DSM Copolymer, Baton Rouge Plant - Executive Summary |
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1395 LDEQ Facility ID Number DSM COPOLYMER, INC, BATON ROUGE, LA -- EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES DSM Copolymer's Baton Rouge plant has a Iong-standing commitment to protection of the health and safety of its employees and the public. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and emphasizing safety in the design, installation, operation, and maintenance of processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Baton Rouge plant is located at 5955 Scenic Highway, Baton Rouge, LA in East Baton Rouge parish. The plant produces synthetic rubber, and uses or produces relatively few regulated substances above the RMP threshold quantities: butadiene (flammable); and ammonia and acrylonitrile (toxic substances). HAZARD ASSESSMENT RESULTS NOTE: Although we have numerous controls to prevent unplanned releases and to manage their consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating worst-case scenarios for toxic or flammable substances. The worst case scenario (WCS) associated with toxic substances at the plant is a catastrophic failure of an acrylonitrile tank car during unloading, resulting in a release of 130,000 lb. of acrylonitrile over a 10-minute period. The maximum distance to a toxic endpoint of 0.076 milligram per liter for this WCS is 8.7 miles. The alternative release scenario (ARS) for acrylonitrile is a pipe rupture during an unloading operation, resulting in a release of 3,400 lb. of acrylonitrile over a 30-minute period. The maximum distance to the toxic endpoint of 0.076 milligram per liter for this ARS is 0.2 mile. The alternative release s cenario (ARS) for ammonia is a >" pipe break at the storage tank, resulting in a release of 31,000 lb. of ammonia over a 30-minute period. The maximum distance to the toxic endpoint of 0.076 milligram per liter for this ARS is 0.2 mile. The WCS associated with a release of flammable substances at the plant is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing butadiene. The full tank inventory of 1,400,000 lb. is assumed to release, completely vaporize, and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is 0.9 miles. The ARS for flammable substances at the plant is a VCE resulting from release of approximately 5,000 lb. of butadiene resulting from the failure of a pump seal over a period of 10 minutes. The release is expected to be detected and isolated by the operators within a maximum of 10 minutes (active mitigation). The maximum distance to the 1-psi endpoint for this event is 0.14 mile. G ENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Baton Rouge plant. Because processes at the plant that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation The Baton Rouge plant encourages employees participation in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the plant accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maint ained at the plant. In addition, the plant has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming "Continuous Process Improvement" teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering and plant management. Process Safety Information The Baton Rouge plant has a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information. Employees have access to any necessary process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known hazards such as those associated with the inadvertent mixing of chemicals. For specific process areas, the plant has documented safety-related limits for applicable process parameters (e.g., temperature, level, composition). The plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems. The plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activit ies, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) The Baton Rouge plant has a comprehensive program to help ensure that hazards associated with the various processes 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 plant 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 by a team of people who have operating and maintenance experience as well as engineering expertise. This 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 wh en the team believes such measures are necessary. The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained for the life of the process. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Baton Rouge plant updates and revalidates the hazard analysis results at least once every 5 years for the life of the process. The results and findings from these updates are documented and forwarded to management for consideration, and the final resoluti on is documented and retained. Operating Procedures The Baton Rouge plant maintains written procedures that address various modes of process operations, such as startup, normal and emergency operations, temporary operations, normal and emergency shutdowns, and initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. Procedures are periodically reviewed and annually certified as current and accurate. Training The Baton Rouge plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training both in safety issues and in plant operations. After successfully completing this training, a new operator is typically paired with a senior operator to learn process-sp ecific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. Operators receive refresher training on the operating procedures at least once every 3 years to ensure that their skills and knowledge are maintained at an acceptable level. Training is documented for each operator, including, the means used to verify that the operator understood the training. Contractors The Baton Rouge plant routinely employs contractors to work on or near process equipment. Additional contractor work force is present during periods of increased maintenance or construction activities. Procedures are in place to ensure that contractors perform their work in a safe manner, have the appropriate knowledge and skills, are aware of the hazards in their workplace, understand what they should do in the event of an emergency, understand and follow site safety rules, and inform plant personnel of any hazards that they find during their work. Each contractor employee is provided with a process overview and information about safety and health hazards, emergency response plan requirements, and safe work practices prior to beginning work. Contractor safety programs and performance are evaluated during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSR's) The Baton Rouge plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This 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 team uses checklists to verify and document all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The Baton Rouge plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems 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 equipment. Maintenance personnel receive training on (1) an overview of the process, (2) safe ty and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a 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, employees will correct the deficiency before placing the equipment back into service (if possible), or Management will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Baton Rouge plant incorporates quality assurance measures (e.g., purchasing specifications and inspection procedures) into equipment pur chases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The Baton Rouge plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Baton Rouge p lant has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The Baton Rouge plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investig ation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained on file as supplements to the hazard analysis records for the affected areas, and are reviewed during PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Baton Rouge plant periodically undergoes audits to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and management personnel participate in the audits. The audit team develops findings that are forwarded to the plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained on file. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the Baton Rouge plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and/or human errors. In addition to the accident prevention program activities, the Baton Rouge plant has safety featur es on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes: Release Detection --Hydrocarbon detectors with alarms Release Containment/Control --Process relief valves that discharge to a flare to capture and incinerate episodic releases --Scrubber to neutralize chemical releases --Valves to permit isolation of the process --Automated shutdown systems for specific process parameters (e.g., high level, high temperature) --Curbing or diking to contain liquid releases --Redundant equipment and instrumentation (e.g, uninterruptible power supply for process control system, backup firewater pump) --Atmospheric relief devices Release Mitigation --Fire suppression and extinguishing systems --Deluge systems for specific equipment --Trained emergency response personnel --Pe rsonal protective equipment (e.g., protective clothing, self-contained breathing apparatus) FIVE-YEAR ACCIDENT HISTORY The Baton Rouge plant has an excellent record of accident prevention. During the past 5 years there have been no incidents in covered processes involving onsite deaths, injuries or significant property damage, or offsite deaths, injuries, evacuations, shelter-in-place, property damage or environmental damage. EMERGENCY RESPONSE PROGRAM INFORMATION The Baton Rouge plant maintains a written emergency response program which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacu ation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. The plant also has procedures that address the use, maintenance, inspection, and testing of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is reviewed annually and updated when necessary based on modifications made to plant processes or other plant facilities. The overall emergency response program for the Baton Rouge plant is coordinated with the East Baton Rouge Parish Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Baton Rouge plant has around-the-clock communications capability with appropriate LEPC officials and emergency response org anizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response. In addition to periodic LEPC meetings, the Baton Rouge plant conducts periodic emergency drills that involve emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. PLANNED CHANGES TO IMPROVE SAFETY The Baton Rouge plant addresses each recommendation resulting from process hazard analyses. Some recommendations result in modifications to the process. The following are examples of changes planned (as of 6/99): Decrease in process chemical inventory involving 1,3-butadiene; Replacement of 2 reciprocating compressors with one new centrifugal compressor; Review and upgrade of facility pressure relief system; Upgrade of hydrocarbon release detection system in the Polymerization area; Review and upgrade of personnel train ing programs; and, Review and update of written operating and maintenance procedures. |