Elf Atochem North America, Inc. Crosby Plant - Executive Summary
A Risk Management Program has been implemented at Elf Atochem North America, Inc.'s Crosby, Texas production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The plan summary is organized to correspond with specific EPA RMP definitions and requirements, including:
-Elf Atochem's Policies to Protect Health, Environment, and Safety;
-Facility Identification and Regulated Substances in Covered Processes;
-Five-Year Accident History;
-Emergency Response Plan; and
-Planned Changes to Improve Safety.
ELF ATOCHEM POLICIES FOR HEALTH, ENVIRONMENT, AND SAFETY
Elf Atochem is committed to employee, public, and environmental safety by conducting its operations in a safe and responsible manner. This commit
ment is inherent to a comprehensive risk management program that covers areas such as equipment design and installation, plant operating procedures, maintenance, and employee training associated with the processes at the Crosby plant. The Risk Management Plan formalizes and documents these activities.
This commitment to health, environment, and safety (HES) starts with the CEO. Senior management routinely dedicates time to review HES matters. This emphasis on safety is carried through to the facility level, where the Plant Manager and the Safety Team regularly review safety performance, take corrective actions, and strive for continuous improvement. The success of Elf Atochem's HES programs is also reflected by a strong commitment to safety by employees and contractors.
Elf Atochem's HES programs include policies, procedures, standards, and guidance materials designed to fulfill Elf Atochem's commitment to health, environment, and safety. These materials include Risk Management
Program guidance to help our facilities prevent and/or reduce the risk of accidents.
FACILITY IDENTIFICATION AND REGULATED SUBSTANCES IN COVERED PROCESSES
The Elf Atochem Crosby faility is located at 18000 Crosby Eastgate Road in Crosby, Texas. The facility manufactures liquid organic peroxides which are primarily used in the production of plastic resins, polystyrene, polyethylene, polypropylene, PVC, and fiberglass. Certain substances used and produced within the facility are regulated substances under 40 CFR 68, the EPA Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability and for the Crosby plant include Sulfur Dioxide (SO2) and 2-Methyl Propene (Isobutylene).
TOXIC WORST CASE SCENARIO
The worst-case accidental release scenario submitted for Program 3 toxic substances involves a catastrophic failure of the Sulfur Dioxide (SO2) storage tank. Sulfur Dioxide is purchased and transported to th
e Crosby facility via pressurized tank trucks. SO2 is stored as a gas in a pressure controlled storage tank. Administrative controls limit the quantity of SO2 stored on-site to 90% of the storage tanks capacity. This quantity is assumed to be released over a 10 minute period and that the entire quantity is released as a vapor. Based on dispersion modeling, using the EPA Off-Site Consequence Analysis (OCA), and EPA assumptions, the resulting concentrations of SO2 from the worst-case scenario release caused off-site impacts.
It should be noted that the worst case scenario is recognized by regulatory agencies and Elf Atochem as an extremely unlikely event. Mitigation and prevention procedures and measures are implemented by Elf Atochem to reduce the risk of the worst case event occurring.
FLAMMABLE WORST CASE SCENARIO
The worst-case accidental release scenario submitted for Program 3 flammable substances involves a catastrophic failure of a 2-Methyl Propene (isobutylene) storage t
ank. Isobutylene is purchased and transported to the Crosby facility via pressurized tank trucks. It is stored as a gas in a pressure controlled storage tank. Administrative controls limit the quantity of isobutylene stored on-site to 90% of the storage tanks capacity. This quantity is assumed to be released over a 10-minute period. It is further assumed that the entire quantity is released as a vapor, which comes in contact with an ignition source, with 10% of the total released quantity participating in a vapor cloud explosion. Based on dispersion modeling, using the EPA OCA look-up tables, and EPA assumptions, the 1 psi overpressurization resulting from the isobutylene vapor cloud explosion caused off-site impacts.
Again, it should be noted that the worst-case scenario is recognized by regulatory agencies and Elf Atochem as an extremely unlikely event. Mitigation and prevention procedures and measures are implemented by Elf Atochem to reduce the risk of the worst-case event
WORST CASE RELEASE MITIGATION MEASURES
The multiple layers of preventive and mitigation measures in use at the Crosby facility make it very unlikely that either worst-case scenarios will occur. In the unlikely event that such a release occurs, Elf Atochem has mitigation measures in place to reduce any potential impacts.
In compliance with regulatory criteria associated with RMP evaluations, active mitigation systems cannot be considered in modeling worst-case scenario impacts; however, the significant planning and subsequent implementation that Elf Atochem has made in active mitigation measures could effectively reduce the risk associated with an RMP worst-case related incident. Mitigation measures include:
-Stationary fire monitors that could remove airborne vapors with water sprays;
-On-site emergency responders 24 hours per day as well as communications link with additional off-site responders and response equipment;
-A Community Alert Network (CAN) enabling the
facility to immediately notify the surrounding neighbors.
TOXIC ALTERNATIVE RELEASE SCENARIO
The alternative release scenario submitted for Program 3 toxic substances involves the failure of a 1" pipe from the SO2 storage tank to the Continuous Perester Unit's (CPU) process building. Mitigation measures to reduce this release are an excess flow valve on the line and a remote activated tank shut-off system. Evaluation of the alternative release scenario per EPA assumptions shows off-site impacts.
The alternative release scenario submitted for Program 3 flammable substances involves the failure of a 4" line from the isobutylene storage tank to the tank's pressure relief device system. Mitigation measure to reduce this release is the remote activated tank shut-off system. Evaluation of the alternative release scenario per EPA assumptions shows off-site impacts.
ALTERNATIVE RELEASE SCENARIOS MITIGATION MEASURES
While the Alternative Release Scenarios are, by def
inition, more likely to occur than the Worst-Case Scenario, they are still very unlikely to occur due to the facility's existing release and accident prevention program. If a release should occur, Elf Atochem has mitigation measures to reduce potential human health and environmental receptor impact. The prevention program elements in place at Crosby are:
-Remote shut-off valves on tank piping designed to shut down all flow from the storage tanks; thereby reducing the amount potentially released;
-Excess flow valves on tank process feed lines from the storage tanks designed to close in the case of a line failure; thereby reducing the amount potentially released;
-Stationary fire monitors that could remove airborne vapor with water sprays;
-On-site emergency responders 24 hours per day as well as emergency communications links with additional off-site responders and response equipment;
-A Community Alert Network (CAN) enabling the facility to immediately notify the surrounding nei
THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
The Elf Atochem Crosby facility has an accidental release prevention program in place to minimize the risk of hazardous chemical releases. This program is designed to address the requirements of 29 CFR 1910.119, Process Safety Management and the EPA Risk Management Program persuant to 40 CFR 68. The accidental release prevention program includes the following elements and activities:
-In-depth hazard analyses are completed every five years by qualified personnel using techniques approved under the OSHA PSM standard of 29 CFR 1910.119;
-Written operating procedures are used for training and directing the work of operators, who receive refresher training every three years;
-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety;
-A Management Of Change (MOC) system is in p
lace to ensure that process operating changes are managed safely;
-Critical equipment is inspected on a planned, periodic basis to ensure proper operating conditions;
-Pre-start up reviews are performed to satisfy conditions for safe operation prior to starting new or modified equipment;
-Incidents are investigated and actions taken as part of a continuous improvement effort;
-Routine audits are conducted to evaluate that safe practices are being followed;
-Storage tanks and associated equipment are designed and constructed in accordance with industry codes, standards (American Society of Mechanical Engineers - ASME), and practices;
-As part of the facility's Mechanical Integrity program, pressure vessels and transfer lines are inspected and tested according to the American Petroleum Institute (API) certified inspectors using API standards;
-All plant process components are inspected and monitored on a regularly scheduled basis as part of the leak detection and repair program;
-The risk of over pressure of pressurized storage tanks is addressed by monitoring the tank temperature and pressure controllers or by a system of relief valves;
-The risk of over filling of vessels is addressed by the use of trained operators who monitor tank level indicators and metering devices;
-The risk of unloading releases are addressed by using a vapor recovery system when unloading chemicals into storage tanks;
-Access to the facility is restricted through security barriers and trained security personnel, thereby minimizing the risk to the tanks of vehicular damage or sabbotage; and
-A safety permitting system is used to ensure routine and non-routine work is carried out after identification and implementation of safe work practices.
This systematic approach to process safety involves all the facility employees. Management and facility personnel strive for continuing improvements in accident reduction. The training, qualification standards, and safety awareness of our o
perations, maintenance, and emergency response personnel are key elements in reducing and mitigating accidents.
FIVE YEAR ACCIDENT HISTORY
There have been no accidental off-site releases of Sulfur Dioxide from our facility for the past five years.
There have been no accidental releases of 2-Methyl Propene from our facility for the past five years that have had an adverse impact on the community. There has been one incident at the facility which meets the EPA Risk Management Program accident criteria with respect to causing significant property damage on-site.
On November 6, 1998, an explosion occurred in one of the facility's production units. Due to mechanical pump problems, the preparation and transfer of the sulfated isobutylene intermediate with the organic peroxide intermediate was delayed. During this delay period, the temperature of the organic peroxide intermediate mixture rose. Upon completion of maintenance activites, the production p
rocess was continued by combining the two intermediate mixtures. Due to the elevated temperature of the organic peroxide intermediate mixture, the resultant mixture underwent a rapid decomposition. From this decomposition, approximately 180 pounds of isobutylene was released. No off-site injuries or property damage resulted from this incident. Property damage occurred on-site and was localized to the facility's production unit.
EMERGENCY RESPONSE STATEMENT
The Elf Atochem Crosby facility maintains a written Emergency Response Plan. The plan includes procedures for notifying civil authorities and the public in the event of an incident; documentation of proper first aid and medical treatment necessary to treat accidental human exposures; procedures for the use of emergency response equipment and for its inspection and testing; descriptions of the training programs for all employees in the relevant emergency response procedures; and the review and update of our response plan to re
flect changes at the facility and to ensure that employees are informed of these changes.
PLANNED CHANGES FOR HEALTH, ENVIRONMENT AND SAFETY
Safety has been a part of the culture at the Crosby facility for many years. An example of Crosby's dedication to safety is that in March of 1999, the facility achieved 16 years without a plant employee lost time incident. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. The Crosby facility is also continuing with its efforts to upgrade the tank systems of the regulated substances to provide remote access controls for these tank systems.
I certify to the best of my knowledge, the information, and belief formed after reasonable inquiry, that the information submitted is true, accurate, and complete. Furthermore, the Crosby facility is in the process of preparing it's Title V permit application to be submitted to the EPA
in April of 2000.