CONDEA Vista Ethylene Underground Storage Facility - Executive Summary |
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LDEQ Facility ID Number (will be assigned) CONDEA Vista, Inc. Ethylene Underground Storage Facility Risk Management Plan Executive Summary CONDEA Vista's Ethylene Underground Storage Facility has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, training of highly qualified personnel, and considering safety in the design, installation, operation and maintenance of our processes. Our policy is to implement reasonable controls to prevent chemical releases. However, if a release does occur, our trained personnel will respond to control, contain, and mitigate the release. CONDEA Vista is committed to Responsible Care? voluntary initiative for safe management of chemicals. CONDEA Vista follows the Responsible Care? Code of Management Practice, which is integral to the implementation of the CONDEA Vista Environmental and Health and Safety policies. The Responsible Care? Community Awareness Code of Management Practice and CONDEA Vista's Community Awareness and Emergency Response policies are designed to assist emergency preparedness and to faster community right to know. CONDEA Vista's Ethylene Storage Complex, located in Sulphur, Louisiana, stores commercial grade ethylene for shipment by pipeline to various commercial users of ethylene. The Ethylene Storage Complex does not use, store, or produce any regulated toxics in sufficient quantity so as to be covered under RMP regulations. The only flammables used or stored in sufficient quantity at the Ethylene Underground Storage Facility so as to be covered under RMP regulations is ethylene and propane. The WCS (worse case scenario) associated with the release of ethylene due the catastrophic failure of the main 6 inch line feeding into the Ethylene Storage Salt Dome. The results of the failure for the main 6 inch line is the release of 27,523 pounds of ethylene. The released ethylene is assumed to vaporize and ignite resultin g in a vapor cloud explosion (VCE). The look up tables published by USEPA were used to determine the maximum distance to the 1 psi overpressure endpoint of 0.24 miles. The alternative case scenario (ARS) for flammable substances at the Ethylene Storage Complex is the release of 10,000 pounds of ethylene due to the failure of a 1.0 inch nozzle. The failure of this nozzle would result in the release of 10,000 pounds of ethylene over a 10 minute time period. The 10 minute time period represents the time required to block in, isolate, and empty the process line, thus stopping the leak. The release is assumed to result in a VCE. The distance to the 1 psi overpressure endpoint for this ARS scenario is 268.7 feet (.05 miles). Process Safety Information The Ethylene Storage Complex maintains a variety of technical documents that are used to help maintain safe operation of the complex. These documents address chemical properties and associated hazards, limits for key process parameter s, specific chemical inventories, and equipment design basis/configuration information. Specific departments are assigned responsibility for maintaining up-to-date process safety information. Employees are provided training on how to locate the information from various computer terminals and paper files located at the Ethylene Storage Complex. Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS). This information is supplemented by documents that address known concerns and known hazards associated with inadvertent mixing of specific chemicals. The complex has documented safety related limits for specific process parameters (e.g. temperature, pressure, composition, etc.). The complex ensures that the processes are maintained within these limits using process controls, monitoring instruments, protective instrument systems, and highly trained personnel. The Storage Complex a lso maintains an electronic database, that is accessible by both employees and contractor supervision, which provides information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical classification, etc. This information in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis The Ethylene Storage Complex has a comprehensive program to help ensure the hazards associated with the handling of ethylene are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Storage Complex primarily uses the hazard and operability (HAZOP ) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are made available to people associated with the Storage Complex for comments and forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest rank receive immediate attention. All approved mitigation options being implemented in response to PHA f indings are tracked until they are complete. The final resolution of each finding is documented and retained. Operating Procedures Operators, supervisors, and engineers work together to develop and maintain operating procedures. These procedures define how tasks related to process operations are safely performed. At the Lake Charles Chemical Complex (LCCC), 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, ? Safety and health considerations, such as chemical hazards, personnel protective equipment required and steps to take if exposed to a particular chemical. Storage Complex personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operation, normal shutd own, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. Training The Ethylene Storage Complex trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training. All new operators receive six weeks of comprehensive training before ever being assigned to the operating unit. This training includes training on specific types of equipment, such as pumps and compressors, general overview of the process, properties and hazard substances in the process, detailed review of complex procedures, such as, safe work practices and emergency response. Oral reviews, hazardous demonstrations, and written tests are used to verify that employees understand the training material before a new employee can report to the unit. Once a new employee reports to the unit, he receives detailed training with respect to process specific procedures. Once the new hire has demonstrated, through oral review and written tests, mastery of process specific operating procedures and for specific tasks, he is allowed to begin work in the unit. Refresher training covers (1) a general overview of the complex, (2) the properties and hazards of the substances in the complex and, (3) a detailed review of the complex operating procedures and safe work practices. Oral review and written tests are used to verify that employees understand the training before an employee can resume work in the complex. The operators have been consulted in safety meetings and through questionnaires regarding effectiveness and frequency of training. Recommendations are reviewed and changes to the training program are implemented as appropriate. Management of Change The Management of Change program for the Storage Complex evaluates and approves all proposed changes to chemicals, equipment, and procedures to help ensure that a 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 a full management of change program to help ensure process safety information and procedures are updated, and affected employees are notified of the change. Pre-Startup Safety Review (PSSRs) The Ethylene Storage Complex conducts a safety review of a new or modified process before the process is placed in service. The purpose of the PSSR is to ensure the safety features, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment in service. The review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the constructio n and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The Ethylene Storage Complex has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, emergency shutdown systems, and rotating equipment (pumps and compressors) in a safe operating condition. The basic aspects of this program include (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies and, (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on (1) an overview of the complex, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices. Written procedures help ensur e that work is performed in consistent manner and provides basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g. adequate wall thickness for pressure vessels). If a deficiency is identified, the equipment will be repaired in a timely manner. All outstanding deficiencies are tracked until such time a final solution has been implemented and documented. Another integral part of the mechanical integrity program is quality assurance. The Storage Complex incorporates quality assurance into equipment purchase and repairs. This helps ensure that new equipment is suitable for intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The Ethylene Storage Complex has a long-standing safe work program in place to ensure worker safety. Examples of the program include (1) control of the entry/presence/exit of support personnel, (2) lockout/tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedures to conduct spark producing activities (i.e, hot work), and (5) a permit and procedures to ensure that adequate precautions are in place before entry into a confined space. These procedures, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Incident Investigation The Ethylene Storage Complex 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. The complex trains employees to identify and report any incident requiring investigation. The investigation is initiated within 48 hours of the incident. Depending on the incident, an investigation team may be for med. Results of the investigation are documented and appropriate changes are made. Employee Participation The Ethylene Storage Complex maintains a written employee participation program to help ensure that safety and environmental concerns of the plant workers are addressed. The plant encourages active participation of personnel in safety, health, and environmental activities at the plant. Employees are consulted and/or informed about all aspects of the RMP prevention program including PHA's (Process Hazard Analysis) and operating procedures. Compliance Audits The Ethylene Storage Complex audits the complex to be certain that the prevention program is effectively addressing safety, health, and environmental issues. The complex assembles an audit team that includes personnel knowledgeable in the complex. This team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to ensure safe operation of the com plex. The results of the audit are documented, recommendations are resolved, and appropriate enhancements made to the operations of the Storage Complex Contractors The Ethylene Storage Complex has established a program to help ensure that contractor activities are performed in a safe manner. This program reviews the safety record of the contractors to ensure the complex only hires contractors who can safely perform the desired task. The complex communicates to the contractor supervisor the hazards of the process on which they and their employees will work, the complex safe work practices, and the complex emergency response procedures. The complex requires that the contractor supervisors train each of their employees on hazards and procedures specific to the complex site. The complex periodically reviews contractors training documents and work performances to help ensure that safe practices are followed. Five Year Accident History The complex has experienced no events in the p eriod of June 1994 to present, which are reportable under RMP regulations. Emergency Response Program The Ethylene Storage Complex emergency response program 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 1910.120 (q)-Hazardous Waste Operations and Emergency Response (HAZWOPER) ? OSHA 29 CFR 1910.119 (n) Process Safety Management of Highly Hazardous Chemicals ? OSHA 29 CFR 1910 Subpart L-Fire Protection ? LADEQ LAC 33.1? 3901- Notification Regulations for Unauthorized Discharge ? LDPS Title 33, Part V, Subpart 2, Ch.101? 1011-Release Reporting ? EPA 40 CFR Part 302.6- Notification Requirements ? EPA 40 CFR part 355.40-Emergency Planning and Release Notification ? EPA 40 CFR Part 68- Risk Management Programs for Chemical Accidental Release Program ? EPA 40 CFR Part 355.30- Facility Coordinator and Emergency Response Plan ? EPA 40 CFR Part 112- Spill prevention, Control and Countermeasures Plan ? EPCRA 302- List of Extremely Hazardous Substances The emergency response strategy for the Ethylene Storage Complex is to prevent and/or control emergency situations via the use of engineering , design, and fixed protection systems. The complex has an Emergency Response Team that is available 24 hours per day, and trained to respond and take actions to contain, control, and mitigate any release that might occur. The team has access to on-site emergency equipment which is appropriate for situations that could possibly occur at the complex. In addition to the considerable on-site resources, the complex is a member of Calcasieu Mutual Aid. This membership allows the complex (if needed) to draw on the emergency response resources of other industries in the immediate area. The following is a partial listing of the equipment which is available for emergency response: Firepumps w/ fixed firewater system Fire Monitors Fire Extingui shers Dry Chemical Truck Foam Pumper Emergency Response Team Drills are conducted to assess the emergency response effort at the complex. The CONDEA Vista Company Ethylene Storage Facility is a participant in the community planning process cooperating with the Calcasieu Parish Local Emergency Planning Committee. A copy of the complex's Emergency Response Plan has been forwarded to the Office of Emergency Preparedness per the requirements of 40 CFR 355. Planned Changes to Improve Safety The Ethylene Storage Complex constantly strives to improve safety and reduce risk through auditing, suggestions from employees, incident investigations, and the use of proper engineering standards and specifications. |