Haldor Topsoe Bayport Facility - Executive Summary |
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Haldor Topsoe, Inc. manufactures and sells catalysts that are used by customers in the petrochemical and fertilizer industries. The company also manufactures environmental catalysts that are used to control emissions in industrial applications, including electrical generation and mineral smelting. An important aspect of customer support is research and development. As a result, the company also operates pilot units that are used to demonstrate and improve industrial applications of our catalysts. The manufacture of catalyst primarily deals with the processing of inorganic materials including acids, ammonia solutions and metal salts. The pilot units primarily deal with industrial gases. As a result, propane and other hydrocarbons may be onsite intermittently. 1. Accidental Release Prevention and Emergency Response Policies: The safe and environmentally responsible operation of our processes is a prime consideration in the design, construction and operation of units at the Haldor Topsoe, Inc. Bayport facility. The company has established corporate environmental and safety policies that reflect the commitment to comply with all applicable state and federal regulations. Systems and procedures have been established to: ' minimize the potential threats to the safety and health of our workers and the surrounding community, and ' protect the environment. Process(es) regulated under Process Safety Management or Risk Management Plan regulations are covered by the Integrated Safe Operating System (ISOS) for the safe design, construction, operation, maintenance of processes and ongoing system improvement. a) Accidental release prevention is a principal goal in many programs: i) Process design and construction follow good engineering practices and utilization of appropriate safety devices. ii) Employee training on the hazards associated with the chemicals used in each of the processes, operating procedures, how to prevent releases, and response actions, among other sa fety training programs. iii) Procedures for the safe operation and maintenance of processes associated with hazardous chemicals. iv) The company has an Emergency Response Policy. The program that is in place to implement that policy is described in more detail in Section 6 of this document. 2. Stationary Source and Regulated Substances: The flammable chemicals, propane and the flammable mixture comprised of propane/propylene, are the only chemicals onsite that meet the applicability provisions of the RMP regulations. The facility has, or may have, the following regulated materials on site: a) Propane and propane/propylene flammable mixture. These are the feed and product (respectively) of a pilot unit that operates intermittently. The unit is used to demonstrate a process that removes hydrogen from saturated hydrocarbons to form olefins. Both RMP and PSM regulations apply to this process. b) Ammonium hydroxide (>20%). It is handled in quantities below the threshold identified un der RMP regulations, therefore RMP requirements do not apply to this material at this site. It is used as a raw material in the Hydrotreating Catalyst Manufacturing Unit. c) Ethylenediamine Solution. This material is purchased in a diluted form that has a partial vapor pressure that is less than 10 mm HG. Therefore it to is exempt from regulation at this site under RMP provisions. The purchase of a diluted solution was the result of a raw material substitution to achieve a risk reduction. It is used as a raw material in a catalyst manufacturing unit. 3. Key Offsite Consequence Analysis Scenarios: a) Worst-Case Scenario (WCS)- Failure of the interconnected tanks used for the storage of propane and propane/propylene mixture. As required by the RMP regulations, the assumptions for the WCS are that the tanks are filled to maximum capacity, in this case 137,900 lbs., the entire contents of the tank(s) are released and find an ignition source, resulting in an explosion in which 10% of the released quantity participates. Although several active mitigation measures are in place to prevent this type of incident, they are assumed to fail in this scenario. The endpoint of 1 psi would result in offsite impacts. b) Alternate Release Scenario (ARS)- We have identified two scenarios: i) The shearing of a valve at the base of the product tank (flammable mixture containing propane and propylene), destroying the excess flow valve that would stop flow from the tank. This scenario assumes the tank has the maximum amount of product that might be expected to be in the tank and associated piping based on operating procedures and administrative controls, 50,000 lbs. The entire contents of the product tank empty to the undiked ground, the vapor finds an ignition source, which results in an explosion of 30% of the vapor. The endpoint of 1 psi would result in offsite impacts. The failure of active mitigation measures in this case was considered because all scenarios that were rev iewed in which the mitigation measures were operable, resulted in no offsite consequences. ii) While loading the product into a LPG truck, the transfer hose fails, releasing the contents of the hose and the piping. The excess flow valve on the truck closes, and the fusible link that is part of the emergency shutdown system closes the valve at the loading station stopping the release within 30 seconds, releasing 150 lbs of propane/propylene mixture. There are no offsite impacts as a result of this scenario. Additional mitigation to prevent or minimize the effects of this scenario include: (1) Operator in constant attendance during loading/unloading operation, (2) Automatic shutoff valve, (3) Local and distant switches that can activate shutoff valve, (4) Manual valve operation, (5) Fire monitors in area to deluge area with water to knock down vapors from release, (6) Hot Work Permit Program that restricts the use or presence of ignition sources in the area. No potentially spark-produ cing activity is allowed in the area while a truck is being loaded or unloaded, (7) Controlled access to the process area. 4. General Accidental Release Prevention Program and Chemical Specific Steps: a) As stated above, covered processes under PSM & RMP regulations are also covered by the company's Integrated Safe Operating System, a management system designed to comply with EPA and OSHA regulations for prevention of accidental releases. It includes programs for process safety information, employee participation, training, process hazards analysis, operating procedures, mechanical integrity, management of change, pre-startup safety review, incident investigation, the hot work permit program, contractor safety, document control procedures and program audits. b) Process specific procedures and prevention measures apply to the pilot unit that contains the flammable chemicals: i) Automatic and manual shutdown systems triggered by critical parameters in the process. Safety shutdown syste m complies with ISAI84 standards. ii) Alarm systems that warn or inform operator of changes in process associated with important process parameters. All critical parameters tied to shutdown system. iii) Operator constantly monitors process on computerized system in control room. (This system is Y2K compliant) iv) Administrative controls regarding: (1) Volume of regulated material in storage (2) Activities in area during loading/unloading process v) Operator frequently in unit monitoring local instrumentation. vi) Unit operators able to be in constant radio contact with each other and supervisor in the plant. vii) The process vessels and piping can be purged with nitrogen automatically (in the event of a shutdown) or manually. Operating procedures indicate this as the appropriate corrective action in many cases for certain process deviations. viii) The storage tanks have a protective fire coating to prevent heat-related releases. ix) Relief valves preventing over-pressurization are routed to a flare. x) Automatic and remote valve controllers can isolate and limit release. xi) Process vessels meet ASME codes. 5. Five year Accident History: The presence of this material at this facility is recent. There has not been an accidental release of this material. The company has operated since 1966 and has not had a release of any chemical that resulted in offsite impacts. 6. Emergency Response Program a) Emergency response preparedness is an important part of our safety and environmental programs by ensuring that we are able to address and minimize the effects of mishaps or incidents that might occur. The program includes: i) Emergency Response Policy that identifies responsibilities and program requirements. ii) Emergency response training for all plant employees, with specialized training for Hazardous Materials Response Team members. iii) Fire fighting training for all members of the Fire Brigade. iv) Company is a member of a mutual aid association that is capabl e of providing support equipment and personnel within a few minutes in the event of an emergency. v) Our plan is coordinated with the local responding fire departments and the LEPC. vi) Procedures for addressing incidents associated with specific substances that have the potential to be released in volumes sufficient to constitute an emergency. vii) Procedures for notifying plant personnel, potentially affected neighbors and communities, outside response organizations, the LEPC, federal and state agencies, local medical facilities and other organizations that may be needed in the event of an emergency. viii) A 2000 gpm fire water pump and the ability to have a pumper-truck from responding organization utilize an additional water source to provide additional support if needed. 7. Plans to improve safety: a) The company has an active safety suggestions program that is available for all employees to submit suggestions for improving any aspect of safety throughout the plant. An incentive program is in place to encourage participation. b) Since the covered process operates intermittently, at the end of an operational run, ISOS Program elements are reviewed for effectiveness and problem identification. Corrective actions are then taken to resolve identified problems. c) The nature of a pilot plant implies that the unit may be modified to improve the process and its safety. All such changes will be done under the Management of Change Procedure. This provides opportunities for additional safety reviews or Process Hazards Analyses to be conducted. |