Solutia - Chocolate Bayou - Executive Summary |
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Solutia Inc. - Chocolate Bayou - Alvin, TX Solutia has officially adopted the following six commitments, expressing our intention to operate responsibly. 7 We will ensure that our operations and distribution systems are safe for employees, visitors, site contractors, communities and the environment. 7 We will make products that are safe when used responsibly. 7 We will keep our operations open to our communities and foster open communications with all of our stakeholders. 7 We will continuously improve our raw material and energy utilization efficiencies, to reduce our impact on the environment and improve the sustainability of our businesses. 7 We will encourage active participation in and positive contributions to safety, health and environmental stewardship by our employees. 7 We will search worldwide for new technologies that bring environmental, safety and health value to all of our stakeholders. By acting on these commitments, we expect to match the best practices of our pe er companies and to adhere to the Responsible Care guidelines developed by the Chemical Manufacturers Association. Solutia Products at Chocolate Bayou: Acrylonitrile is an important ingredient used to make nylon carpet fibers and acrylic fabrics. Nitrilotriacetate acid is used as a "detergent builder" to improve a detergents ability to clean. Formalin is a chemical intermediate used within the plant to produce other products such as Solutias Nitrilotriacetate acid and Monsantos Disodium imminodiacetate. Guest Companies Products Produced At Chocolate Bayou: Sorbic acid and Potassium Sorbate are widely used in food processing and as food preservatives. Sorbates are antimicrobial preservatives that inhibit the growth of certain molds, yeasts and bacteria in food products. This business is owned and marketed by Eastman Chemical Company and operated by Solutia Inc. Linear alkylbenzene is an ingredient used to make detergents. This material is the "surfactant" that enhances a d etergents ability to remove dirt and grease. This business is owned and marketed by Huntsman and operated by Solutia Inc. MHBA is an abbreviation for 2-hydroxy-4 - (methylthio) butanonic acid, which is an amino acid nutrient source used in animal feeds. The MHBA facility is owned by Novus International, Inc and operated by Solutia Inc. Disodium imminodiacetate is used to produce Roundup, the worlds largest selling herbicide. This product is owned and marketed by Monsanto Company and operated by Solutia Inc. 1.0 Accidental Release Prevention and Emergency Response Policies At Solutia Inc - Chocolate Bayou, 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 and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provid es a brief overview of the comprehensive risk management activities that we have designed and implemented, including: A description of our facility and use of substances regulated by EPA's RMP regulation A summary of results from our assessment of the potential offsite consequences from accidental chemical releases An overview of our accidental release prevention programs A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule An overview of our emergency response program An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment The certifications that EPA's RMP rule requires us to provide The detailed information (called data elements) about our risk management program 2.0 Stationary Source and Regulated Substances Our facility produces a variety of chemicals in our processing operations. Solutia operates the entire facility for Solutia, Novus, Eastman, Huntsman, and Monsanto. 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: Note: The totals reflected below represent chemical in process, storage, or transportation containers. Toxics Chemical Quantity (LB) Container Use Acrylonitrile Process 344,000 Process Vessels Finished Product Storage 27,571,500 3 - Tanks Finished Product Transportation 7,200,000 1 - Barge Finished Product Ammonia (anhydrous) Process 59,600 Process Vessels Raw Material Storage 335,000 2 - Storage Vessels Raw Material Hydrocyanic Acid Process 88,300 Process Vessels By Product/Raw Material Storage 225,000 Tank Raw Material Crotonaldehyde Storage 345,660 Storage Tank Raw Material Transportation 360,000 2 - Railcars Raw Material Formaldehyde (solution) Process 1,160,730 Process Vessels Finished Product Transportation 720,000 4 - Railcars Finished Product Hydrogen Fluoride (concentration >= 50%) Process 100,000 Process Vessels Raw Material Sulfur Dioxide Storage 10,000 5 - Cylinders Raw Material Flammables Chemical Quantity (LB) Container Use Propylene Process 67,080 Process Vessels Raw Material Storage 818,846 3 - Storag e Tanks Raw Material Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 3.0 Key Offsite Consequence Analysis Scenarios Solutia used RMP*Comp (1.06) to perform the offsite consequences analyses required under the EPAs Risk Management Planning (RMP) rule, which implements section 112 r of the 1990 Clean Air Act. EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative 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 Acrylonitrile Worst-Case Scenario A storage tank of Acrylonitrile [2-Propenenitrile] has a instantaneous l iquid spill to the ground and volatilization occurs with the duration being 10-minute release. This worst-case scenario would have off-site impacts. Alternative Release Scenario(s) Regulated Toxic Chemicals Acrylonitrile Alternative Release Scenario: Alternative Release scenario for Acrylonitrile [2-Propenenitrile] involves a failure of a relief vent, on a vessel, that breaks off due to corrosion releasing Acrylonitrile. This alternative release scenario would have off-site impacts. Ammonia (anhydrous) Alternative Release Scenario: Alternative Release scenario for Ammonia (anhydrous) involves an incident in which a tractor with a backhoe strikes the ammonia pipeline inflicting a two inch hole in the pipe and releasing Ammonia. This alternative release scenario would have off-site impacts. Hydrocyanic Acid Alternative Release Scenario: Alternative Release scenario for Hydrocyanic Acid is the failure of piping, creating a one-inch hole. This alternative release sce nario would have off-site impacts. Crotonaldehyde Alternative Release Scenario: Alternative Release scenario for Crotonaldehyde [2-Butenal] involves a bleeder failure, on the main transfer line, of Crotonaldehyde releasing the Crotonaldehyde. This alternative release scenario would have off-site impacts. Formaldehyde (solution) Alternative Release Scenario: Note: RMP*Comp will only allow the use of 37% Formaldehyde and our facility has 50% Formaldehyde. Solutia used the RMP*Comp for the calculation. Alternative Release scenario for Formaldehyde (50% solution) involves a nozzle to breaking and creating a four inch hole releasing the substance. This alternative release scenario would have off-site impacts. Hydrogen Fluoride (concentration >= 50%) Alternative Release Scenario: Alternative Release scenario for Hydrogen fluoride (concentration >= 50%) involves the failure of piping creating a one inch hole and releasing Hydrogen Fluoride. This alternative release scena rio would have off-site impacts. Sulfur Dioxide Alternative Release Scenario: Alternative Release scenario for Sulfur Dioxide involves the failure of the vessel creating a 0.5 inch hole and releasing Sulfur Dioxide. This alternative release scenario would have off-site impacts. Worst-case Release Scenario(s) Regulated Flammable Chemicals Propylene [1-Propene] worst-case scenario A storage vessel of Propylene has a instantaneous spill to the ground and volatilization occurs with the duration being 10-minute release. This release scenario would have off-site impacts. Propylene Alternative Release Scenario(s) Regulated Flammable Chemicals Alternative Release scenario for Propylene [1-Propene] is the failure of valve creating a one inch hole. This alternative release scenario would have off-site impacts. 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 systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Program Management of change Process Pre-startup review Compliance audits Incident investigation Employee participation Hot work permit Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Acrylonitrile * Process operators conduct area patrols to inspect equipment. * Ground level and aerial water hydrants provide spill mitigation. Also, foam spray connections provide spill mitigation. * Piping and vessels are identified and inspected on scheduled basis. The schedule is designed to identify potential failures. * Several Acrylonitrile detection sensors or located throughout the tank area that sound alarms in control room if an Acrylonitrile leak occurs. Ammonia (anhydrous) * Process operators conduct area patrols to inspect equipment. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potential failures. * Ground level and aerial water hydrants provide spill mitigation. * Remote isolation of major vessels and pumping system. * Several ammonia detection sensors or located throughout the process area that sound alarms in control room if an ammonia leak occurs. Hydrocyanic Acid * Process operators conduct area patrols to inspect equipment. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potential failures. * Ground level and aerial water hydrants provide spill mitigation. * Remote isolation of major vessels and pumping system. * Se veral hydrocyanic acid detection sensors located throughout the process and piping area that sound alarms in control room if an hydrocyanic acid leak occurs. Sulfur Dioxide * Process operators conduct area patrols to inspect equipment. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potential failures * Only 2000 lbs. are connected with process at one time. * Ground level and aerial water hydrants provide spill mitigation. Crotonaldehyde * Process operators conduct area patrols to inspect equipment. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potential failures. * Remote isolation of major vessels and pumping system. * Ground level and aerial water hydrants provide spill mitigation. Formaldehyde (solution) * Process operators conduct area patrols to inspect equipment. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potentia l failures. * Remote isolation of major vessels and pumping system. * Ground level and aerial water hydrants provide spill mitigation. Hydrogen Fluoride (concentration >=50%) * Process operators conduct area patrols to inspect equipment. * Water spray system to mitigate releases over small bore piping systems. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potential failures. * Ground level and aerial water hydrants provide spill mitigation. * Remote isolation of major vessels and pumping system. * Several hydrogen fluoride detection sensors or located throughout the process area that sound alarms in control room if an hydrogen fluoride leak occurs. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to en sure that we are meeting our own high standards for accident prevention. 5.0 Five-year Accident History We keep records for all significant accidental chemical releases that occur at our facility. In the past five years we have had three chemical releases involving materials covered under EPAs RMP rule that resulted in a OSHA recordable injury to an employee. Due to the OSHA recordable injuries we are including these incidents in our RMP executive summary. These three incidents would have no off-site impact. In 1999, release of Crotonaldehyde that lasted for one minute resulted in a OSHA recordable injury but no off-site impact. In 1998, release of Formaldehyde (solution) that lasted for 45 minutes resulted in a OSHA recordable injury but no off-site impact. In 1995, we had a release a of Acrylonitrile and Hydrocyanic Acid (13 lbs.) that lasted for fifteen minutes resulting in a OSHA recordable injury but on off-site impact. For each of these incidents, we have condu cted formal incident investigations to identify and correct the root causes of the events. 6.0 Emergency Response Program We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. The Integrated Contingency Plan (ICP) for the Solutia Inc. (Solutia) Chocolate Bayou Plant. The purpose of the ICP is to ensure the safety of those that may be affected by an emergency and to protect the environment from adverse consequences of an emergency. Consolidation of emergency response information into a single document will help to minimize any confusion that those involved in emergency response may have regarding which set of guidelines are appropriate for an incident. The types of emergencies covered by the ICP include: * Explosion * Fire * Spill or Leak * Bomb threat * Weather Emergencies - Hurricane - Tornado - Flood - Freeze * Utility Emergencies - Nitrogen in the Instrument Air - Steam Curtailment - Electrical Curtailment or Interruption * Medical Emergencies * Offsite Transportation Spill (Rail, Highways, and Waterways) * Offsite Pipeline Spill In general, the ICP follows the National Response team's Integrated Contingency Plan Guidance and addresses the Federal and state Requirements. The ICP consists of an Introduction, a Core Response Plan, and supporting sections. The Introduction discusses purpose and provides basic identification and location information about the facility. The Core Response Plan summarizes the systems and resources used for emergency management here at the Chocolate Bayou Plant and include flow charts that identify all steps that may be required when responding to an emergency. A complete notification list and telephone directory is also found in the Core Response Plan. The supporting sections contain a wide variety of detailed information relevant to emergency situations. Topics addressed include: * Detailed discussion of facility design, hazards, and preventive measures. * Ensuring safety of plant personnel, responders, and those in the community through adequate notification. * The roles and responsibilities of positions in the various response management systems * Specific actions to be taken by responders in various pre-identified emergency situations. * Resources and equipment available during a response. * Training and exercises/drills used to maintain preparedness. * Process used to evaluate plan performance and to make appropriate modifications. * Agreements with outside assistance providers. * Documentation of plan approvals and certification s. * Indexes that identify the locations of information within the ICP to satisfy various regulatory requirements. 7.0 Planned Changes to Improve Safety The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: * Revise vent system in our AN intermediate storage. * Relocate the AN 2 & 3 Propylene vaporizers. * Conducting Facility Siting needs for location. * Maintain a capital and maintenance program to enhance reliability of operating units, therefore reducing upset conditions. * Maintain OSHA Star Status * Maintain ISO 14000 Status 8.0 Certification Solutia Inc Chocolate Bayou has no Program 1 or 2 process. To the best of the undersigneds knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, a nd complete. Steve Ward Signature Print Name Site Manager June 14, 1999 Title Date 9.0 RMP Data The Risk Management Plan contains additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: Registration Offsite consequence analysis Five-year accident history Program 3 prevention program Emergency response program |