Equistar Chemicals, LP - Morris Plant - Executive Summary
RISK MANAGEMENT PLAN |
Equistar Chemicals, LP (Equistar) operates an olefins and polymers manufacturing facility, the Morris Plant, in Morris, IL. The facility is located at 8805 North Tabler Road. Equistar employs approximately 550 full time employees at the plant site. There is collocated a research facility with about 60 employees.
1.0 ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES:
Equistar 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, Equistar has established a system to help ensure safe operation of the processes at the Morris 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 (EPA's) regulation 40 CFR Part 68, Accidental Release Prevention Requirement Risk Management Programs (the RMP rule); and the Occupational Safety and H
ealth Administration's (OSHA), Process Safety Management (PSM) Standard (29 CFR 1910.119). This document is intended to satisfy the RMP Plan requirements of the RMP rule and to provide the public with a description of the risk management program at the Plant.
The risk management program at the Morris Plant consists of the following four elements:
7 A Management system to oversee implementation of the RMP elements.
7 A hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) 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 describin
g these elements is provided in this RMP Plan.
Although the risk management program at the Morris Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at the Plant. In fact, the Plant has a comprehensive safety program in place, establishing many levels of safeguards against a release of a hazardous substance as well as injuries and damage from a release of a hazardous substance.
It is our policy to adhere to all applicable federal, state and local rules and regulations, industry standards and best practices. To effectively implement these policies, Equistar has established a management system headed by the Health, Safety and Environmental (HSE) Departments to oversee safety and environmental-related activities.
1.1 Policy on the use of hazardous substances:
Before using a hazardous substance, less hazardous alternatives are considered. When a hazardous substance is used, Equistar considers
the potential for this substance to adversely affect the plant workers, the public and the environment through the management of change and the process hazard analysis processes and takes steps to prevent any such effects.
1.2 Preventing accidental releases of the hazardous substances:
Equistar is committed to the safety of workers, the public and the preservation of the environment through the prevention of accidental releases of hazardous substances. Equistar implements reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used, the equipment is carefully designed, built, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, installation and operation of the equipment. Equistar uses Fire, Safety and Environmental (FS&E) Guidelines when designing new or modifying existing processes. Each project is thoroughly reviewed b
efore approval. In addition, Equistar requires the documentation of standard operating procedures and the training of affected employees with regard to these procedures as part of the management of change process. Equistar's 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. The Morris Plant also participates in auditing processes to measure and enhance its prevention program.
1.3 Minimizing impact from an accidental release:
In the event of an accidental release, the Morris Plant controls and contains the release in a manner that will be safe for workers and will prevent impact to the public and the environment. Equistar provides response training to its personnel, designates an emergency response coordinator to oversee response activities, conducts regular drills to review response activities and coordinates response efforts with area industry and t
he local emergency response agencies. Equistar trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs. In addition, Equistar works with the area industry, the local fire department and Local Emergency Planning Committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur. Response activities have been discussed with the Local Emergency Planning Committee and the Northeast Illinois Area Industry Mutual Aid Association.
1.4 Community Participation:
The Morris Plant actively participates in and is committed to the Chemical Manufacturers Association's Responsible Care. initiative. As part of Equistar 's Responsible Care. efforts, the Morris Plant has voluntarily been involved in a Community Advisory Panel (CAP) since November 1992. The purpose of this group is to share information about plant operations with members of the community and to discuss their concerns. The group meets bimonthly and ad
dresses topics of interest to the members including plant safety and environmental performance, emergency response programs, health issues and process safety performance. Through this outreach effort, as well as other community involvement, the plant stays abreast of community concerns and works to address them.
2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED
Equistar's Morris Plant is located on an 890-acre site and began operations in 1968. The stationary source consists of an ethylene, polyethylene, and polypropylene process areas and support facilities. The following facilities (processes) are covered by this Rule: Olefins unit, Low Density Polyethylene (LDPE) unit, Polypropylene (PP) unit, Linear Low Density (LLDPE) unit, and the Process Research Center (PRC). The Morris Plant's key products are ethylene, propylene, low-density polyethylene, linear low-density polyethylene and polypropylene with by-products of hydrogen, crude butadiene and aromatic gasoline. The
feedstocks used are ethane and propane. All feedstocks arrive at the facility by pipeline and railcar. Aromatic gasoline is transported by pipeline to our river property dock where it is loaded into barges for transportation.
3.0 WORST-CASE AND ALTERNATE RELEASE SCENARIO ANALYSIS
The Morris Plant handles several regulated toxic and flammable substances in sufficient quantity to be covered by the RMP rule. The Morris Plant performed off-site consequence analysis to estimate the potential for accidental release of a regulated substance that may affect the public or the environment. The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario " (WCS) and an "alternative release scenario" (ARS) for each toxic and one to represent all flammables. In reality, Equistar does not expect a worst-case release scenario to ever occur. The alternative release scenarios were developed to help the LEPC improve the community emergency response plan.
EPA Look-Up Tables were used for evaluating the worst and alternate case release scenarios for flammable and toxic materials. The EPA recommended Landview program was utilized to estimate the number of people living within this distance from the location of the covered processes. United States Geological Survey (USGS) maps were utilized to identify the public and environmental receptors located within this distance. Specific information on scenarios, public and environmental receptors has been provided in the data elements portion of EPA's RMP Submit Program
4.0 ACCIDENTAL RELEASE PREVENTION PROGRAM (' 68.155d):
The facility complies with the EPA's Accidental Release Prevention Rule (40 CFR part 68) and OSHA's Process Safety Management Rule (29 CFR 1910.119). Program 3 is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment outside the plant fence line. The Morris Plant's prevention program consists of the following 1
4.1 Process Safety Information
The Morris Plant maintains a variety of 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. Equistar ensures that this process safety information is available to all employees, the LEPC, the local fire department, the area hospital and the county sheriff's office.
Material safety data sheets (MSDSs) document the physical properties of the hazardous materials handled at the plant, including regulated substances in covered processes. 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 corrosively data
7 Thermal and chemi
cal stability data
7 Hazards of mixing substances in the process
MSDSs for hazardous substances handled in the process are throughout the facility so that the employees have ready reference to this information. In addition, all MSDSs are provided to the LEPC and the fire department for use in helping formulate emergency response plans.
The engineering design documents include the operating parameters and the design basis and configuration of the equipment in the covered process. The available information includes:
7 Operating parameters
7 Block flow or simplified process flow diagrams
7 Process chemistry
7 Maximum intended inventories
7 Safe upper and lower limits for parameters such as temperature, pressure, or flow
7 Consequences of deviations from established operating limits
7 Design basis and configuration of equipment
7 Piping and instrumentation diagrams, including materials of construction
7 Electrical classification
7 Safety systems
7 Applicable design codes and standard
7 Design basis for relief and ventilation systems
When important information was not available from the design documents, it was developed through engineering analysis, in the case of operating parameters, during process hazard analyses of the process. All critical operating parameters are included in the operating procedures to ensure the safe operation of the process. These documents are used to (1) train employees, (2) perform process hazards analyses and (3) to maintain the equipment.
4.2 Process Hazard Analysis
The Morris Plant performs and periodically updates process hazard analyses (PHAs) of the covered process to identify potential process hazards and to generate recommendations that might improve the safe operation of the process. A team composed of personnel with engineering and process operating experience and a leader with process hazard analysis experience is assembled to analyze the hazards of the process. The plant uses the HAZOP and "what-if checklist" tec
hniques to perform this analysis. The PHA team prepares a written report describing the results of the analysis, including a list of recommendations. Responsibility to resolve the recommendations is assigned to unit personnel. As appropriate, changes to enhance the safety of the process are implemented.
4.3 Operating Procedures
Morris Plant engineers, operators and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include:
7 Steps for safely conducting activities
7 Applicable process safety information, such as safe operating limits and consequences of process deviations
7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions
to take if exposure to a hazardous substance occurs
7 Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations.
The Morris Plant trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process and (3) a detailed review of the process operating procedures and safe work practices. Oral reviews and written tests are used to verify that an employee understands the training material before the employee can work in the process. The operators are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training. Recommendations from the operators are re
viewed and changes to the training program are implemented as appropriate.
4.5 Mechanical Integrity
The Morris Plant maintains the mechanical integrity of process equipment to prevent equipment failures that could endanger workers, the public or the environment. The mechanical integrity program includes (1) an inspection and testing program to identify equipment deterioration and damage before the equipment fails and (2) a quality assurance program to ensure that new and replacement equipment meets the design standards required for service in the plant's processes. The mechanical integrity program includes:
7 Specifications for inspection and testing of process equipment
7 Specifications for replacement parts and equipment
7 Procedures for inspecting, testing, and maintaining process equipment
7 Procedures for safe work practices such as Lock-out / Tag-out; Hot Work; Confined Space Entry; and Line Breaking
7 Training of maintenance personnel
7 Documentation of maintenance
4.6 Management of Change
The Morris Plant management of change program evaluates and approves all proposed changes to chemicals, equipment and procedures for a covered process to ensure that the change does not negatively affect safe operations. Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change review. All other changes must be confirmed through the full management of change review to ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes.
4.7 Pre-startup Review
The Morris Plant performs a safety review of a new or modified process before the process is placed into service to ensure that the process has been prepared to operate safely. This review confirms that:
Construction and equipment are in accordance with design specifications
7 Adequate safety, operating, maintenance and emergency procedures are in place
7 Employee training has been completed
7 For a covered process, that management of change requirements has been completed.
7 A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed.
4.8 Compliance Audit
The Morris Plant audits the covered process to be certain that the prevention program effectively addresses plant safety issues. The plant assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process. This team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented.
4.9 Incident Investigation
The Morris Plant investigates all incidents that could reasonably have resulted in a serious injury to plant personnel, or impact the public or the environment so similar incidents can be prevented in the future. The plant trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved and appropriate process enhancements are implemented.
4.10 Employee Participation
The Morris Plant developed a written employee participation program for the covered process to help ensure that the safety concerns of the plant's workers are addressed. The plant encourages active participation of personnel in the prevention program activities. Employees are consulted on, and informed about, all aspects of the prevention program.
4.11 Hot Work Permits
Plant established a hot work permit program to control spark or flame- producing activities that could result in fires or explosions in covered processes at the plant. The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The Shift Supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation.
The Morris Plant established a program to ensure that contractor activities at the plant are performed in a safe manner. The program reviews the safety record of all contractors to ensure that the plant only hires contractors who can safely perform the desired job tasks. The plant explains to the contract supervisors the hazards of the process on which they and their emp
loyees will work, the plant's safe work practices, and the plant's emergency response procedures. The plant requires that the contractor supervisors' train each of their employees who will work at the plant before that worker can begin work at the plant site. The plant periodically reviews contractors' training documents and work performance to help ensure that safe practices are followed.
5.0 FIVE-YEAR ACCIDENT HISTORY (' 68.155e):
The Morris Plant has an excellent record of accident prevention over the last 5 years. The frequency of accidental releases has decreased.
We investigate every incident very carefully to determine ways to prevent similar incidents from occurring. Incident investigations may result in the replacement of existing equipment and/or addition of new equipment, revisions to operating procedures, mitigation systems, emergency response plan, and equipment design.
6.0 EMERGENCY RESPONSE PROGRAM INFORMATION (' 68.155f):
The Equistar Morris Plant em
ergency response plan has been developed to meet the emergency planning, response and notification requirements of the following 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 (HAZWOPER)
7 OSHA 29 CFR 1910, Subpart L - Fire Protection
7 EPA 40 CFR Part 302.6 - Notification Requirements
7 EPA 40 CFR Part 355.30 - Facility Coordinator and Emergency Response Plan
7 EPA 40 CFR Part 355.40 - Emergency Planning and Release Notifications
7 EPA 40 CFR Part 112 - Spill Prevention, Control and Countermeasures Plan
7 EPA 40 CFR Part 68 - Risk Management Programs for Chemical Accidental Release Prevention
7 EPCRA section 302 - List Of Extremely Hazardous Substances
The emergency response strategy for the Morris Plant is to prevent and/or control emergency situations via the use of engineering, design
and fixed fire protection systems. Fixed fire protection systems are designed to National Petroleum Refiners Association (NPRA) guidelines. The plant has an Emergency Response Team on each shift, available 24 hours per day, to respond and initiate response actions to contain, control and, if possible, mitigate the release. The team has access to on site emergency equipment, which is appropriate for the anticipated emergency situations and capabilities of Equistar personnel. The following is a listing of some of the on-site equipment, available for emergency response:
7 2000 gallon per minute Pumper/ Rescue Truck equipped w/ 500 gallons of water and 250 gallons of foam
7 1000 gallon per minute 54 foot Squirt Truck equipped w/ 500 gallons of water and 500 gallons of foam
7 HAZMAT Truck and Response Trailer
7 Rescue Trailer
7 Boat, Boom, skimmer, and portable fire water pump on boat
7 14,000 gallon per minute Firewater System
7 Mobile Incident Command Vehicle
tance is required during an emergency response, the following Mutual Aid Association could be activated and requested to provide additional resources as necessary:
7 Northeast Illinois Area Mutual Aid Association
7 Mutual Aid Box Alarm System (MABAS 15)
7 Shabonna Fireman's Association
7 Three Rivers Spill Cooperative
Quarterly drills are conducted to assess and evaluate the emergency response effort at the Morris Plant. These drills include participation by various public emergency response organizations such as fire departments, Hazmat teams, police departments, U.S. Coast Guard, Grundy County Emergency Management Agency, sheriff's department, and the appropriate LEPC organizations.
The Morris Plant has a community alert (CAL) system available through the Grundy County Emergency Management Agency to notify the public of a potential or actual hazardous situation.
The Morris Plant is an active participant in the community planning process with the Grundy County Local Emergency Pla
nning Committee. A copy of the plant's Emergency Response Plan has been forwarded to the Office of Emergency Preparedness as per the requirements of 40 CFR 355.
The Morris Plant is an active member of the Chemical Industries Council of Illinois (CICI). The Morris Plant is an active participant in and is committed to the Chemical Manufacturers Association's (CMA) Responsible Care. initiative. We also conduct annual assessments of the Plant's compliance effort.
7.0 PLANNED CHANGES TO IMPROVE SAFETY (' 68.155g):
The Morris Plant constantly strives to improve the safety of the processes at the facility through the auditing process, the suggestion process and incident investigation process.
8.0 PROCESSES NOT COVERED BY THE RULE:
The Equistar Chemicals, LP, Morris Plant has determined that the following processes at this facility are not covered by the Rule:
7 Waste Water Treatment Plant (WWTP)
9.0 REVIEW AND UPDATE:
The RMP Coordinator at the Equistar Chemicals, M
orris Plant shall review and update the RMP as specified in 40 CFR 68.190 (b) and submit it in a method and format to a central point specified by the EPA prior to June 21, 1999.
The RMP Coordinator at Equistar Chemicals', Morris Plant shall review and update the offsite consequence analysis at least once every five (5) years. If changes in processes, quantities stored or handled, or any other aspect of the stationary source might reasonably be expected to increase or decrease the worst-case distance to the endpoint. The plan must also be updated:
7 Within five years of its initial submission or most recent update,
7 No later than three years after a newly regulated substance is first listed by EPA,
7 No later than the date on which a new regulated substance is first present in an already covered process above a threshold quantity,
7 No later than the date on which a regulated substance is first present above a threshold quantity in a new process,
7 Within six months of a change th
at requires a revised PHA or hazard review,
7 Within six months of a change that alters the Program level that applied to any covered process,
7 If the site is no longer subject to this part, the RMP Coordinator will submit a revised registration to EPA within six months indicating that the site is no longer covered.