scenarios) Scenario Luxate Process Unit: 
For the Planning-case scenario, a liquid phase scenario from the Luxate process unit was evaluated.  The analysis for the planning-case scenario for regulated substance was phosgene. 
 
For the analysis, a 1,000-pound phosgene release from the transfer pipe was used.   
 
 
 
Worst case Scenario Nitric Acid Process Unit: 
At the Lyondell - Lake Charles Facility, a gas-phase scenario was selected from the Nitric Acid process unit to evaluate for the worst case scenario.  
 
For the first flammable analysis, a butane release from butane storage vessel.   
 
For the toxic analysis, a 312,000-pound ammonia release from a storage vessel was selected.  
 
Planning-case (Alternate Release Scenarios) Scenario Nitric Acid Process 
Unit: 
For the Planning-case scenario, three- (3) gas phase release scenarios from the Nitric Acid process unit were evaluated.  
 
For the flammable analyisis, a 7,200-pound butane leak from a pipe leak was used 
 
For the first toxic analysis, a 600-pound ammonia release from vessel overfilling activities was used.  
 
For the second toxic analysis, a 2,000-pound chlorine release from the transfer pipe interconnected to the chlorine cylinder was used.  
 
 
 
IV. The General Accidental Release Prevention Program and Chemical Specific Prevention Steps 
 
Efforts to reduce pollution and increase safety at the Lake Charles- Lyondell facility focus on several fronts. Lake Charles facility employees strive to develop technologies that minimize waste, install newer equipment that is more environmentally-sound, treat waste streams that are generated by their manufacturing processes, and develop and enhance their systems for analyzing and addressing risks that help the facility prevent incidents. 
 
Manu 
facturing Excellence: 
 
Driving Lake Charles facility safety and environmental improvements is Lyondell's Manufacturing Excellence initiative, which incorporates all of the Chemical Manufacturers Association's Responsible Care . codes and our own tough standards. Established in 1991and adopted at the Lake Charles facility in 1997 after the purchase from Olin, Manufacturing Excellence includes a total of 43 performance standards that cover specific areas of chemical manufacturing including safety and environmental performance, product quality, manufacturing reliability, and efficiency. Through Manufacturing Excellence, the Lake Charles facility has installed the processes, systems, and technology to identify problems, analyze their causes and define and implement solutions. 
 
Lyondell's Manufacturing Excellence standards complement one another, improve safety and environmental performance, while also leading to gains in efficiency and reliability. For example, by finding ways to reduce or 
eliminate waste from our manufacturing operations, we're able to improve raw material yields, an attractive bottom-line benefit.  
 
A major emphasis has been improving reliability and the percentage of time our plants are up and running. Besides reducing the chance for safety and environmental problems that occur during process upsets, shutdowns, and startups, improving reliability also reduces production costs. Our goal is a 99 percent reliability rate for our continuous process plants. Toward this end, we've strengthened preventive and predictive maintenance systems and have put in place resources focused on reliability at our manufacturing plants. Rigorous auditing process tracks how well our facility is meeting Manufacturing Excellence's high standards. Audit teams composed of experts from different Lyondell facilities and the corporate auditing group examines performance and documentation to make sure our standards are met.  
 
 
Chemical Manufacturers Association - Responsible Care 
. 
 
The Lyondell - Lake Charles facility is proud to be an active participant in Responsible Care . -- a Public Commitment. As a member of the Chemical Manufacturers Association, Lyondell supports a continuing effort to improve the industry's responsible management of chemicals. 
 
Process Safety: 
 
A new process safety effort is underway at the Lyondell - Lake Charles facility. Lyondell has implemented a strong inspection and maintenance program at Lake Charles to minimize the risk of a material release or other process upset. As part of a more than $100 million effort to expand toluene diisocyanate production at the plant, Lyondell is planning to replace the oldest part of the TDI unit and adding many significant safety enhancements. 
 
The effort at Lake Charles supplements Lyondell's ongoing programs to minimize the chance of an upset. Lyondell continuously examines the plant's operations for process safety hazards. Understanding these hazards helps ensure they are addressed through equ 
ipment design, operating procedures, training, maintenance, and emergency response.  Lyondell follows, at a minimum, the rigorous standards set by ASME in designing process vessels and process piping systems to minimize process safety hazards.  
 
The Lake Charles facility has a number of existing engineering controls, systems and operating practices, which, as a whole, provide protection against accidental releases. Some of these systems and operating practices are listed below. The following table provides examples of some of the existing controls, systems and practices. 
 
 
Engineering and Operational Controls: 
7 Fenceline gas monitors 
7 Automatic sprinkler systems 
7 Containment building 
7 Closed-circuit TV cameras 
7 Back-up power generators  
7 Redundant controllers 
7 Interlock systems 
7 Vent scrubbers to treat toxic off-gases 
7 Process containment building 
7 Remote isolation valves 
7 Process safety management program 
7 Double-walled containment vessels for critical equipment use for p 
hosgene 
7 Seal-less (canned-motor, diaphragm and magnetic drive pumps) and dual mechanical seal for process liquid transfer pumps 
7 Pipe specifications requiring welded construction 
7 Point-of-Discharge ventilation and treatment system (ET system) to reduce fugitive emissions from decontamination operations 
 
Administrative Controls: 
7 Trained and qualified personnel 
7 Standard operating procedures 
7 Aggressive inspection program of process equipment 
7 24-hour instrument monitoring 
7 Protective safety process 
7 Leak detection and repair program 
7 Vibration and spike energy analysis of critical equipment 
7 Personnel exposure monitoring badges 
7 100% X-ray of welds for critical service use 
7 Hydrostatic testing of piping systems 
7 Helium leak tests 
7 Portable foam for vapor suppression of liquid spill releases 
7 Within a 24-hour period, plant operators perform periodic inspections 
 
 
The Lake Charles operations undergoes a process hazard analysis (PHA) every five years and before any signi 
ficant process change. The PHA studies all factors that contribute to a plant's safety performance -- from plant design to its employee experience -- identifies potential hazards, and verifies that systems are in place to address the hazards. In addition, risk-screening studies at each of our plants have searched for hazards that have the potential to cause major accidents. Following these studies, a set of safety-critical variables were implemented for each location, covering such factors as reactor temperature, unwanted side reactions, or caustic solution flow to scrubbers which neutralize process toxic off-gases. These variables are continuously monitored to ensure that they are within a safe range. 
 
 
Contractor Safety: 
 
Lyondell - Lake Charles contractor safety management systems require our contractors to accept the same safety responsibilities and standards that apply to our employees. We have rigorous standards for evaluating their past performance and their safety management  
systems before they are hired. Once selected, every contractor must go through the appropriate training program for the job. Employees also monitor the contractor's safety performance and conduct unannounced audits to check compliance with safety policies and work procedures. Contractors are also evaluated at the end of a job or on a regular basis for those on-site for longer periods. 
 
 
Management System Verification: 
 
Lyondell Chemical was among the first US chemical producers to participate in the Management Systems Verification (MSV) process. In January 1997, an outside verification team evaluated the management systems in place to support Lyondell Chemical Responsible Care . efforts.  
 
The MSV process includes industry representatives, public participants, and a management system verification consultant evaluated Lyondell Chemical Responsible Care . management systems using the Chemical Manufacturers Association's protocol. The MSV focuses on processes for implementing Responsible  
Care . and evaluating the Facility's management systems necessary to ensure the sustainability and continuous improvement of Responsible Care ..  
 
Product Stewardship: 
 
Lyondell's product stewardship effort requires commitment from people inside and outside of the Lyondell organization. 
 
Product Stewardship is perhaps the most demanding of the Responsible Care . codes. Besides ensuring high standards for handling at our manufacturing sites, we also try to work closely with our suppliers, manufacturers, transporters, distributors, and customers. We also share ideas with other chemical companies through the Chemical Manufacturers Association's Product Stewardship committee. A successful Product Stewardship effort requires commitment from a wide range of people at Lyondell, including top management, sales and marketing personnel, logistic people, and safety and health professionals. Our business processes must make it possible for all of these groups to share ideas about potential risks a 
nd how to manage them. 
 
Over the past few years we've coordinated a major product stewardship effort for toluene diisocyanate (TDI).  Lyondell has undertaken a worldwide campaign to educate customers, distributors, and contracted transportation companies on the safe use of this product. 
 
When ARCO Chemical Company acquired the Lake Charles Facility in 1996 and Lyondell purchased the facility in 1998, a team of European employees developed a plan to ensure safe handling at customer sites. The team developed product safety bulletins, emergency handling brochures, a logistics code of practice, workshops, and training. In 1997, the Lake Charles Facility provided health and safety information to about 100 TDI customers in Western Europe, the Middle East and Africa. Similar efforts have taken place in Asia and the Americas. 
 
 
 
V. The Five Year Accident History 
 
The EPA requires that a 5-year history of certain releases be reported. A release must be from a process involving a regulated subs 
tance and have caused at least one of the following. 
 
7 On-site deaths, injuries, or significant property damage; or 
7 Known off-site deaths, injuries, property damage, environmental damage, evacuations or sheltering in place. 
 
The incidents listed below meet USEPA's criteria for reporting. 
 
7 September 14, 1994 - The muriatic acid accumulator vessel overpressured, releasing 374 pounds of hydrogen chloride and 36 pounds of phosgene. Two employees were hospitalized with one injury resulting in a fatality. The acid accumulator vent system was redesigned to prevent recurrence. 
 
7 April 1, 1995 - A pressure relief valve on an ammonia pump opened, releasing 280-420 pounds of ammonia. This resulted in a number of odor complaints from the Westlake community but no other on-site or off-site impact. This relief valve and other similar relief valves were inspected and repaired as necessary. 
 
7 September 29, 1995 - A pipe flange bolt failure released 14 pounds of liquid phosgene. Fourteen on-site 
employees were treated and released from area hospitals. Workers at a nearby facility were instructed to shelter-in-place as a precautionary measure. One worker at that facility was hospitalized. Root cause of the release was corrosion of the flange bolts. Corrective actions included metallurgical upgrades, improved bolt coatings, and increased inspection frequency of bolts in similar service. 
 
7 November 8, 1995 - Less than one pound of phosgene was released from a fugitive emissions control hose, exposing an operator who was hospitalized for observation. Other fugitive emissions control hoses were immediately inspected and repaired as necessary. 
7 June 22, 1997 - A crack in a liquid unloading line released 1,000 pounds of chlorine. One employee was treated on-site for exposure. Four workers at a nearby facility were also given first aid for chlorine inhalation. All returned to work after treatment. Root cause of the release was pipe failure due to stress. The chlorine unloading syst 
em was redesigned to prevent recurrence. 
 
 
VI. The Emergency Response Program 
 
Community Safety: 
Area industries work hard to ensure the safety of their employees, the community and the environment. While Lyondell continues to reduce the risk associated with our operations, emergency preparedness and community response are essential to the safety and well being of the community. 
 
We work closely with three community safety groups: 
 
Calcasieu Parish Local Emergency Planning Committee - Local Emergency Planning Committees were created by Congress through SARA Title III, the national Emergency Planning and Community Right-to-know Act. The act was signed into law October 17, 1986, as key legislation to help communities protect public health, safety, and the environment from chemical hazards. To implement this Act, Congress required each state to create a State Emergency Response Commission (SERC). The SERCs were required to divide their states into Emergency Planning Districts and name a  
Local Emergency Planning Committee (LEPC) for each district. 
 
The Calcasieu Parish Local Emergency Planning Committee was started in 1988. It was made up of mayors, public health officials, government, media representatives, environmentalists, and industry and union representatives. The Calcasieu Parish LEPC is the focal point for community emergency-response planning, evacuation studies, hazardous material transportation studies and public awareness campaigns, and has the responsibility to collect, manage and provide public access to information on hazardous substances within Calcasieu Parish. The Calcasieu Parish LEPC has been recognized for community emergency planning by the U.S. Environmental Protection Agency (EPA) and the Federal Emergency Management Agency. 
 
Community Awareness Emergency Response (CAER) - The CAER organization is a voluntary group of industrial safety representatives and municipal emergency responders. The organization was established in 1985. Through the CAER  
program, many of the emergency sirens in Calcasieu Parish were purchased. The CAER organization works closely with the Calcasieu Parish LEPC to provide funding for awareness projects, to assist with drills and to suggest ways of improving the Calcasieu Parish emergency-response plan. 
 
Southwest Louisiana Mutual Aid Association - The Southwest Louisiana Mutual Aid Association is one of the oldest organizations of its type along the Gulf Coast. This organization is made up of emergency responders from area municipalities, volunteer firefighters, law enforcement, medical providers and industrial representatives. The Mutual Aid Association provides equipment and assistance to member facilities during large-scale emergencies. 
 
People and Training: 
A good emergency-response team consists of several components. The first is professional and well-trained people. The second component is state-of-the art equipment. Lake Charles facility emergency-response personnel go through rigorous hazardous  
materials response training and fire brigade training at two of the best training facilities on the Gulf Coast. The Texas A&M Fire Training School is known around the world for its excellence in emergency-response training. The Louisiana State University Fire Training Center trains responders around the state and the Gulf Coast. The Lake Charles personnel train at each of these facilities. Lyondell also augment the site personnel training through the Southwest Louisiana Fire Training Center and on-site training. 
 
The Second Component is Good Equipment: 
The Lake Charles facility has a broad range of equipment and resources to use in the mitigation of emergency events. The following equipment is available for emergency situations: fire trucks, ambulance, diking supplies, deluge sprinkler systems, halon systems, stationary firewater monitors, water hydrants, fire extinguishers, emergency communication network and a hazardous material equipment trailer. 
 
Planning: 
A good emergency-response 
plan requires extensive planning and periodic drills. The Lake Charles facility has a full-time emergency-response coordinator, whose job it is to prepare people and equipment for emergency response. Our plan meets all the State and Federal requirements.  The facility coordinates the site's plan and drill with State and local agencies while working closely with the Local Emergency Planning Committee, local hospitals and other industries to ensure that the facility is ready to respond to an emergency on our plant site. 
VII. Planned Changes to Improve Safety 
 
Lake Charles facility has an on-going program that continuously strives to develop technologies that minimize waste, install newer equipment that is more environmentally-sound, treat waste streams that are generated by our manufacturing processes, and develop and enhance our systems for analyzing and addressing risks that help the facility prevent incidents. 
 
The Lake Charles Facility has a number of upcoming changes that are inte 
nded to improve reliability and safety.  Some of the proposed upcoming changes include: 
 
7 Chlorine area monitoring devices; 
7 Toluene Dissocyanate (TDI) area monitoring devices; 
7 New TDI Containment building; 
7 Chlorine handling and exposure reduced with the construction of transfer pipeline to the process; 
7 Critical equipment interlock upgrades; 
7 Additional scrubbers for toxic gas treatment; and  
7 Closed-loop sampling systems.
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