Aristech Chemical Corporation Pasadena Texas Plant - Executive Summary |
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ARISTECH CHEMICAL CORPORATION PASADENA, TEXAS PLANT ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Aristech Chemical Corporation's Pasadena, Texas 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 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 r egulated by EPA's RMP rule; * An overview of our emergency response program; * An overview of improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment. STATIONARY SOURCE AND REGULATED SUBSTANCES Aristech Chemical Corporation operates two world-scale plants at its Pasadena, Texas facility for the production of Phthalic Anhydride (PA) and 2-Ethyl Hexyl Alcohol (2EH). The facility is located adjacent to Route 225 on the Houston Ship Channel. The Phthalic Anhydride (PA) Unit came on line in August of 1983 with a current annual capacity of over 260 million pounds. The 2-Ethyl Hexyl Alcohol (2EH) Unit came on line in September of 1983 and has a annual production capacity of over 275 million pounds. The 2EH process utilizes substances that are on the EPA's List of Regulated Substances. Following is a list of these substances: Toxics - There are no toxic substances used in any of the proces ses at the facility that meet the EPA's threshold limits for those substances. Flammables - Chemical Total Quantity on Site (in lbs.) Use Propylene 1,400,697 Feedstock for 2-EH Process Propane 421,040 Byproduct of 2-EH Process 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 EPA's RMP rule requires that we provide information about the worst-case release scenario and alternative release scenario for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the expos ure distances for each scenario: Worst-case Release Scenario The 2-EH production process includes a horizontal propylene storage vessel that contains 385,768 lbs. of propylene when filled to capacity. The Worst Case Scenario is based on the failure of this vessel, resulting in the release of the entire contents of the vessel instantaneously. The released material vaporizes over a 10-minute period and is ignited, resulting in a vapor cloud explosion. Storage quantity of the propylene storage vessel is limited to 95% of the total capacity of the vessel by means of administrative level control established in Section PAS:PS:PRO:4A of the Pasadena Plant's Process Safety and Risk Management Manual. It has been determined that the resulting vapor cloud explosion would reach nearby off-site public receptors (industrial/commercial areas). Alternative Release Scenario The selection of the 2-Ethyl Hexyl Alcohol Plant process Alternative Release Scenario is based on a more likely event than the Worst Case Scenario. Many release scenarios were studied before the selection was made. This event involves a propylene supply pipeline-metering substation located near the fenceline within the facility. The event is based on the propylene metering substation piping being damaged by a maintenance crew working nearby with an overhead crane or backhoe. The result of the damage is a 1.7" diameter hole in the pipe. The damage to the 3" pipe results in a release rate of 5,850 lb./minute leak rate. The initial release of 10,200 lbs. of propylene vaporizes and finds an ignition source (a passing vehicle), resulting in a vapor cloud explosion. A total of 58,500 lbs. of propylene is released before the pipeline can be isolated. Electronic LEL sensing devices are utilized throughout the facility allow for rapid detection of this type of leak. These devices are connected to the Emergency Alarm System and will activate the Alarm System in the event a release is detected. In the event of fi re, explosion, or a release of a regulated substance from the process, 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. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Aristech Pasadena is in full compliance with OSHA's Process Safety Management Standard. This standard is a fully comprehensive prevention program designed to prevent accidental releases of hazardous chemicals. We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals through the requirements of OSHA's PSM Standard. Our management systems address each of the key areas of this successful prevention program including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre- startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors These elements of our prevention program work to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems establish 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. Over the last year and half, Aristech Pasadena has been actively addressing the issue of Year 2000 (Y2K) readiness. The plant has been systematically identifying, evaluating, testing, and upgrading (where necessary) computer hardware, software, process control equipment, safety systems and emergency protection equipment at the facility for Y2K readiness. In addition, impact assessments to evaluate potential business risks and exposures posed by Y2K have been conducted. Aristech Pasadena is also working to obtain assurances from vendors regarding readiness of their systems. The plant's Y2K activities have been communicated to Aristech Pasadena employees to enhance their awareness of the issues. The work on Y2K readiness is expected to be completed by October 1999. FIVE-YEAR ACCIDENT HISTORY Records are kept for all significant accidental chemical releases that occur at our facility. The following is a summary of accidental chemical releases involving materials at our facility covered under EPA's RMP rule during the past five years: There were no accidental chemical releases of covered substances that resulted in on-site or off-site injuries or property damage from 1994 until August 26th, 1997. On August 26th, 1997, an Operations Technician was injured on-site while pulling a sample from a sample point in the 2-EH process. Approximately < lb. of propylene was released when the glass sample container broke. The Operations Technician received a cut on the neck. No other accidental releases of covered subs tances resulting in on-site or off-site injury or property damage have occurred since August 26, 1997 through June 20th, 1999 (date of submittal). EMERGENCY RESPONSE PROGRAM An integrated emergency response/contingency plan is maintained, 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 Houston area "Channel Industries Mutual Aid Organization (CIMA)" and the local community emergency response plans. CHANGES TO IMPROVE SAFETY The following is a list of recent major improvements that we have implemented at the facility to help prevent and/or better respond to accidental chemical releases: * 1997 - The existing process computer control system of the facility was upgraded to a Honeywell TotalPlant DCS Control System that utilizes Global User Stations, High Performance Process Managers, and Total Plant History for more effective and efficient control of the operations of the plant. * 1997 - A fire water deluge system was installed over the Oxo Reactor process circulation compressor. * 1995 - A pipeline was installed for transferring propane/propylene from the plant to customers rather than transferring by tractor/trailer. This project resulted in eliminating the risk involved in loading two tractor/trailer rigs per day. * 1994 - A third propylene supply pipeline to the plant was installed which reduced the overall amount of propylene received in railcars and stored onsite. This project resulted in a reduction of over a half million lbs. of propylene inventory onsite and the risk associated with unloading these railcars. The following is a list of projected improvements planned to help prevent and/or better respond to accidental chemical releases: * Implementation of a comprehensive off-site air monitoring program for measurement of: 1)the amount of particulates in air as would be caused by a propylene/propane fire at the plant, and 2) any other air contaminants that may be released as a result of an emergency at the facility. * Continuous dialog and work in partnership with the surrounding communities and facilities of the area in our on-going efforts to reduce the overall risk to the neighboring communities and industrial facilities. |