Lyondell - Channelview Plant - Executive Summary

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EXECUTIVE SUMMARY 
 
 
 
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
At the Lyondell - Channelview Plant, we are committed to operating and maintaining our processes (especially those using hazardous substances) in a safe and responsible manner.  We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment.  This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 
 
-A description of our facility and use of substances regulated by EPA's RMP regulation 
-A summary of results from our assessment of the potential off site consequences from accidental chemical releases 
-An overview of our accidental release prevention programs 
-A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 
-An overview of our emergency respon 
se program 
-An overview of planned improvements at the facility to help prevent accidental chemical releases from occuring and adversely affecting our employees, the public, and the environment. 
 
STATIONARY SOURCE AND REGULATED SUBSTANCES 
 
Our facility produces a number of products that include propylene oxide (PO), styrene monomer (SM), methyl tertiary butyl ether (MTBE), polyether polyols, and an assortment of products from the butanediol unit, including allyl alcohol.  A variety of chemicals and processes are used to produce these products.  There are two PO/SM units, one MTBE unit, one Polyols unit, and one BDO unit on site.  These units/processes use the following chemicals that the EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release: 
 
TOXICS 
 
Propylene Oxide (PO): Approximately 35.2 million lbs are on-site based on storage, production, and use.  PO is the major product of the facility and is also a 
feedstock for the polyols (AA) and BDO Units. 
 
Allyl Alcohol (AA): Approximately 4.5 million lbs are on-site, based on storage and production.  AA is a product produced in the BDO Unit. 
 
Ethylene Oxide (EO):    Approximately 1.54 millions lbs are stored and used on-site.  EO is a primary feedstock of the Polyols Unit. 
 
FLAMMABLES 
 
Propylene:  Approximately 950,000 lbs are stored and used on-site.  Propylene is the primary feedstock for both PO Units. 
 
Propane:  Approximately 75,000 lbs are stored and used on-site.  Propane is a chemical used in the production of PO. 
 
Methylamine:  Approximately 740,000 lbs are stored and used on-site.  The methylamine is stored in an aqueous solution that is approximately 40% MA and 60% water.  MA is a feedstock in the Butanediols Unit. 
 
Ethylene:  Approximately 71,000 lbs are contained in a pipeline and used as a primary feedstock in the production of ethylbenzene in both PO/SM Units. 
 
Isobutylene: Approximately 414,000 lbs are contained in a surge drum 
in the MTBE Unit.  Isobutylene is an intermediate chemical used in the production of MTBE. 
 
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 
 
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS 
 
EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility.  The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: 
 
REGULATED TOXIC CHEMICALS 
 
Worst-case Scenario - Propylene Oxide 
 
The worst case scenario for propylene oxide (PO) assumes the complete rupture of the largest PO storage tank releasing 17,250,000 pounds of liquid PO into a containment dike, leading to a vapor cloud release.  This release would impact off-sit 
e public receptors. 
 
Credit was taken for the containment dike (passive mitigation), the entire contents of the tank were contained, reducing the amount of PO released to the atmosphere. 
 
Alternative Release Scenario - Propylene Oxide 
 
The alternative release scenario for propylene oxide assumes failure of a 6" loading hose or loading arm.  This release scenario also assumes the release would not be controlled for 15 minutes and all active safety systems fail including the emergency shutdown.  The total release would be 20,200 pounds of PO, the vapor could would extend past the fence line and impact neighbors closest to the fence line. 
 
Credit was not taken for safety systems in place that would minimize the release.  These systems include: 
 
-Emergency shutdown switches 
-Drains that lead to a chemical sump 
-Water spray/sprinkler system 
-Deluge system 
-Remote isolation valves 
-Emergency Team response 
 
Alternative Release Scenario - Allyl Alcohol 
 
The alternative release scenario for all 
yl alcohol (AA) assumes failure of a 6" loading hose or loading arm.  This release scenario also assumes the release would not be controlled for 15 minutes and all active safety systems fail including the emergency shutdown.  The total release would be 21,500 pounds of AA, the vapor cloud would extend past the fence line and impact neighbors closest to the fence line. 
 
Credit was not taken for safety systems in place that would minimize the release.  These systems include: 
 
-Emergency shutdown switches 
-Drains that lead to a chemical sump 
-Water spray/sprinkler system 
-Deluge system 
-Remote isolation valves 
-Emergency Team response 
 
Alternative Release Scenario - Ethylene Oxide 
 
The alternative release scenario for ethylene oxide (EO) assumes failure of a 6" loading hose or loading arm.  This release scenario also assumes the release would not be controlled for 15 minutes and all active safety systems fail including the emergency shutdown.  The total release would be 19,900 pounds of E 
O, the gas could would impact public receptors.  
 
Credit was not taken for safety systems in place that would minimize the release.  The systems include: 
 
-Emergency shutdown switches 
-Drains leading to a chemical sump equipped with a spray system to knock down vapors 
-Check valves 
-Water spray/sprinkler system 
-Deluge system 
-Emergency Team response 
 
REGULATED FLAMMABLE CHEMICALS 
 
Worst-Case Scenario - Isobutylene 
 
The worst case scenario for flammables assumes the complete rupture of the isobutylene surge drum, releasing 414,000 pounds of isobutylene into an undiked area, leading to a vapor cloud explosion and overpressure.  The overpressure would extend past the fence line and impact neighbors closest to the fence line. 
 
Alternative Release Scenario - Propylene 
 
The alternative release scenario for flammables assumes a flange separation on a 12" propylene recycle line.  This release scenario also assumes the release would not be controlled for 15 minutes and all active safety system 
s fail.  The total release would be approximately 163,000 pounds of propylene, leading to a vapor cloud explosion and overpressure.  The overpressure would be contained on-site, but would have an impact on a cogeneration facility owned by a different company and located on-site. 
 
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 
 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals.  Our management systems address each of the key features of successful prevention programs including: 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
Process Safety Information:  Chemical hazard, process technology, and equipment information is documented, maintained up-to-date, and available to operating personnel. 
 
Process H 
azard Analysis:    A rigorous practice of reviewing new processes or changes to existing processes at the design stage to identify and mitigate potential safety, health, and environmental issues before the process is installed and operated.  Scheduled process hazard/risk reviews are conducted to revalidate initial process hazard reviews on a periodic basis.  Process hazard analyses are conducted every five years to identify major process hazard scenarios and to recommend corrective action(s) needed to prevent their occurrence. 
 
Operating Procedures:  Operating procedures provide detail on how to safely operate a process and are maintained up-to-date.  Operating procedures are based on process hazard/risk reviews.  The procedures include emergency shutdown and safe start-up methods. 
 
Operator Training/Certification Program:  The plant has a training and testing program which provides operators with the proper skills and knowledge prior to allowing them to independently operate a process 
.  Operator recertification is required. 
 
Computerized Process Simulation:  Computerized process simulation programs are used for training and troubleshooting including emergency shutdown and safe start up situations. 
 
Maintenance Procedures:  The plant has specific procedures for maintaining process equipment so that it operates safely.  Plant and unit specific procedures for servicing operating equipment are in place, including preventative maintenance and reliability programs. 
 
Maintenance Training:  The plant trains and tests mechanics and craftsmen who perform routine or complex maintenance tasks on process equipment and inspections on operating equipment to ensure they have the required knowledge and skills. 
 
Mechanical Integrity Program:  Vessels (including shipping containers) and other process equipment are periodically tested and inspected to ensure safe operation of process equipment, following recognized standards and/or government requirements.  This program includes testi 
ng, inspection and maintenance of critical equipment, including pressure relief devices, hoses, piping, instruments, and shutdown systems. 
 
Quality Assurance:  The plant has a system to ensure that purchased equipment and materials meet established engineering standards and specifications. 
 
Process Change Authorizations (Management of Change):  The plant has a management system to ensure that modified facilities and processes are safe for operation.  Design and pre-startup safety reviews are conducted for facility or process changes before the changes are implemented. 
 
Checkout & Custody Transfer (Pre-Startup Safety Reviews):  Reviews are conducted just prior to start up to ensure that modified facilities and processes are safe for operation. 
 
Incident Investigation:  The plant has a program to ensure accidents, incidents, and near miss events are properly investigated to determine the Root Cause(s) and Contributing Cause(s), and to implement corrective action(s) that are needed to pre 
vent recurrence. 
 
Employee Participation:  The plant has a program to involve employees in prevention program elements.  Also, each operating area has representatives on the Plant Safety Committee.   
 
Hot Work Permit:  Protects employees and property by preventing fires and explosions.  It ensures, among other things, that no flammable materials are present when an open spark or flame may be present for maintenance activities.  The plant has a procedure to ensure that welding, cutting and brazing are safely performed in areas where flammable or combustible material may be present. 
 
Line Breaking:  Requires isolation and draining of lines to be opened, preventing accidental releases or opening the wrong line. 
 
Compliance Audits:  Periodic corporate led and plant led audits are conducted to ensure that process operations comply with governmental and Lyondell requirements.  RMP compliance audits will be combined with PSM compliance audits. 
 
Contractor Safety Program:  The plant has a prog 
ram to ensure that contractors are properly trained and perform their work in compliance with safety requirements.  Contractors must meet rigorous safety performance requirements before being allowed to work on process equipment.  Contractor employees and regular plant employees must follow all of the same plant safety procedures and requirements. 
 
Equipment Design:  Vessels (including shipping containers) and other process equipment are designed according to recognized industry standards and/or governmental requirements. 
 
Manufacturing Excellence Standards:  Rigorous corporate standards that we follow to ensure that we operate our facilities in a safe and environmentally sound manner.  Our compliance to these standards is routinely audited by corporate experts.  We have Manufacturing Excellence Standards in the following areas:  Environment, Health and Safety; Technical; Operations; Maintenance; Transportation and Storage; Quality; and Purchasing.  Manufacturing Excellence is Lyondell 
's comprehensive program to ensure that all the elements listed above are implemented and maintained at every Lyondell facility.  This program includes accountabilities for timely and proper implementation of the program elements. 
 
These general prevention elements and the chemical specific steps discussedooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooo 
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