Chevron Phillips Chemical Company LP - Executive Summary |
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INTRODUCTION The chemical manufacturing industry synthesizes many products which provide benefits enjoyed by our society. These include plastics, adhesives, paints, fuel additives, and agricultural chemicals just to name a few. The manufacture of many of these products unavoidably uses substances regulated under the Environmental Protection Agency (EPA) Risk Management Program (RMP) Rule (40 CFR 68). In using, storing and handling these regulated substances, Chevron Phillips Chemical Company's Orange, Texas facility recognizes the potential for community and environmental receptors exposure. Because of concern over the potential impacts of accidental releases to the community and the environment, the Orange, Texas Facility's Management is committed to full compliance with the requirements of the EPA RMP Rule. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Chevron Phillips Chemical Company's Orange, Texas Facility management demonstrates its commitment to safety a nd the environment by enforcing Chevron Phillip's Corporate Policy 530/MCPG. Policy 530/MCPG states that the Company will conduct scientific hazards assessments in order to identify, characterize, and safely manage any potential hazards of company operations. Additionally, the Orange, Texas facility demonstrates its commitment to process safety management through active implementation of the Chemical Manufacturers Association (CMA) Responsible Care Program. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Chevron Phillips Chemical Company's Orange, Texas Facility located on FM 1006, Orange, Texas, manufactures high density polyethylene plastics. These plastics are used to manufacture consumer products such as milk bottles, plastic piping, and other plastic products. The manufacture of high density polyethylene plastics at the Orange, Texas Facility require the use of the following regulated chemicals: Ethylene - Ethylene gas (CAS 74-85-1) is the primary raw material in the ma nufacture of high density polyethylene plastics. Ethylene molecules polymerize under the presence of a catalyst or an initiator to form polyethylene. Isopentane - Isopentane (CAS 78-78-4) is used to prepare a catalyst mixture which is used in the manufacture of high density polyethylene. Isobutane - Isobutane (CAS 75-28-5) is a diluent or carrier agent used in the manufacture of high density polyethylene. This substance is not generally involved in the chemical polymerization reaction. Propane - Propane (CAS 74-98-6) is used in the high density polyethylene manufacturing process as a refrigerant. Propane is used to condense various substances in the process such as ethylene, isobutane and isopentane. n-Butane - n-Butane (CAS 106-97-8) comes in mixed with the isobutane which is used as a diluent in the manufacture of high density polyethylene. Quantities Handled or Stored Isopentane: 210,000 lbs Ethylene: 120,000 lbs Isobutane: 780,000 lbs Propane: 280,000 lbs n-Buta ne: 440,000 lbs WORSE CASE RELEASE SCENARIOS Toxic Worse Case Scenario: The Chevron Phillips Orange, manufacturing facility has no listed toxics above Threshold Quantity. Flammable Worse Case Scenario: The Worst Case and Alternate Case Flammable scenarios for the Orange, Texas facility by EPA definition is a vapor cloud explosion of the single vessel with the greatest amount of flammable material. For the Orange plant, the vessel with the potentially largest quantity of flammable material is V-501, containing 240,000 lbs. of isobutane. Using the EPA look-up tables, the distance to a 1.0 psi blast overpressure is predicted to have off site impacts. ALTERNATIVE RELEASE SCENARIOS Toxic Alternative Release Scenario Chevron Phillips Orange Chemical Plant has no listed toxic materials above Threshold Quantity. Flammable Alternative Release Scenario Some specific scenarios that were analyzed include: 1. Release of a flammable material and forming a flammable vapor cloud 2. Release of a flammable material and igniting, which forms a jet fire. 3. Vapor cloud explosion, with a lower yield factor than for worst case. 4. BLEVE, (Boiling liquid expanding vapor explosion). The above scenarios were analyzed for all the flammable materials, (isopentane, ethylene, isobutane, & propane). Scenarios types 1 & 2 did not go off-site and would not be candidates for submitting as an alternative release scenario. It was decided that a VCE would be a more likely incident, (even though a very low probability), than a BLEVE. The vessel with the longest distance for a vapor cloud explosion is V-501, with a quantity of 51,270 gallons. The calculated distance to a 1.0 psi blast overpressure is predicted to have off site impacts. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The facility complies with the requirements of the OSHA PSM Standard (29 CFR 1910.119). The management systems used to comply with the OSHA PSM requirements comprise the accidental release preven tion program for this facility. In general, the accidental release prevention program includes programs in the following general categories: Safety In Design ? Use of applicable codes and CCC Technology Standards meet or exceed regulatory standards ? Materials of construction are chosen to provide mechanical integrity ? Fire water monitors are strategically located ? Pumps and compressor systems are designed to minimize releases ? Tanks are nitrogen purged to reduce the potential for a fire or explosion ? Unloading hoses are designed to resist chemical attack ? Backflow from tanks is minimized by use of check valves ? Equipment is electrically grounded to prevent sparks ? Dikes, curbs and drains are designed to collect/contain spills Safety In Operations ? Operational Safety Standards are incorporated into procedures and facilities as appropriate ? Operators are trained on proper unloading procedures ? Technical resource people are available around the clock ? Trucks meet DOT spe cifications ? Industrial Hygiene and air emission monitoring programs are used to detect leaks and check air quality ? The area has undergone a Process Hazards Analysis Maintaining The Facility ? Maintenance personnel are trained and experienced ? Contractors are trained and qualified ? Preventive testing and inspection of critical equipment is done routinely per procedures ? Technology and equipment/process documentation exist to promote facility integrity Auditing Our Operations ? Routine safety inspections are conducted ? Corporate audits are conducted every three years ? Process designed changes are reviewed before startup ? Investigations are held on all incidents & accidents Five Year Accident History Our five year accident history shows that no accidental releases of any of the covered chemicals has occurred that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, significant property damage, or environmental damage. EMERGENCY RESPONSE PROGRAM The facility has a written emergency response procedure which has been coordinated with local emergency response agencies. In general, the emergency response procedure includes the following: ? Plant Emergency Response Plan is in place and updated periodically ? Certified Emergency Medical Technicians (EMTs) are available on each shift ? Plant Emergency Response Team members attend fire school annually ? Plant participates in community drills ? Facility emergency response drills are conducted at least twice per year ? Participation in Orange County's mutual aid network ? Emergency alarm is activated by on-site personnel ? Plant Emergency Incident Command System is activated in the event of a release ? Plant emergency response is immediate ? LEPC, EPA, TNRCC, local hospitals, and county officials are notified as appropriate ? "ALL CLEAR" signal is activated notifying the plant and community that conditions are safe. PLANNED CHANGES TO IMPROVE SAFETY Changes to the facility are typically done to address concerns surfaced by Process Hazards Analysis, incident investigations and audits. In general, these changes include: ? Routine updating of Operating Procedures ? Installing automatic shutdown systems and controls ? Reviewing Safety Procedures as needed ? Removing obsolete equipment |