Firestone Synthetic Rubber & Latex Company, L. C. - Executive Summary |
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10.1 ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Lake Charles Plant is committed to operating the plant in a manner that is safe for its workers, the public and the environment. As part of this commitment, Firestone has established a system to help ensure safe operation of the processes of the Lake Charles Plant. One component of this system is a risk management program (RMP) that helps manage the risks at the plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirement Risk Management Program (the RMP rule) and OSHA's 29 CFR part 1910.119 (the PSM rule). This document is intended to satisfy the RMP Plan requirement of the RMP rule and to provide interested parties with a description of the risk management program at the Plant. Firestone is an active participant in the community. The Lake Charles Plant is voluntarily involved in the Calcasieu Community Advisory Pan el (CAP). The purpose of this group is to share information about plant operations with members of the community and to discuss their concerns. The Lake Charles Plant is also an active member of the Lake Area Industry/McNeese Engineering Partnership (LAI/MEP), the Safety Council of Southwest Louisiana, Mutual Aid of Southwest Louisiana, Calcasieu Area Emergency Response (CAER), and the Calcasieu Parish Emergency Planning Committee. Over the past five years the Lake Charles Plant has received several corporate pollution prevention awards and several National Safety Council and Bridgestone/Firestone corporate awards for both one million and two million manhours worked without a lost time accident. Firestone is committed to the safety of workers, the public and the preservation of the environment through the prevention of accidental releases of hazardous substances. The Lake Charles Plant implements reasonable controls to prevent foreseeable releases of substances. However, if a rel ease does occur, trained personnel are prepared to respond quickly and effectively. 10.2 DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Lake Charles Plant is located on Highway 108 near Sulphur, Louisiana. The Plant produces a wide range of synthetic rubber products manufactured by the solution polymerization process. Two flammable substances and one toxic substance are covered under the Accidental Release Program (ARP). The two flammable substances are 1, 3-butadiene and 2-butene-cis. The toxic substance is boron trifluoride. 10.3 OFFSITE CONSEQUENCE ANALYSES (HAZARD ASSESSMENT) SUMMARY The Worst-Case Scenario for flammables on site involves an instantaneous release/evaporation/dispersion and explosion of the contents of a 1, 3-butadiene storage vessel. No credit is taken for any of the existing mitigation systems. This is a physically impossible event which is not expected to ever occur. Analysis of this hypothetical event indicates the endpoint would ex tend beyond the boundaries of the Plant. The Worst-Case Scenario for a toxic release on site involves a rupture of a boron trifluoride storage container. No credit is taken for any of the existing mitigation systems. In accordance with federal and state guidelines for calculation, this release is assumed to occur at the worst case weather conditions of "F" Pasquill stability class and 1.5 meters/second, which occurs only on still, cloudy nights. Although we believe this event is unlikely to occur, analysis of this event indicates the endpoint would extend beyond the boundaries of the plant. The Planning Case (Alternate Release) Scenario for a flammable involves a release of 1, 3-butadiene from piping in the Tank Farm Area. A 3/4-inch piping failure was assumed to have occurred and it was assumed that no one would be able to shut off the flow for 10 minutes. This is a very conservative assumption as there are automatic shut-off valves in this piping, as well as detection capa bility and alarms. Although we believe this event is unlikely to occur, analysis of this event indicates the endpoint would extend beyond the boundaries of the plant. The Planning Case (Alternate Release) Scenario for the only toxic material involves a release of boron trifluoride from a 1/2-inch piping failure at the discharge of a storage container. It was assumed that no one would be able to shut off the flow for 30 seconds. This is a realistic assumption as there is a Plant safety policy to have operations and plant protection personnel standing by wearing personal protection equipment any time this material is being served to the process. There is also detection, alarm, and water deluge capability at this specific process location. This case was analyzed at average weather conditions for our area. Although we believe this event is unlikely to occur, analysis of this event indicates the endpoint would extend beyond the boundaries of the plant. 11.0 MANAGEMENT SYSTEM FOR PRO CESS SAFETY/RISK MANAGEMENT The following is a summary of the accident prevention program in place at the Lake Charles Plant. The processes at the plant that are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard. Therefore, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. The Prevention Program questions found in section 7 of the Risk Management Plan Data Elements submittal have been answered assuming that, for this initial RMP submittal only, they apply to OSHA 29 CFR Part 1910.119. 11.1 Employee Participation Open communications are encouraged between supervisors and employees regarding all safety and health issues. There are various levels of responsibility taken by different employees, including the plant manager, safety coordinator, department managers, first-line supervisors, and all employees. The Plant actively seeks employee involvement in the development and conduct of all accident prevention activities through the appropriate existing safety programs. Accident prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments, or suggestions. 11.2 Process Safety Information The Plant keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDSs). Other chemical-specific information includes maximum intended inventories of chemicals, information on inadvertent chemical mixtures that could occur and their associated hazards. The Plant also maintains numerous technical documents that provide information about the design and construction of process equipment, which include information on materials of construction, piping/instrumentation diagrams, relief systems design, as well as others. This information is provided to maintain safe operations at the facility. 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. PSI is updated through the Management of Change Program, as are the operating specifications. The entire system is audited every three years. 11.3 Process Hazard Analysis (PHA) The 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 uses some or all of the hazard evaluation techniques outlined in the American Institute of Chemical Engineers publication Guidelines for Hazard Evaluation Procedures to perform these evaluations. The analyses are conducted using a team with operating and maintenance experience as well as engineering expertise. PHA team members include employees with expertise in the following areas: technical, staff engineering, operations, maintenance, safety, and PHA methodology. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes recommendations for additional prevention and/or mitigation measures when the team be lieves such measures are necessary. The PHA team findings are forwarded to plant management for resolution. The final resolution of each finding is documented and retained. All PHA team recommendations are tracked until they are completed. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the PHA team updates and revalidates each PHA every five years. These periodic reviews are conducted at this frequency until the process is no longer operating. 11.4 Operating Procedures The Plant maintains written procedures that address various modes of process operations, such as (1) initial startup, (2) normal startup, (3) normal operation, (4) normal shutdown, (5) emergency operations, (6) emergency shutdown, (7) temporary operation, (8) preparation for maintenance procedure, (9) quality assurance, and, (10) inadvertent mixing. The specific instructions include the applicable safety precau tions and appropriate information on safety implications. These procedures provide guidance for experienced operators and a basis for consistent training of new operators. Operating procedures are reviewed and updated annually by the Manufacturing Department to verify current status. The review is to assure that the procedures reflect current operating practice, include changes from process technology changes, chemical changes, equipment changes, and changes to facilities. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. 11.5 Training In addition to training on operating procedures, the Plant has a comprehensive training program for all employees involved in operating the process. New employees receive immediate training in the following areas of the process: overview of process; process fundamentals; and process description. Training includes emphasis on specific safety and hea lth hazards, emergency operations, and safe work practices applicable to the job. This training must be passed through oral or written testing and the employee must demonstrate and verify that they understand the required operating procedures before they are allowed to operate the unit alone. In addition, all operators receive refresher training at least every three years. This refresher training on the operating procedures is to ensure that their skills and knowledge are maintained at an acceptable level. Additionally, more frequent training will occur upon the request of the employee. The appropriate frequency of training is decided by management in consultation with the employees involved in operating the particular process. All of this training is documented for each operator including the means used to verify that the operator understood the training. 11.6 Contractors The Plant uses contractors for selected maintenance, construction, and engineering service support activ ities. The Lake Charles Plant evaluates contractor safety programs and performance during the selection of a contractor. Because some contractors work on or near process equipment, the Lake Charles Plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have appropriate knowledge and skills, (3) are aware of the hazards of their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site specific safety rules, and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. Plant personnel periodically monitor contract performance to ensure that contractors are fulfilling their safety obligations. 11.7 Pre-startup Safety Review (PSSR) The Plant con ducts a PSSR on any new plant modification that requires a change in 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 procedure also provides a final check that construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. 11.8 Mechanical Integrity The purpose of the Mechanical Integrity Program is to assure the continued integrity of process equipment in order to prevent or minimize employee exposure to the uncontrolled release of toxic, flammable or explosive chemicals, and the attendant consequences of such a release. The Plant has well established practices and pr ocedures for maintaining process equipment. The basic aspects of this program include (1) 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 process, (2) safety 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 jobs in a safe manner. Another integral part of the mechanical integrity program is quality assurance. The Plant incorporates quality assurance measures into equipment purchases, installations, repairs and replacement. 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. 11.9 Safe W ork Practices The Plant has 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/tag out procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous and toxic substances before process piping and 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. 11.10 Management of Change The Plant has a comprehensive system of written procedures to manage changes to all covered processes. The purpose of this system is to ensure that process changes maintain or enhance the sa fety, environmental, and technical integrity originally designed into the Plant. This system requires that changes to items such as chemicals, process equipment, technology (including process-operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Prior to changes being made, they 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, including contractor employees, are notified and provided any necessary training on the change. 11.11 Incident Investigation The Plant promptly investigates all incidents that resulted in or reasonably could have resulted in, a fire/explosion, toxic gas release, major p roperty damage, environmental loss, or personal injury. The goal of each investigation is to gather the facts, determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident. The investigation team documents its findings in a report. The report includes dates of the incident and investigation, description of incident, factors contributing to the incident. The team develops recommendations to prevent a recurrence, and forwards this report to the plant management team for resolution. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHA's and PHA revalidations. 11.12 Compliance Audit To help ensure that the accident prevention program is functioning properly, the Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least ev ery three years. The audit includes an evaluation of the design and effectiveness of the PSM system. The audit team develops findings in a report that is forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked and documented until they are complete. The final resolution of each finding is documented, and the two most recent compliance audit reports are retained. 12.0 CHEMICAL SPECIFIC PREVENTION STEPS The processes at the Plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to the RMP-covered process at the Lake Charles Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. In addition to the accident prevention program activities the Plant has safety features on many units to help (1) contain/control a release, (2) qu ickly detect a release, and, (3) reduce (mitigate) the consequences of a release. The following types of safety features are used in various processes: 12.1 Release Detection 1. Sensors with audible alarms are located to detect and warn of leaks. 2. Video cameras are located in the facility, which assist with leak detection. 3. Operators perform visual walk arounds of operating areas. 12.2 Release Containment/Control 1. Pressure relief valves on applicable tanks. 2. Key manual valves are chained and padlocked in their critical (open/closed) position. 3. Excess flow check valves in selected operations to limit releases. 4. Dikes are utilized around applicable vessels. 5. Water deluge systems are utilized at points within the facility to assure the ability to suppress releases. 6. Atmospheric scrubbers are utilized to reduce emissions/releases. 12.3 Release Mitigation 1. Standard operating procedures that control, isolate, and terminate leaks. 2. Personnel trained in emergency p rocedures. 3. Personal protective equipment (e.g., escape respirator, self-contained breathing apparatus, and supplied air breathing apparatus). 13.0 FIVE YEAR ACCIDENT HISTORY The Plant has an excellent record of accident prevention over the past five years. There has been no RMP defined incident involving a regulated substance. 14.0 EMERGENCY RESPONSE PROGRAM The 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 overall emergency response program for the Lake Charles Plant addresses personnel, planning, resources, communications and alliances. Firestone has an emergency response team consisting of employees representing various units in the plant. This team has been trained in hazardous materials, conf ined-space rescue and medical training. Planning has been developed in coordination with the Local Emergency Planning Commission (LEPC) and Mutual Aid as well as neighboring companies and communities. The Plant has the resources to respond to emergencies immediately; these include equipment, materials and additional labor. Fire water pumps, dry chemicals, foam, emergency vehicles, rescue equipment, spill control/cleanup material and water are available on-site for immediate use. Firestone has an alliance with the LEPC and Mutual Aid if additional equipment or personnel is needed. An internal public-address system is in place to allow communication with employees to address a variety of conditions that may need their response. Communication with the public is done through the Community Awareness Emergency Response (CAER) sirens and the local broadcast media. There is also a 24-hour community information line, access to the Emergency Call System (ECAL) of the Calcasieu Office o f Emergency Preparedness and use of a dedicated emergency radio signal. 15.0 PLANNED CHANGES TO IMPROVE SAFETY Firestone is committed to continuous improvement in safety for its workers, the public and the environment. The Lake Charles Plant has a number of active programs (as outlined in section 11 above) to identify opportunities for improvement. For example, during the past three years, the Plant has reduced the possibility of runaway reactions by adopting an inherently safer operating philosophy, improved heat exchanger mechanical integrity, and reduced the use of toxic chemicals by substituting a less hazardous water treatment chemical. |