Westhollow Technology Center - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention and Emergency Response Policy Westhollow Technology Center management and employees are committed to operating and maintaining all processes containing flammable and toxic materials in a safe and responsible manner. A program of hazard recognition, risk assessment, safe operation, and release prevention combined with emergency response, ensures the safety of employees and the public, as well as protecting the environment. A Process Hazards Analysis (PHA) has been conducted and revalidated on all processes covered by the OSHA 1910.119 Process Safety Management of Highly Hazardous Chemicals to evaluate and mitigate risk. Facility Description The Westhollow Technology Center conducts research and development activities using chemicals, polymers, fuels, and lubricants in laboratories and small pilot plant and development units. The facility in located on 209 acres and employs approximately 1250 scientists, engineers, technicians and administrative support staff. Potential risks to employees, the public, and the environment associated with the hazards of chemicals in use are managed by risk assessment, safe design, mechanical integrity, safe operating procedures, spill and release control plans, and a site emergency response plan which is coordinated with community emergency organizations. Stationary Source and Regulated Substances Assessment An assessment of the chemical and flammable inventories in use at the facility has determined that the total on-site ethylene inventory exceeds the threshold RMP planning quantity for flammable gas. Ethylene is used at the facility for several research and support projects including an on-site pilot plant operation. There are two stationary ethylene tube trailer unloading stations designed to safely receive and unload ethylene from tube trailers to supply ethylene to project users. Offsite Consequence Analysis Scenario - Ethylene Trailer Unloading Stations The worse case-modeling scenario was based on a 2,000-lb. release of ethylene from a single ethylene tube on the tube trailer. The EPA OCA model for the Westhollow Technology Center ethylene trailer unloading stations determined that the distance to endpoint is 0.10 mile. In addition, a refined modeling consequence analysis was performed using DNV Technica's PHAST 5.2 (Process Hazard Assessment Software tool). The refined model determined that the distance to end point is 0.15 mile (767 feet). The release was assumed to result in a vapor cloud containing the total quantity of ethylene that could be released from a single tube and the vapor cloud detonated. The endpoint for the consequence analysis of the worse case scenario is an overpressure of 1 pound per square inch (psi). The result of each analysis determined that there is no off-site impact as defined by the RMP requirements. The determined end point distances do not cross any site property line. Five Year Accident History A review of incident investigations and incident history for the site confirmed that there has not been any ethylene release for the past five years. Incident investigation procedures are in place and would be used to investigate any significant accidental release if one should occur and to identify and correct any root cause(s). These procedures meet the investigation requirements of the OSHA 1910.119 Process Safety Management of Highly Hazardous Chemicals. Emergency Response Program A Westhollow Technology Center Emergency Manual provides a written guideline for the emergency response organization in the event that an emergency situation (including fire, spill or release) should occur. The purpose of the plan is to provide for the safety and health of employees, the public and the environment during emergency situations. The plan also provides for ongoing training of site emergency response personnel. The plan is coordinated with the local fire department community emergency response plan. Certification Based on the criteria in 40 CFR 68.10, the distance to a specific endpoint for the worst case release scenario for an ethylene tube trailer is less than the distance to the nearest public receptor. Within the past five years, the ethylene tube trailers have had no accidental release that caused off-site impacts provided in the RMP rule (40 CFR 68.10(b) (1). In the event of fire, 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 defined in the site emergency response procedures. The Westhollow Technology Center emergency response activities have been coordinated with local emergency responders (fire department). Based on the consequence analysis and confirmation that no ethylene releases have occurred for the past five years, the Westhollow Technology Center facilit y qualifies as "Program 1 Facility". The undersigned certifies that, to the best of my knowledge, the information, and belief formed after reasonable inquiry, the information is true, accurate, and complete. Signature: (Hard Copy Signed) Name: T.A. Colangelo Title: Manager, Health, Safety and Environment Date: June 16, 1999 |