Occidental Chemical Corporation Ingleside Plant - Executive Summary |
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EXECUTIVE SUMMARY Occidental Chemical Corporation (OxyChem), a wholly owned subsidiary of Occidental Petroleum Corporation (OPC), is a leading producer of electrochemicals, proprietary products, plastics, and resins. Occidental Chemical Corporation's Ingleside Plant is an integral part of the OxyChem commitment to the industrial chemicals market. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES OxyChem is committed to operating the Ingleside Plant in a manner that is safe for its workers, the public and the environment. It is our policy to adhere to all applicable Federal, State and local rules and regulations, industry standards and best practices. As part of this commitment, OxyChem has established systems to help ensure safe operation of the processes at this facility, which includes the prevention of accidental releases of hazardous substances and emergency response programs. OxyChem is focusing on individual employee responsibilities for working safely and achiev ing the targets of zero safety and environmental incidents. This program includes training of all employees on the basic values and beliefs that all accidents and chemical releases are preventable and it is the responsibility of every employee to ensure that they are aware of the goals of zero incidents and will be held accountable for their actions. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The Ingleside Plant located on Highway 361 near Corpus Christi, Texas, produces important commodity chemicals such as chlorine, caustic soda, ethylene dichloride (EDC), and vinyl chloride monomer (VCM). The VCM Plant is a joint venture between OxyMar and OxyVinyls entities. The OxyMar portion of the VCM Plant is a joint venture between Occidental Chemical and Japan's Marubeni Corporation. The OxyVinyls portion is a joint venture between Occidental Chemical and Geon Corporation. OxyChem also operates a CoGeneration plant, which is a joint venture with Conoco Global Power, Inc. Oxy Chem operates all of the joint ventures at the site. The Ingleside Plant is strategically located on 1,071 acres along the Texas Coastal Bend with excellent dock, pipeline, and rail facilities. The site has eight regulated substances that are products, intermediates, or raw materials. Chlorine Ethylene Vinyl chloride Anhydrous Hydrogen Chloride Ammonia (anhydrous) Chloroform Propylene Ethyl Chloride OFF SITE CONSEQUENCES ANALYSIS SCENARIOS WORST-CASE TOXIC SCENARIO *The "worst-case release scenario" for chlorine is the failure of one of the chlorine storage tanks, which would release 690,000 pounds of liquid chlorine instantaneously. According to the EPA's OCA Guidance, the release would have off site impact. Storage tank failure is unlikely due to the high design standards and detailed inspection program assuring vessel integrity. WOR ST-CASE FLAMMABLE SCENARIO *The "worst case scenario" for vinyl chloride monomer (VCM) involves a VCM storage sphere that contains 14,000,000 pounds of VCM. The entire quantity of the tank is released and the VCM vapor cloud detonates. According to the EPA's OCA Guidance, the release would have off site impact. Sphere failure is unlikely due to the high design standards and detailed inspection program assuring vessel integrity. ALTERNATIVE TOXIC RELEASE SCENARIOS *Chlorine - The failure of a 1-inch unloading hose connected from a liquid chlorine tank car to the chlorine unloading header releasing 921 lbs. of chlorine in a 30 second period. The SAFER Trace 8.0 software was used for this scenario to determine the off-site consequences. *Ammonia - A high-pressure gas release caused by a 3/4 inch severed pipe at the ammonia storage tank located at Boiler #5. This high-pressure gas release lasts for 5 minutes before the Emergency Response Team can isolate the leak. A water fog system i s also used to mitigate the ammonia release. According to the EPA's OCA Guidance, the release would have off site impact. *Anhydrous Hydrogen Chloride (HCl) - A gasket leak on the discharge of the HCl column reflux pump at the VCM Plant. The liquid HCl release lasts for 20 minutes before operations and the Emergency Response Team can isolate the leak. The liquid HCl vaporizes and 4,860 pounds is released to the atmosphere. According to the EPA's OCA Guidance, the release would have off site impact. *Chloroform (trichloromethane) - An over pressurization of the light ends distillation column in the VCM Plant. The pressure relief valve lifts resulting in a release of chloroform of 1,814 pounds over in two minutes. According to the EPA's OCA Guidance, the release would have off site impact. ALTERNATIVE FLAMMABLE RELEASE SCENARIO *Vinyl chloride monomer (VCM) - A hose failure at the VCM ship dock due to hydrostatic pressure in the line. This scenario releases 1,300 pounds of liquid VC M, which then vaporizes and explodes. According to the EPA's OCA Guidance, the release would have off site impact. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PREVENTION STEPS The following sections briefly describe the elements of the Ingleside Plant's Program 3 prevention program that address EPA's RMP rule prevention program requirements. Each of the sections listed below are documented and maintained in two documents at the plant; The Plant Safety and Health Procedures Manual and The OxyChem Process Reliability Guidelines Manual. Each of these manuals is updated regularly. The Ingleside Plant's prevention program has been prepared for compliance with OSHA's Process Safety Management (PSM) and the EPA's Risk Management Rule (RMP) and consists of the following elements: Process Safety Information Pre-startup Review Managemant of Change Process Hazard Analysis Compliance Audit Mechanical Int egrity Operating Procedures Employee Participation Contractor Safety Training Hot Work Permits Emergency Response Incident Investigation Before using a hazardous substance at the Ingleside Plant, less hazardous alternatives are always considered. When a hazardous substance is used at the Ingleside Plant, OxyChem reviews the potential for an accidental release of this substance, which could adversely, affect plant workers, the public and the environment, and takes steps to prevent any such effects. This is accomplished through the facility's Management of Change (MOC), also referred to as the Technical/Engineering Assistance Request (TEAR) program, and Process Hazard Review (PHR) procedures, which are followed for all new installations or modifications of existing processes. The equipment is carefully designed, installed, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction and operation of the equipment. OxyChem also uses the Corporate Fire, Safety and Environmental (FS&E) Guidelines when designing new or modifying existing processes. In addition, OxyChem requires the documentation of standard operating procedures and training of affected employees with regard to these procedures as part of the MOC procedure. OxyChem'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. FIVE-YEAR ACCIDENT HISTORY A 180-pound chlorine release occurred on March 1, 1997. This release was the result of a low anolyte level in a diaphragm cell in the chlorine cell lines, which caused the over pressurization of the chlorine header. There were no off-site injuries and no environmental impact. The property damage caused by the over pressuriza tion was approximately $400,000. As a result of the incident, the Ingleside Plant revised chlorine cell line maintenance procedures, training for chlorine cell line operators, and chlorine cell line operating procedures. THE EMERGENCY RESPONSE PROGRAM The Ingleside Plant has established a written emergency response plan and maintains emergency response team (ERT)that is trained in these emergency response procedures. All plant personnel are trained in evacuation procedures and in-plant drills are conducted periodically. The drills are used to test the response time of the Emergency Response Team, to test the plant employee accountability program, and to activate the plant's Emergency Command Center (ECC). The Ingleside Plant has Chemical Emergency Response Program Team (CERP) available 24 hours per day to respond to in plant chemical emergencies. The plant's CERP team serves as the Chlorine Institute's CHLOREP (Chlorine Emergency Plan) Sector 26 Response Team for South Texas and re sponds to chlorine emergencies within this region. The team maintains a mobile chemical emergency command center equipped with the necessary equipment to respond to chlorine emergencies. The Ingleside Plant uses a SAFER Real Time modeling program to assess release impacts if any and to aid in the determination of response activity. The Ingleside Plant also has a community alert network (CAN) system available through the San Patricio Local Emergency Planning Committee (LEPC) to notify the public of a potential or actual hazardous situation. The CAN is a new telephonic public notification system, which alerts neighboring residents of events such as evacuations and sheltering in place. In addition, the Ingleside Plant has developed a Special Situations Plan (SSP) which is a program designed for responding to emergencies that may have impacts beyond the immediate plant and is a supplement to the Emergency Response Plan. The Special Situation Plan links the local response to the OxyChem C orporate Emergency Response Center located in Dallas, Texas, which can then provide assistance as, needed. The intent of the SSP is to aid the community after an event in order to return their quality of life back to normal as quickly as possible. The facility is also an active member of the San Patricio County Local Emergency Planning Committee (LEPC). PLANNED CHANGES TO IMPROVE SAFETY The Ingleside Plant constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, and a program soliciting safety and environmental suggestions from the plant employees. The key element of Ingleside's safety and environmental programs is prevention. Ingleside will continue to improve all its processes in order to prevent significant events from occurring in the future. |