Celanese Calvert City Plant - Executive Summary |
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Celanese Ltd Risk Management Plan Executive Summary 1. Accidental release prevention and emergency response policies: The Celanese Ltd. Plant, which is located on 246 Johnson-Riley Road in Calvert City is a Program 3 facility in the Environmental Protection Agency's (EPA) Risk Management Plan (RMP). The largest feedstock, Vinyl Acetate Monomer (VAM), is used in the production of polyvinyl alcohol (PVOH). VAM, in the quantities handled at this facility, is considered hazardous by EPA under the Risk Management Rule. Celanese is committed to continuous improvement in all aspects of safety and environmental performance. It is our policy to adhere to all applicable Federal, Commonwealth of Kentucky and local rules and regulations. The Celanese Site Director at the Calvert City plant is responsible for facility operation. The Celanese Site Services Leader reports to the Site Director and has overall responsibility for compliance with all aspects of the facility's Risk Manag ement Plan. Celanese Environmental, Health and Safety (EH&S) operates under a tiered Management System, with policies and procedures cascading from Corporate requirements to detailed plant operating and safe work practices. As a member of the American Chemistry Council (ACC), Celanese subscribes to the Responsible Care Program. As a site that is in compliance with the OSHA Process Safety Management (PSM) regulation, the Calvert City plant strives to prevent chemical emergencies. Prevention of chemical emergencies includes specifying that all equipment, piping, vessels, tanks, etc. meet all applicable design codes and specifications. Documentation of these codes and specifications form the basis of our process safety information including flow diagrams, piping and instrument diagrams, process descriptions, and other documentation. Trained and qualified employees work with sophisticated control systems that include instrumentation, alarms and shutdowns to keep our processes ope rating in safe limits that minimize adverse impacts on the employees, the surrounding community and/or the environment. Operating instructions, start-up/shutdown instructions and consequences of deviation define required operating conditions and steps needed to control normal and out of normal conditions. Under PSM, employee involvement in all aspects of plant operations, its safety and environmental programs is required and met at the Calvert City plant. Employees are regularly trained, certified, and subject to random substance abuse checks to ensure the safety of the plant. Our safety process contains many other elements including management of change, hot work procedures and regular process hazards analysis using the hazard and operability (HAZOP) tool. All contractors working at the plant are subject to the same rules and procedures that Celanese employees must follow under the contractor safety program. The emergency response plan includes Occupational Safety an d Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPPER) training and qualifications for on-site employees. Celanese participates in a partnership among the Calvert City area industries named the Calvert City Industrial Mutual Aid Program or CIMAP. This organization collaborates with community emergency responders and citizens to form a strong Local Emergency Planning Committee or LEPC. This document has been prepared in accordance with the EPA's RMP regulation (40 CFR Part 68). The substances and processes considered during the preparation of this document, the scenarios described, and modeling techniques selected were chosen based on the criteria established in the regulation. 2. The stationary source and regulated substances handled: The stationary source is the Celanese PVOH plant located on 246 Johnson-Riley Road in Calvert City, Kentucky. The only RMP covered process is the Polyvinyl Alcohol production unit. In the PVOH unit, V AM is polymerized in a solvent to make polyvinyl acetate (PVAc). PVAc is converted to polyvinyl alcohol (PVOH), which is ground to a granule, dried, stored, packaged and shipped in bags, trucks and railcars. PVOH is a water soluble powder that is used in applications such as water-based adhesives and to protect fibers as they are woven into fabrics. The regulated substance handled at this stationary source is: ? Vinyl Acetate with the maximum quantity in an individual storage tank of 118,075 pounds 3. The worst case scenarios and alternative release scenarios, including administrative controls and mitigation measures that limit the distance for each reported scenario: In the plant, the greatest VAM inventory is contained in one of three storage tanks. Under worst case conditions of a single tank failure, the entire contents of the tank would be released from the tank and be contained in an earthen dike around the tanks. Using the EPA look-up tables for rural terrain, the vaporized VAM would spread to endpoint that would exceed plant boundaries. Although there are active controls directed at preventing such a release and controlling the consequences, no credit was taken for active mitigation methods in evaluating this Worst Case Scenario. The alternative case for a toxic liquid at the plant is the overpressure of a PVOH polymerization reactor and a subsequent VAM release from the pressure relief system. It was calculated that 5,900 pounds of VAM were released and vaporized to the environment. Using the EPA lookup tables and default weather conditions, the radius to the endpoint would exceed plant boundaries. Even though the EPA methodology would allow credit for active mitigation methods, no such credit was taken. The PVOH polymerization reactors are provided with safety systems, including: computer control and monitoring of all process parameters, dilution methanol addition, DEHA reaction stopper injection, cooling water, dual pressure relief systems and a catch tank or vent collection system. If any or all of these prevention systems operates as designed, the radius to the endpoint would be significantly reduced. 4. The general accidental release prevention program and specific prevention measures: Key to the plant's prevention programs are the layers of protection provided at each process. The hierarchy starts with the facility design and construction which is to all applicable design standards using qualified engineers and contractors. A comprehensive mechanical integrity program includes routine checks of all process equipment, tanks, vessels and piping. These checks are done using nondestructive testing techniques and kept in the permanent equipment files. Trained operators working with current operating procedures and process safety information keep the processes operating safely and in environmental compliance. Control systems and instrumentation provide the tools to keep the process within these limits and provide the information and control to properly operate each process in normal, startup/shutdown and emergency conditions. Instrumentation alarms alert plant operators to deviations and provide early warning to process upsets. In the event an upset leads to an uncontrolled condition, process safety devices including critical interlocks that activate automatic shutdowns, pressure relief valves, rupture disks, and flame arrestors are in place to safely control upset conditions. Process areas are covered by fire sensors and flammable vapor sensors, fire sprinklers systems, monitor nozzles, dry chemical extinguishers, etc. Containment dikes around storage tanks and process areas are curbed to contain small spills and direct them to drains to the plant's chemical sewer and the wastewater treatment plant. Each process design is subject to detailed process hazard reviews during design, construction and startup. All process changes must be reviewed and approved under a detailed Management of Change procedure before any changes are made. At periods not to exceed five years, Operational Plant Hazard reviews are conducted by multi-disciplinary teams. The elements of the prevention program are audited regularly at the plant and corporate levels. These audits are documented as part of the basic safety process with corrective action defined and tracked through the plant management systems. 5. Five year accident history: Neither the stationary source nor the covered process at the Celanese plant at Calvert City has had an incident in the last five years that would be reported under RMP. Previously the facility was operated by Air Products and Chemicals, Inc. There have been no releases of VAM that have had any off-site consequences, resulted in any employee injuries, or resulted in any significant equipment damage. 6. The emergency response program: The facility's emergency response program is operated jointly with its neighbor, Air Products and Chem icals, Inc. and is based on the OSHA HAZWOPER standard. There are at least 16 trained emergency responders in the fire and rescue squad that are divided into shifts and day workers. Each shift has a fire and rescue squad that is led by the shift safety officer. In an emergency, the safety officer assumes on-scene command of any incident. On-site emergency resources include a fire/foam truck, a rescue truck and ambulance. In addition to these resources, Celanese is a member of the Calvert Industrial Mutual Aid Program (CIMAP) and can count on pooled resources from surrounding plants and communities. As a member of the LEPC, Celanese regularly stages emergency response drills both in-house and outside with emergency responders from the public and private sector. LEPC members and other emergency responders regularly tour the facility to familiarized themselves with the plant, its hazardous materials, equipment, layout, personnel and emergency procedures. 7. Planned changes to im prove safety: The process safety information and systems are evaluated regularly through Plant Hazard Reviews and with industry-wide changes in standards and as a result of incidents that have occurred within the chemical industry. The PVOH polymerization reactors and mitigation systems have no outstanding recommendations. The emergency notification and response systems are composed of a siren system that is activated by the 911 operator backed up by the safety officer at Air Products. In the event of an emergency, 911 would activate the sirens and voice control modules that are placed in public buildings such as the Convalescent Center, City Hall and the Calvert Elementary School. Once a citizen has heard the siren, they are to turn their radio on the local Calvert City station (WCCK) and listen for specific instructions. The sirens are routinely tested one day per month and training in the community has been ongoing for almost one year. |