Chevron Chemical Company, LLC - Oak Point Plant - Executive Summary |
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LDEQ Facility ID Number - 1708 1.0 Accidental Release Prevention and Emergency Response Policies At Chevron Chemical Company, LLC - Oak Point Plant, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs, fire prevention programs and emergency response training and planning programs to help ensure the safety of our employees and the public as well as protection of the environment. As specified in the EPA RMP rule, we have not had any accidents in the past five years from any covered process 2.0 Stationary Source and Regulated Substances Our facility produces petroleum additives using a variety of chemicals and processing operations. Our plant is one of the largest and most advanced producers of high-quality blended fuel and lubricating oil additives in the world. The facility serves domestic and international markets. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics RMP-regulated chemicals Quantity handled/stored Use at the facility Ethylenediamine 96,000 / 96,000 lbs. Fuel Additive Production Boron trifluoride 3,300 / 40,000 lbs. PIB Production Ammonia (anhydrous) 20,000 / 20,000 lbs. PIB Production Flammables RMP-regulated chemicals Quantities handled/stored Use at the facility Methylamine 64,000 / 64,000 lbs. Calcium Phenate Production Methylpropene,2- 5,250,000 / 14,000,000 lbs. PIB Production Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that could affect our employees, the public, and the environment by our use of these chemicals. 3.0 Key Offsite Consequence Analysis Scenarios EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative case 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: Worst-case Release Scenario(s) - Regulated Toxic Chemicals Our worst case scenario involves the release of one full cylinder of boron trifluoride gas in our PIB plant within ten minutes. The cylinder contains 3,300 pounds of boron trifluoride. The worst case scenario would occur if: 1. a large leak or rupture occurred due to a material failure of the vessel or piping that was not recognized during the equipment inspection processes, 2. any indications prio r to the failure were not recognized during the routine inspection procedures, 3. the boron trifluoride could not be directed to the PIB wastewater scrubber column, 4. the large leak or rupture was not detected by the process observation cameras, 5. Operations personnel fail to respond to the leak or rupture, 6. the boron trifluoride deluge system failed, 7. and our emergency response system failed to respond to the incident. We also assume that the release occurs at night during overcast conditions (F stability) with a wind speed of 1.5 meters per second. Depending on the wind direction, different areas surrounding the plant might be affected. In addition to the residents, other affected groups could include people at the Alvin Callender Naval Air Station, Our Lady of Perpetual Help Elementary School, and Belle Chasse High School. Alternative Release Scenario(s) - Regulated Toxic Chemicals Our alternate case scenario is a = inch hole developing in the tubing connecting th e cylinder of boron trifluoride gas to our PIB plant. The alternate release scenario would occur if: 1. the hole developed due to a material failure of the vessel or piping that was not recognized during the equipment inspection processes, 2. any indications prior to the failure were not recognized during the routine inspection procedures, 3. the boron trifluoride could not be directed to the PIB wastewater scrubber column, 4. the large leak or rupture was not detected by the process observation cameras, 5. Operations personnel fail to respond to the leak or rupture, 6. the boron trifluoride deluge system failed, 7. and our emergency response system failed to respond to the incident. An alternate case scenario where one or more of these conditions do not apply may result in an incident with no off-site consequences. We assume that the release occurs during more typical weather conditions (D stability) with a wind speed of 3 meters per second (6.7 miles per hour). Depending o n the wind direction, different areas surrounding the plant might be affected. In addition to the residents, other affected groups could include people at the Alvin Callender Naval Air Station. Worst-case Release Scenario(s) - Regulated Flammable Chemicals Our worst case scenario involves the catastrophic failure, evaporation, and explosion of one full sphere of 2-methylpropene (isobutylene) in our PIB plant. The sphere contains 5,250,000 pounds of 2-methylpropene. The worst case scenario would occur if: 1. the sphere is full and has a catastrophic failure due to a material failure that was not recognized during the equipment inspection processes, 2. the entire contents evaporate but do not drift apart, 3. any indications prior to the failure were not recognized during the routine inspection procedures, 4. the 2-methylpropene is not incinerated in the relief line to the PIB flare, 5. the 2-methylpropene finds a source of ignition 6. the 2-methylpropene deluge system fails to prevent the explosion, 7. Operations personnel fail to respond to the leak or rupture, 8. and our emergency response system failed to respond to the incident. We also assume that the release occurs at night during overcast conditions (F stability) with a wind speed of 1.5 meters per second (3.4 miles per hour). In addition to the residents, other affected groups could include people at the Alvin Callender Naval Air Station. Alternative Release Scenario(s) - Regulated Flammable Chemicals Our alternate case scenario is a 2 inch hole developing in the piping leading to or from the 2-methylpropene sphere in our PIB plant. The alternate release scenario would occur if: 1. the hole developed due to a material failure of the vessel or piping that was not recognized during the equipment inspection processes, 2. any indications prior to the failure were not recognized during the routine inspection procedures, 3. the 2-methylpropene could not be directed to the PIB flare, 4. the 2-m ethylpropene finds a source of ignition 5. the 2-methylpropene deluge system fails to prevent the explosion, 6. Operations personnel fail to respond to the leak or rupture, 7. and our emergency response system failed to respond to the incident. An alternate case scenario where one or more of these conditions do not apply may result in an incident with no off-site consequences. We assume that the release occurs during more typical weather conditions (D stability) with a wind speed of 3 meters per second (6.7 miles per hour). No residents would be affected by the alternate release scenario. The only affected group would be the people at the Plaquemines Parish Wastewater Treatment Plant and anyone on a nearby ship. 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. 4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps We take a sy stematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: o Process safety information o Process hazard analysis o Operating procedures o Training o Mechanical integrity o Management of change o Pre-startup review o Compliance audits o Incident investigation o Employee participation o Hot work permit o Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: 7 Process controls, alarms, and shutdown systems 7 Highly qualified operators with extensive initial and refresher training 7 Thorough operating procedures that are kept up to date 7 Inspection and preventative maintenance processes 7 Pressure relief and treatment system for ammonia, boron trifluoride, and 2-methylpropene systems 7 Gas detection monitors on ammonia and 2-methylpropene systems 7 Cameras for continuous monitoring of boron tri fluoride handling equipment in the control room 7 Remote shutdown valves located at two points within the PIB Plant 7 Water spray system on ammonia, boron trifluoride and 2-methylpropene vessels 7 Fire hoses and monitors to "knock-down" and absorb vapors 7 Well-trained Emergency Response Team on-site and available at all times These individual elements of our prevention program work together to prevent and mitigate accidental chemical releases. Our company and our employees are committed to the high safety standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. |