Oxy Vinyls, LP - Deer Park PVC Plant - Executive Summary
The Deer Park PVC Site is a polyvinyl chloride (PVC) resin manufacturing facility owned by Oxy Vinyls, LP. Oxy Vinyls, LP, referred to as "OxyVinyls", is a joint venture between Occidental Chemical Corporation (a subsidiary of Occidental Petroleum Corporation) and The Geon Company. This facility is located in Deer Park, Texas on Tidal Road. The Deer Park PVC Site manufactures PVC from polymerization of vinyl chloride and ships PVC resin to external customers via railcar. The facility was originally constructed in 1974 and employs approximately 70 full-time employees. |
1. Accidental Release Prevention and Emergency Response Policies at the Stationary Source (' 68.155(a))
OxyVinyls is committed to operating the Deer Park PVC Site in a manner that is safe for its workers, the public and the environment. It is our policy to adhere to all applicable Federal, State and local rules and regulations, industry standards and best practices. As part of this commitment, OxyVinyls has establ
ished a system to help ensure safe operation of the processes at this facility that includes the prevention of accidental releases of hazardous substances. One component of this system is a risk management program (RMP) that provides the basis for managing risks at the Deer Park PVC Site. The RMP complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirement Risk Management Programs (the RMP rule), OSHA 1910.119. This document is intended to satisfy the RMP plan requirement of the RMP rule and to provide the public with a description of the risk management program at the Deer Park PVC Site.
The Risk Management Program at the Deer Park PVC Site consists of the following three elements:
7 A hazard assessment to (a) help the facility and community understand the potential off-site consequences of hypothetical accidental releases and to (b) provide information to the public regarding accidents that
have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances)
7 A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes)
7 An emergency response program to help respond to accidental releases of regulated substances from covered processes
Information further describing these elements is provided in this RMP Plan.
Although the risk management program at the Deer Park PVC Site helps ensure that the facility is maintained and operated in a safe manner, it is only one component of the safety and environmental program at the Deer Park PVC Plant. In fact, the Deer Park PVC Plant has a comprehensive safety and environmental program in place, establishing many levels of safeguards against release of a hazardous substance as well as injuries and damage from such a release.
OxyVinyls' policy on the use of hazardous substances
: Before using a hazardous substance at the Deer Park PVC Site, less hazardous alternatives are always considered. When a hazardous substance is to be used at the Deer Park PVC Site, the plant personnel review the potential for an accidental release of this substance that could adversely affect plant workers, the public and the environment, and takes steps to prevent any such effects. This is accomplished through the facility's Management of Change (MOC) and Process Hazard Review (PHR) procedures that are followed for all new installations or modifications of existing processes.
OxyVinyls strives to prevent accidental releases of the hazardous substances used at the facility by implementing reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used at the Deer Park PVC Site, the equipment is carefully designed, installed, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards
are closely adhered to in the design, construction and operation of the equipment. In addition, the facility requires the documentation of standard operating procedures and training of affected employees with regard to these procedures as part of the MOC procedure. The facility mechanical integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances.
OxyVinyls' goal is to minimize impacts from accidental releases should they occur. In the event of an accidental release, the Deer Park PVC Site controls and contains the release in a manner that will be safe for workers and will minimize the impact to the public and environment. The facility maintains an active Emergency Response Team that is on call at all times to respond to accidental releases of any of the hazardous chemicals handled by OxyVinyls facilities. In addition, OxyVinyls has a leadership role in Channel Industries
Mutual Aid (CIMA). This is a state chartered non-profit mutual-aid cooperative combining the fire fighting, rescue, hazardous material handling and emergency medical capabilities to its members in the Houston Ship Channel area. Participating in this organization ensures emergency response capabilities far greater than an individual plant can provide. Along with the CIMA organization, the plant takes an active role in the local emergency planning committee for Deer Park. The facility promotes the use of the CAER Phone Hotline number to inform citizens of any unusual plant event and actively works with the Deer Park Citizen's Advisory Council.
An OxyVinyls Emergency Response Plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, and EPA regulations, as well as OxyVinyls' corporate guidelines. This plan outlines the responsibilities and actions required for control an emergency within the boundaries of the Deer Park PVC P
lant. If the emergency extends beyond or could potentially extend beyond the plant boundaries, the Deer Park Local Emergency Planning Committee (LEPC) is notified and a statement of the type of emergency and any community protection factors are recommended.
The facility employees are active participants in the community. The purpose of this group is to share information about plant operations with members of the community and to discuss their concerns. Through this outreach effort, as well as other community involvement, the plant stays abreast of community concerns and works to address them.
The Plant Manager's Safety and Environmental Committee, along with representation from all departments and contractors, meet monthly to promote dialog between employees and management. To effectively implement these policies, OxyVinyls has established a management system headed by the Health, Environmental and Safety (HES) Departments to oversee safety and environmental-related activities.
2. The Stationary Source and Regulated Substances Handled (' 68.155(b))
The Deer Park PVC Site handles two substances that are covered by the RMP rule, as shown in the following of RMP-covered chemicals at the plant.
Regulated Substance Largest Vessel Inventory RMP Threshold Quantity
Anhydrous Ammonia 20,000 lbs. 10,000 lbs.
Vinyl Chloride 1,200,000 lbs. 10,000 lbs.
Anhydrous ammonia is used as a cooling medium in the process and as a refrigerant for chilling water. Vinyl chloride is the primary feedstock for the plant. The vinyl chloride is polymerized in a water slurry solution to make PVC resin. Un-reacted vinyl chloride is recovered and recycled; while the PVC and water slurry are further processed and dried to produce PVC resin (dry powder). The PVC resin is then stored in silos until loaded into railcars for shipment to customers.
Based on the RMP criteria for process program levels, this is
considered a single Program 3 process that contains both ammonia and vinyl chloride.
3. The Worst-Case Release Scenario(s) and the Alternate Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario (' 68.155(c))
The facility performed off-site consequence analyses of accidental releases of regulated substances to estimate the potential affects to the public or the environment. The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario" and an "alternative release scenario". OxyVinyls does not expect a worst-case release scenario to ever occur given the multiple levels of protection in place to prevent such a scenario. The alternative release scenarios that have been developed are based on more likely potential accidental releases. These have been shared with the LEPC to assist them in improving the community emergency response plan.
Distances to toxic and flammable
endpoints were calculated based on the EPA RMP Offsite Consequence Analysis Guidance. The meteorological data used for the modeling was the EPA default for the worst case scenario and EPA suggested values for the alternative release scenario. The Landview. III program was utilized to estimate the number of persons living within this distance from the location of the potential release point. USGS maps were utilized to identify the public and environmental receptors located within this distance.
The following information summarizes the off-site consequence analysis performed by the Deer Park PVC Site:
3.1 Toxic Substances - Ammonia
The "worst-case scenario" for ammonia would be a catastrophic failure of the anhydrous ammonia storage tank. This scenario assumes that 20,000 pounds of liquefied ammonia would be released and evaporated within a 10-minute period. Under the EPA default worst weather conditions, the ammonia gas cloud would travel a distance of 1.7 miles before the conce
ntration of ammonia diminished below the toxic endpoint concentration of 0.14 mg/L (200 ppm). No credit is taken for passive or active mitigation in the analysis. U.S. Census data indicates that approximately 1,500 persons live within this distance from the storage tank. Public receptors within the distance to the toxic endpoint include residences, schools, and an industrial area. An environmental receptor within this distance is a state park.
An alternate release scenario that was selected for ammonia involves a process-upset condition that causes pressure build-up in a vessel, resulting in the pressure relief device opening to the atmosphere. It is estimated that 1,000 lbs. of gaseous ammonia would be released over a 10-minute period. Under the EPA alternate release weather conditions, the ammonia gas cloud would travel a distance of 0.2 miles Active mitigation accounted for in the analysis includes multiple process alarms to alert operators of an upset condition. U.S. Census
data indicates that no residences would be affected by this release. A public receptor within the distance to the toxic endpoint is an industrial area. No environmental receptors would be affected under this scenario.
3.2 Flammable Substances - Vinyl Chloride
The worst case scenario involving a flammable substance at the facility would be a catastrophic failure of a vinyl chloride storage tank. This flammable substance release scenario assumes that the entire contents of the tank (1.2 million pounds) is released and vaporizes to form a vapor cloud that subsequently ignites. In this scenario, an endpoint of 1-psi over normal atmospheric pressure would extend to a distance of 0.64 miles. U.S. Census data indicates that the residential population within the endpoint distance is 90 persons. Public receptors within the endpoint distance include residences and industrial areas. No environmental receptors would be affected under this scenario.
The alternate release scenario for vi
nyl chloride that was selected involves a process-upset condition that results in a pressure relief device opening to the atmosphere. It is estimated that 1,000 lbs. of gaseous vinyl chloride would be released over a 10-minute period. Active mitigation includes operator intervention to shutdown or regain control of the process. No credit is taken for passive mitigation in the analysis. In this scenario, the distance to the lower flammability limit (LFL) associated with a vapor cloud fire would extend to 0.10 miles. U.S. Census data indicates that no residences would be affected by this release. A public receptor within the endpoint distance includes an industrial area. No environmental receptors would be affected under this scenario.
4. The General Accidental Release Prevention Program and the Specific Prevention Steps (' 68.155(d))
The Deer Park PVC Site developed and implemented a prevention program in accordance with OSHA's Process Safety Management standard in 1992. Under
the EPA RMP criteria for establishing a prevention program, a Program 3 prevention program is required for the Deer Park PVC process. The Program 3 prevention program is essentially the same as OSHA PSM standard, except that the program also focuses on protecting the public and the environment beyond the plant's boundaries. The following sections briefly describe the 12 elements of the Deer Park PVC Plant's Program 3 prevention program that address EPA's RMP rule prevention program requirements.
4.1 Process Safety Information
The Deer Park PVC Site maintains technical documents that are used to help ensure safe operation of the plant processes. These documents address (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant and (3) design basis and configuration of the equipment at the plant. The facility ensures that this process safety information is up-to-date and available to all employees. Information
pertaining to hazardous chemicals in the process is documented in the facility Material Safety Data Sheets (MSDSs) files. The information available for each hazardous substance typically includes:
7 Toxicity information and permissible exposure limits
7 Physical data (e.g., boiling point, melting point, flash point)
7 Reactivity and corrosivity data
7 Thermal and chemical stability data
7 Hazards of mixing substances in the process
Information pertaining to the technology and equipment in the process is documented in Design manuals, Process Description Manuals, process flow diagrams, engineering drawings, and equipment files. These documents are used to (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment.
The available information includes:
7 Applicable design codes and standards
7 Design basis and configuration of equipment
7 Design basis for relief and ventilation systems
7 Piping and instrumentation diagrams, including materials of c
7 Process chemistry
7 Operating parameters
7 Maximum intended inventories
7 Safe upper and lower limits for parameters such as temperature, pressure, or flow
7 Configuration of equipment
7 Electrical classification
7 Safety systems
4.2 Process Hazard Analysis
The Deer Park PVC Site performs and updates process hazard analyses (PHAs) of the covered process to help identify potential process hazards and generate recommendations that might improve the safe operation of the process. These process hazard analyses are revalidated at least every five years. PHA teams for employee involvement conduct process Hazard Analyses. These teams are comprised of personnel with engineering, process operating experience, and specialized knowledge. A leader with applicable PHA training facilitates the hazard analyses. The PHA team prepares a written report describing the results of the analysis, including a list of recommendations to address potential hazards. Hazards that are identifi
ed are risk-ranked to ensure that highest priority is given to those having the highest consequence and likelihood of occurrence. The recommendations are assigned to unit personnel and tracked to completion using the facility Action Tracking System.
4.3 Operating Procedures
Operating procedures have been developed for each process area. These are maintained by the training supervisor using a document control system. Operating procedures are reviewed annually by operators and process engineers and certified as being correct. The procedures include steps for safe operation during all phases of operation, including initial startup, normal startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations, as applicable. Within the operating procedures are:
7 Steps for safely conducting work activities
7 Applicable process safety information, such as safe operating limits and consequences of process deviat
7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs
The Deer Park PVC Site has implemented an effective training program to administer training activities. The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) safety, health, and environmental topics, (3) process-specific training on the properties and hazards of the substances in the process and (4) job-specific requirements. This training is provided in both a classroom and on-the-job setting. A combination of oral reviews and written tests are used to verify that an employee understands the training material. Training documentation is retained by the Training and Safety Departments.
4.5 Mechanical Integrity
The Deer Park PVC Site maintains the mechanical integrity of process equipment to help prevent equipment failures that cou
ld endanger workers, the public, or the environment. Inspectors that have been qualified to API, AWS, and ASNT standards are utilized for performing inspections and tests of mechanical equipment. Qualified instrument and electrical technicians are utilized for inspections and tests of instrumentation and electrical equipment. The mechanical integrity program includes -
(1) an administrative procedure that defines the inspection and testing program
(2) equipment inspection procedures that defines methods of inspection, acceptance criteria, and inspector qualifications
(3) specific non-destructive inspection procedures
(4) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes
4.6 Management of Change
The Deer Park PVC Site Management of Change procedure defines the requirements for review and approval of all proposed changes to chemicals, equipment, and procedures for processes to ensure
that safety, health and environmental affects of changes are considered. The Management of Change system ensures that the affected employees are notified of the changes, training is provided, and that process safety information and procedures are updated accordingly. Plant personnel receive training on how to identify potential changes and the types of changes that are covered by the Management of Change procedure.
4.7 Pre-startup Review
The Deer Park PVC Site performs a Pre-startup Safety Review (PSSR) for all changes to the process before they are put into service to help ensure that the process is safe to operate, procedures are in place, and affected personnel are adequately trained to operate or maintain the process. Startup of the applicable process or equipment cannot commence until issues identified by the Pre-startup Review have been addressed and authorization is given by area supervision. Specific items that the PSSR confirms are:
7 Construction and equipment are in a
ccordance with design specifications
7 Adequate safety, operating, maintenance, and emergency procedures are in place
7 Affected employees are trained before they can be affected by the change
7 Construction and equipment are in accordance with design specifications during a process walk-through
7 A PHA has been performed as specified by the Management of Change procedure
4.8 Compliance Audit
The Deer Park PVC Site audits covered processes every 3 years to be certain that the prevention programs are effectively implemented at the plant. Audit specialists who are knowledgeable in the process and who have been trained in the auditing process have been employed to review the facility prevention program. These audits evaluate whether the prevention program satisfies the requirements of the EPA RMP rule and OSHA PSM standard, and whether the prevention program is effectively implemented. The results of audits are documented, recommendations are assigned to individuals to be resolved, a
nd appropriate enhancements to the prevention program are implemented. In addition, monthly audits of process activities are conducted, often with the assistance of outside customers and suppliers.
4.9 Incident Investigation
The Deer Park PVC Site investigates incidents, including near misses and operational errors, that could reasonably have resulted in a serious injury to personnel, the public, or could have caused damage to the environment so that similar incidents can be prevented in the future. An investigation team referred to as a "Board of Inquiry" is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are assigned to persons to be resolved, and appropriate process or system enhancements are implemented.
4.10 Employee Participation
The Deer Park PVC Site developed a written employee participation program for the facility to help ensure that the safety concerns of the plant's worker
s are addressed. The facility encourages active participation of personnel in prevention program activities at the plant. Some examples in which employees participate include development of prevention programs and documentation, process hazard analysis, development of operating procedures, development of alternate release scenarios, and incident investigations. Employees are consulted on and informed about all aspects of the RMP rule prevention program.
4.11 Hot Work Permits
The Deer Park PVC Site established a hot work permit program to control spark or flame-producing activities that could result in fires or explosions in all processes at the plant. The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and developed a Hot Work Permit procedure to comply with these requirements. Personnel who are to perform hot work are required to receive a Hot Work Permit. Qualified individuals who issue hot work permits receive specialized training in
the procedure and activities related to hot work. Refresher training on hot work is required every three years.
OxyVinyls Houston Operations has established a contractor program to ensure that contractor activities at the plant are performed in a safe and responsible manner at the plant. OxyVinyls requires that contractors undergo a qualification process before being allowed to work at the facility. Contractors are required to submit information regarding their safety, health, and environmental programs and performance. This information is evaluated to ensure that the plant only hires contractors who can perform the desired job tasks in a safe and environmentally sound manner. The plant ensures that contractors observe all safe work practices and are aware of the hazards of the process and the plant's emergency response procedures.
5. Five-year Accident History (' 68.155(e))
There has been one accident at the Deer Park PVC facility over the past five years
that meets the EPA RMP accident criteria. This involved a release of vinyl chloride in which a neighboring plant was requested to shelter-in-place. The release did not result in any injuries, evacuations, property damage, or environmental damage.
6. The Emergency Response Program (' 68.155(f))
The Deer Park PVC facility, as part of the OxyVinyls Houston Operations, has established a written emergency response plan and maintains an emergency response team trained in the Emergency Response procedures. All plant personnel are trained in the plant alarm system, sheltering-in-place, and evacuation procedures. The written emergency response plan complies with the following federal and state contingency plan regulations:
7 OSHA 29 CFR 1910.38(a) - Employee Emergency Action Plans
7 OSHA 29 CFR 1910.119 (n) - Process Safety Management of Highly Hazardous Chemicals
7 OSHA 29 CFR 1910.120(p) and (q) - Hazardous Waste Operations and Emergency Response
7 OSHA 29 CFR 1910, Subpart L - Fire P
7 EPA 40 CFR 302.6 - Notification Requirements
7 EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Plan
7 EPA 40 CFR 355.40 - Emergency Planning and Release Notifications
7 EPA 40 CFR 112 - Spill Prevention, Control and Countermeasures Plan
7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention
OxyVinyls Houston Operations actively participates in the Channel Industries Mutual Aid (CIMA) organization. CIMA is an organization of Houston channel industries established to coordinate and assist member companies with industry emergencies. OxyVinyls also has employees that participate on the Houston Chemical Emergency Response Team (CERP). The team maintains a mobile chemical emergency command center equipped with the necessary equipment to respond to chemical emergencies at all times.
In addition, OxyVinyls has developed a Special Situations Plan that is a supplement to the Emergency Response Plan and is designed for responding t
o emergencies that may have impacts beyond the immediate plant. The Special Situation Plan links the local response to the Corporate Emergency Response Center, which can provide additional assistance.
OxyVinyls Houston Operations actively works with the Deer Park Local Emergency Planning Committee (LEPC) and supports the local Deer Park Emergency Warning System. The Deer Park LEPC meets every month and conducts annual training exercises of the emergency response plan. The company's emergency response plan has been communicated to CIMA, the Deer Park Fire Department, and the Deer Park LEPC.
7. Planned Changes to Improve Safety (' 68.155(g))
The Deer Park PVC Site constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, process hazard analysis, and a program for soliciting safety and environmental suggestions from the plant employees.
8. Certification (' 68.185)
To the best of the
undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete.
Signed by Byron McWhirter*, PVC Plant Manager, on June 17, 1999.
* The Certification with original signature is included with this RMP submittal.