Rohm and Haas Texas Incorporated - Executive Summary |
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Executive Summary for Rohm and Haas Texas Incorporated Accidental Release Prevention and Emergency Response At Rohm and Haas Texas Incorporated, 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 provides 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 A n 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 Stationary Source and Regulated Substances Our facility produces Acetylene using natural gas and a limited amount of oxygen. We produce acrylic and methacrylic acids and esters using a variety of chemicals and processing operations. 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: Toxic Chemicals: Ammonia Ammonia is received by pipeline and stored as a pressurized liquid in a horizontal tank capable of holding 180,000 pounds at 200 psig. The quantity is limited by automa tic and manual systems to 90,000 pounds. Ammonia is reacted with natural gas and air in the presence of a platinum gauze to produce HCN . It is also used in various neutralization processes around the plant. Hydrogen Cyanide HCN is produced by the catalytic reaction of ammonia, natural gas and air over a platinum gauze. It is stored as a refrigerated liquid in two separate, non-connected, widely-separated stainless steel tanks. Inventory is limited by policy to 3500 pounds in each tank. HCN is used as an intermediate in the production of methacrylic acid and its esters, methyl methacrylate and butyl methacrylate. Flammables Acetylene Acetylene gas is made by the partial oxidation of natural gas with pure oxygen. It is stored as a gas under 2 psig in a dry gas holder. The holder contains 18,900 pounds of acetylene. Acetylene is sold to a single customer. Propylene Liquid propylene is received into the plant via pipeline, and there is no storage tank. There are two long, in terconnected pipelines from the metering station to the process units, and each of the lines can contain 6,000 pounds. Propylene is used to produce acrylic acid via partial oxidation presence of a catalyst. 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. Key Offsite Consequence Analysis Scenarios PA'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 Ammonia The inventory of the tank is limited to 50% of capacity by automatic level controls and the operating procedures. The worst case for ammonia is the release of the entire tank inventory in 10 minutes. This will produce a cloud that can reach into the city of Deer Park, and could impact the North Campus of the Deer Park High School, San Jacinto Elementary School, Tidal Road, and the San Jacinto Battleground State Park in addition to surrounding plants in our area. Hydrogen Cyanide The inventory if HCN is limited by procedures and controls. The worst case for HCN is the release of the inventory of one tank into the diked area that surrounds each tank. This will produce a cloud that will not impact public receptors other than neighboring industrial plants and Tidal road. Alternative Release Scenario(s) Regulated Toxic Chemicals Ammonia The Alternative case for ammonia is a line leak. This will produce a cloud that will not reach into the city of Deer Park, and could impact only Tidal Road and the San Jacinto Battleground State Park in addition to surrounding plants in our area. Hydrogen Cyanide The Al ternative case for HCN is a line leak. This will produce a cloud that will not impact public receptors other than neighboring industrial plants and Tidal road. Worst-case Release Scenario(s) Regulated Flammable Chemicals Acetylene The Worst case release scenario for acetylene is a rupture of the product holder that would release the entire inventory of acetylene in 10 minutes, which then ignites. This scenario results in a overpressure that would affect Tidal road, but would affect no other offsite receptors, not even industrial neighbors. Propylene The worst case scenario for propylene is a rupture of the line such that the entire contents of both lines is emptied in 10 minutes, followed by ignition. This could result in a vapor cloud explosion that would cause an overpressure that would affect Tidal Road and the closest parts of the two closest plants. It would not affect the general public in Deer Park. {For each scenario that you have selected for reporting, provide a brie f summary that includes a description of the scenario (e.g., chemicals involved and quantities, equipment involved, assumed conditions), the estimated exposure distance, a list of the potentially impacted receptors, as well as administrative controls and mitigation measures to limit the exposure distances for each reported scenario. Keep each summary brief a short paragraph with lists of key issues will suffice.} Alternative Release Scenario(s) Regulated Flammable Chemicals Acetylene The alternative release scenario for acetylene is a leak in the product line that lasts 10 minutes, or until mitigation measures (blocking in isolation valves, beginning to apply water spray to disperse the cloud) can be applied. This scenario results in overpressure that would barely affect Tidal road, and would affect no other offsite receptors, not even industrial neighbors. Propylene The alternative case scenario for propylene is a leak in the line that lasts 5 minutes, or until mitigation (bl ocking in isolation valves, beginning to apply water spray to disperse the cloud) can be applied. This could result in a vapor cloud explosion that would cause an overpressure that can affect Tidal Road and the closest parts of the two closest plants. It would not affect the general public in Deer Park. 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. All of this information including all details has been shared with the general public in the area and with the Deer Park LEPC. The LEPC is using the information for a detailed review of the city's emergency response plans. 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 safe ty information - All of our processes have a comprehensive information package that is used to guide the choice of process and control technologies, operating parameters, and inspection intervals for equipment such as pipes, vessels, and protective systems. Process hazard analysis - All processes have been subjected to a PHA that was at least as rigorous as a HAZOP. These HAZOPs were used to define the scenarios used in this report. The accident scenarios found in HAZOPs form the basis of additional analyses which allow us to ensure that the integrity levels of all protective systems are high enough to protect both our employees and our neighbors. They also help us target the most important equipment for more frequent inspection. Operating procedures - Operating procedures include windows for safe operations and guides for trouble shooting which allow operators to keep the processes out of unsafe areas. Operators are involved in writing, reviewing, and updating operating proc edures. Training - Training is based on the operating instructions. Operators help determine the frequency of refresher training. Mechanical integrity - We have a comprehensive inspection and preventive maintenance system that ensures that equipment maintains its capability to contain the process chemicals. This system is being continuously improved. Management of change - Rohm and Haas Texas was a pioneer in the management of change and has a comprehensive, well-institutionalized MOC system. Employees at all levels are involved in the operation of the MOC system. Pre-startup review - The Pre-Startup Safety Review (PSSR) is integral to ensuring that any new or modified process is build as intended. It is the completion of hazard analysis to ensure that the analyses conducted are, indeed applicable to the process as built. PSSRs are part of the institutionalized MOC and PHA systems. Compliance audits - Compliance audits are performed every three years. Actions needed are entered into a computer-based action tracking system that automatically tells those responsible if completion of action items is taking longer than anticipated, so that remedial steps may be taken. Incident investigation - Rohm and Haas Texas also pioneered process safety incident investigations using multiple-cause, system-oriented techniques. Many technical papers and presentations came from this work. We continue to investigate process incidents using this technique so that we can gain all the information from each incident that we can, in order to prevent future incidents and to add to the body of information about each process. Employee participation - Employees participate in all aspects of the prevention program. Since 1978, Rohm and Haas Texas would not perform a HAZOP unless hourly employees were present. Operators help write operating instructions and perform much of the training for new employees. Operators and mechanics are expected to attend MOC reviews. Hot wo rk permit - Rohm and Haas has had a very effective Hot Work permit system for over 25 years. Contractors - Contractors are picked according to stringent standards of management, competence, and safety. Contractors are expected to adhere to the same standards of safety that our own employees do. As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Hydrogen Cyanide: Where possible, HCN lines are all-welded construction, and all welds are 100% X-rayed. Where flanges are required, we use 300# flanges and spiral-wound gaskets for maximum integrity, and flanges are inspected on a regular basis. Pumps for 100% HCN are of two types; in one system, the pumps are inside the tank, and leaks outside the process are impossible. In the other system, a magnetic drive pump having no seals is used, and leaks are, again, impossible. HCN detectors are mounted at strategic locations throughout the unit, and provide an excellent warning system. There are evacuation procedures at each HCN unit which are tested and drilled. Ammonia: There is a new, all-welded stainless steel ammonia line from the metering station to the unit. (Carbon steel is considered adequate for ammonia service, but we opted for the more costly choice to eliminate future concerns about external corrosion.) There are two tanks capable of storing ammonia, but only one is in service at any time. This allows maintenance to be performed at leisure on the tank that is out of service. The tanks are made from carbon steel and both are stress-relieved. There are excess-flow check valves in the tank outlets and in the line from the tank to the north end of the plant. These valves will slam shut on flow increases such as might be encountered upon line rupture or significant leaks. Acetylene: All large lines containing acetylene are packed with small-diameter tubing to prevent detonations. Pressure in acetylene systems is carefully controlled to prevent op erating in the area in which ignition would cause a detonation. Acetylene lines operate at no more than 22 psig, which is far below the pressure capability of the heavy pipe used. The pipe can contain a detonation. Where acetylene lines can be near vehicles, the lines are 12-inch XX heavy construction. This line can and has withstood vehicle impact with no damage at all. Propylene: The propylene lines are welded carbon steel; one is buried, the other is above ground. The buried pipe is coated and wrapped and is cathodically protected. As a matter of interest, if this line leaks, the leak will be dissipated by its travel through the ground. Unfortunately, we do not know how to model this, and the EPA lookup tables certainly cannot take this into account. The design pressure of the propylene lines is 1440 psig, while it operates at about 250-300 psig most of the time. The extra capability gives us an inherently safer means of being prepared for pressure surges, but there are a lso relief valves in the system to prevent damage to the pipelines. There are remotely-operated isolation valves in the line to allow isolation of a segment that happens to leak. There are vehicle barricades to protect above-ground parts of the line. There is no tank, so the only inventory is in the lines themselves. The vaporizer system is surrounded by propylene detectors. Note: All lines and vessels have inspection programs tailored to the hazards. 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 ensure that we are meeting our own high standards for accident prevention. Five-Year Accident History We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: Ammonia - There have been no releases of ammonia that met the criteria for the Five-Year Accident History. Hydrocyanic Acid - There have been no releases of HCN that met the criteria for the Five-Year Accident History. Acetylene - There have been no releases of Acetylene that met the criteria for the Five-Year Accident History. Propylene - There have been no releases of propylene that met the criteria for the Five-Year Accident History. 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. Our responders are trained in fire fighting at Texas A&M University fire school, and also in Hazardous Material response tec hniques. Furthermore, we coordinate our plan with the community emergency response plan. 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: As of the time of this submittal, we do not have any improvements planned. Certifications Within the past five years, the processes have had no accidental release that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the processes, entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMPlan. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true accurate, and complete. For all other covered processes, the undersigned also certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RMPlan is true, accurate, and complete. Printed Name: Katherine Pearson-Dafft Signature: Title: Risk Analyst Date: June 18, 1999 RMP Data Elements The following pages present 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 2 prevention program Program 3 prevention program Emergency response program |