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Sasol North America Inc. Ethylene Storage Facility

Parent Companies:
Sasol LTD.
EPA Facility ID:
100000100945
Other ID:
Facility DUNS:
150056414
Parent Company DUNS:
102666872

Location:

Address:
2210 West Burton Street
Sulphur, LA 70663
County:
CALCASIEU
Lat / Long:
30.241, -93.412 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Sasol North America Inc.
Phone:
(337) 494-5450
Address:
2210 West Burton Street
Sulphur, LA 70663 -8402
Foreign Address:

Person responsible for RMP implementation:

Name:
J. Paul Warner
Title:
Responsible Care Manager

Emergency contact:

Name:
Steve Mercer
Title:
Safety & Health Manager
Phone:
(337) 494-5403
24-hour phone:
(337) 527-7061
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 494-5301
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
6
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 4, 2008
Inspecting Agency:
DNR Pipeline Safety
Using Predictive Filing:
No

Processes:

Ethylene Storage
RMP ID:
77167
CBI claimed:
No
Program Level:
3
NAICS:
All Other Pipeline Transportation (48699)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene [Ethene]
74-85-1
100,000,000
No
Propane
74-98-6
89,725
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Nov. 7, 2008
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
No
RMP ID:
52952

Deregistration:

Date:
Effective Date:
Reason:
Source reduced inventory of all regulated substances below TQs
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ethylene Storage)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Blast walls
Public OCA Chemical (in Ethylene Storage)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ethylene Storage)
CBI claimed:
No
Model used:
PHAST Dispersion Modeling
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Ethylene Storage, All Other Pipeline Transportation (48699)
Prevention Program ID:
45460
Safety Review Date
Sept. 19, 2008, since latest RMP submission
PHA Update Date
Sept. 9, 2008, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 10, 2008, since latest RMP submission
Training Review Date
Jan. 7, 2008, since latest RMP submission
Maintenance Review Date
June 25, 2008, since latest RMP submission
Maintenance Inspection Date
Aug. 18, 2008, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 31, 2008
Management of Change Review Date
April 4, 2008
Pre-startup Review Date
June 23, 2008
Compliance Audit Date
April 9, 2007
Compliance Audit Change Completion Date
April 9, 2009
Incident Investigation Date
Jan. 21, 2005
Incident Invest. Change Completion Date
April 1, 2005
Participation Plan Review Date
Feb. 29, 2008
Hot Work Review Date
Jan. 9, 2008
Contractor Safety Review Date
Jan. 9, 2008, since latest RMP submission
Contractor Safety Eval. Date
Oct. 16, 2008, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Oct. 3, 2008
Local Response Agency:
Local Response Agency Phone:
(337) 437-3512
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

LDEQ Facility ID Number 33785
Sasol North America Inc. Ethylene Underground Storage Facility
Risk Management Plan
Executive Summary

Sasol?s Ethylene Underground Storage Facility has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, training of highly qualified personnel, and considering safety in the design, installation, operation and maintenance of our processes. Our policy is to implement reasonable controls to prevent chemical releases. However, if a release does occur, our trained personnel will respond to control, contain, and mitigate the release.

Sasol is committed to Responsible Care? voluntary initiative for safe management of chemicals. Sasol follows the Responsible Care? Code of Management Practice, which is integral to the implementation of the Sasol Environmental, Health and Safety policies. The Responsible Care? Community Awareness Code of Management Practice and Sasol?s Community Awareness and Emergency Response policies are designed to assist emergency preparedness and for faster community right to know.

Sasol?s Ethylene Underground Storage Facility located in Sulphur, Louisiana, stores commercial grade ethylene for shipment by pipeline to various commercial users of ethylene. The Ethylene Storage Complex does not use, store, or produce any regulated toxics in sufficient quantity so as to be covered under the RMP regulations.

In February of 2001, the acquisition of CONDEA By Sasol Limited was complete. The name change from CONDEA Vista to Sasol North America Inc. became effective September 2001.

The only flammables used or stored in sufficient quantity at the Ethylene Underground Storage Facility so as to be covered under RMP regulations is ethylene and propane

Process Safety Information

The Ethylene Storage Complex maintains a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical pr
operties and associated hazards, limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information. Specific departments within the chemical complex are assigned responsibility for maintaining up-to-date process safety information. Employees are provided training on how to locate the information from various computer terminals and paper files located at the Ethylene Storage Complex.

Chemical specific information, including exposure hazards and emergency response/exposure considerations, is provided in material safety data sheets (MSDS). This information is supplemented by documents that address known corrosion concerns and known hazards associated within inadvertent mixing of specific chemicals. For the different process areas, the chemical complex has documented safety related limits for specific process parameters (e.g. temperature, pressure, composition, etc.). The chemical complex ensures that the processes are maintained within the limits using process controls, monitoring instruments, protective instrument systems, and highly trained personnel.


The Ethylene Storage Complex also maintains an electronic database, that is accessible by both employees and contractor supervision, which provides information about the design pressure and temperature ratings, electrical classification, etc. 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.

Process Hazard Analysis

The Ethylene Storage Complex has a comprehensive program to help ensure the hazards associated with the various processes are identified and controlled. Within this program, each process is systemically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.

The Ethylene Storage C
omplex primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations and the What-if/Checklist method for Process Hazard Analysis revalidations. The analysis are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The 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 when the team believes such measures are necessary.

The PHA team findings are made available to people associated with the Ethylene Storage Complex for comments and forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest rank receive immediate attention. All approved mitigation options being implemented in response to PHA findings are tracked until they are complete. The final resolution of each finding is documented and retained.

Operating Procedures

Operators, supervisors, and plant engineer?s work together to develop and maintain operating procedures. These procedures define how tasks related to process operations are safely performed. At the Ethylene Underground Storage Facility, 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:
?Steps for safely conducting activities
?Applicable process safety information, such as safe operating limits,
?Safety and health considerations, such as chemical hazards, personnel protective equipment required and steps to take if exposed to a particular chemical.

Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal
operation, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations.

Training

The Ethylene Underground Storage Facility trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training.

All new operators receive ten weeks of comprehensive training before ever being assigned to a specific operating unit. This training includes training on specific types of equipment, such as pumps and compressors, general overview of the process, properties and hazard substances in the process, and detailed review of complex procedures, such as, safe work practices and of emergency response. Oral reviews and written tests are used to verify that employees understand the training material before a new employee can report to a process unit. Once a new employee reports to a particular process unit, he receives detailed training with respect to process specific procedures and for specific tasks; he is allowed to begin work in a specific operating unit.


Refresher training 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 review and written tests are used to verify that employees understand the training before an employee can resume work in the process. The operators have been consulted in safety meetings and through questionnaires regarding effectiveness and frequency of training. Recommendations are reviewed and changes to the training program are implemented as appropriate.

Management of Change

The Management of Change program for the Ethylene Storage Complex evaluates and approves all proposed changes to chemicals, equipment, and procedures for covered processes to help ensure that a 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 program. All other changes must be confirmed through a full management of change program to help ensure process safety information and procedures are updated, and affected employees are notified of the change.


Pre-Startup Safety Review (PSSR)

The Ethylene Underground Storage Facility conducts a safety review of a new or modified process before the process is placed in service. The purpose of the PSSR is to ensure the safety features, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment in service. The review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems is operationally ready. The PSSR review team uses checklists to verify 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 Ethylene Underground Storage Facility has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, emergency shutdown systems, and rotating equipment (pumps and compressors) in a safe operating condition. The basic aspects of this program include (1) conducting training, (2) developing written procedures, (3) performing inspections and test, (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. Written procedures help ensure that work is performed
in consistent manner and provides 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, the equipment will be repaired in a timely manner. All outstanding deficiencies are tracked until such time a final solution has been implemented and documented.

Another integral part of the mechanical integrity program is quality assurance. The Ethylene Storage Complex incorporates quality assurance into equipment purchase and repairs. This helps ensure that new equipment is suitable for intended use and that proper materials and spare parts are used when repairs are made.


Safe Work Practices

The Ethylene Underground Storage Facility has a long standing safe work program in place to ensure worker safety. Examples of the program include (1) control of the entry/presence/exit of support personnel, (2) lockout/tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedures to conduct spark producing activities (i.e. hot work), and (5) a permit and procedures to ensure that adequate precautions are in place before entry into a confined space. These procedures, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.

Incident Investigation

The Ethylene Underground Storage Facility investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so similar incidents can be prevented. The Ethylene Storage Complex trains employees to identify and report any incident requiring investigation. The investigation is initiated within 48 hours of the incident. Depending on the incident, an investig
ation team may be formed. Results of the investigation are documented and appropriate changes are made.


Employee Participation

The Ethylene Underground Storage Facility maintains a written employee participation program to help ensure that safety and environmental concerns of the plant workers are addressed. The plant encourages active participation of personnel in safety, health, and environmental activities at the plant. Employees are consulted and/or informed about all aspects of the RMP prevention program including PHA?s (Process Hazard Analysis) and operating procedures.

Compliance Audits

The Ethylene Underground Storage Facility audits the covered processes to be certain that the prevention program is effectively addressing safety, health, and environmental issues. The complex assembles an audit team that includes personnel knowledgeable in the processes. 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 complex. The results of the audit are documented, recommendations are resolved, and appropriate enhancements made to the operations of the Ethylene Storage Complex.


Contractors

The Ethylene Underground Storage Facility has established a program to help ensure that contractor activities are performed in a safe manner. This program reviews the safety record of the contractors to ensure the plant only hires contractors who can safety perform the desired task. The complex communicates to the contractor supervisor the hazards of the process on which they and their employees will work, the plants safe work practices, and the plants emergency response procedures. The plant requires that the contractor supervisors train each of their employees on hazards and procedures specific to the complex site. The plant periodically reviews contractors training documents and work performances to help ensure that safe practices are followed.

Five Ye
ar Accident History

?The Ethylene Storage Complex has experienced zero events in the period of June 1994 to present, which are reportable under the RMP regulations.


Emergency Response Program

The Ethylene Underground Storage Facility emergency response program has been developed to meet the emergency planning, response, and notification requirements of the following regulations:
?OSHA 29 CFR 1910.38 (a)-Employee Emergency Action Plans
?OSHA 29 CFR 1910.120(q)-Hazardous Waste Operations and Emergency Response (HAZWOPER)
?OSHA 29 CFR 1910.119(n)-Process Safety Management of Highly Hazardous Chemicals
?OSHA 29 CFR 1910 Subpart L-Fire Protection
?LADEQ LAC 33.1? 3901- Notification Regulations for Unauthorized Discharge
?LDPS Title 33, Part V, Subpart 2, Ch.101? 1011-Release Reporting
?EPA 40 CFR Part 302.6-Notification Requirements
?EPA 40 CFR Part 355.40-Emergency Planning and Release Notification
?EPA 40 CFR Part 68- Risk Management Programs for Chemical Accidental Release Program
?EPA 40 CFR Part 355.30-Facility Coordinator and Emergency Response Plan
?EPA 40 CFR Part 112-Spill prevention, Control and Countermeasures Plan
?EPCRA 302-List of Extremely Hazardous Substances


The emergency response strategy for the Ethylene Underground Storage Facility is to prevent and/or control emergency situations via the use of engineering, design, and fixed protection systems. The plant has an Emergency Response Team that is available 24 hours per day, and trained to respond and take actions to contain, control, and mitigate any release that might occur. The team has access to on-site emergency equipment which is appropriate for situations that could possibly occur at the Ethylene Storage Complex. In addition to the considerable on-site resources, the Ethylene Storage Complex is a member of Calcasieu Mutual Aid. This membership allows the Ethylene Storage Complex (if needed) to draw on the emergency response resources of other industries in the immediate area. The following is
a partial listing of equipment which is available for emergency response:

Firepumps w/fixed firewater system
Fire Monitors
Fire Extinguishers
Dry Chemical Truck
Foam Pumper
Water Deluge Systems
Emergency Response Team

Drills are conducted to assess the emergency response effort at the Ethylene Storage Complex.

The Sasol North America, Inc. Ethylene Storage Complex is a participant in the community planning process cooperating with the Calcasieu Parish Local Emergency Planning Committee. A copy of the plant?s Emergency Response Plan has been forwarded to the Office of Emergency Preparedness per the requirements in 40 CFR 355.

Planned Changes to Improve Safety

The Ethylene Underground Storage Facility constantly strives to improve safety and reduce risk through auditing, suggestions from employees, incident investigations, and the use of proper engineering standards and specifications.

State of Louisiana Air Toxics Permit
Ethylene Dome-1952