Bayport Marine Terminal - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At Celanese's Bayport Terminal we are committed to operating and maintaining all of our processes 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:
7 A description of our facility and use of substances regulated by EPA's RMP regulation
7 A summary of results from our assessment of the potential offsite consequences from accidental chemical releases
7 An overview of our accidental release prevention program and chemical-specific prevention steps
7 A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
7 An overview of our emergency response program
7 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
Our facility handles commodity organic chemicals for shipping. At our facility, we handle the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release:
- Vinyl Acetate is handled for sale entirely in the merchant market. The material is stored on site in inerted atmospheric tanks.
- Formaldehyde is handled for sale entirely in the merchant market. The material is transferred from rail cars or trucks into drums on site until shipped.
- There are no flammables at the facility which are covered by the EPA regulation.
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employe
es, 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 scenarios and alternative release scenarios 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 Scenario - Regulated Toxic Chemical
A Vinyl Acetate (VA) Worst Case Scenario (WCS) was selected to represent the toxic chemicals WCSs at our facility since it reaches the farthest. In this case, using the EPA requirement for a WCS, the entire contents of our largest tank (35,000,000 pounds) results in a liquid spill and subsequent vaporization of the product. This scenario would produce a release with offsite consequences, reaching local public receptors. The only mitigation considered was a dike around the tank which would contain t
he entire amount.
Alternate Release Scenarios - Regulated Toxic Chemicals
The Alternate Release Scenario (ARS) for Vinyl Acetate (VA) is based on the rupture of the loading hose connecting piping from the shore to a barge. The Operator stationed in the area would isolate using remotely actuated valves and pump trip in less than ten minutes. This scenario results in a liquid release of 39,000 pounds of VA and subsequent vaporization. No credit was taken for containment systems in the area which could further reduce the release. Only industrial areas and public roadways would be affected.
The ARS for formaldehyde involves a rupture of the unloading hose. The Operator at the drumming station would detect the loss of flow and activate the isolation system which would close valves and trip the unloading pump. This scenario results in a liquid release of 5,300 lbs of formaldehyde in solution with subsequent vaporization. Any material released would be contained in a diked area m
inimizing the offsite consequences. Only industrial areas and public roadways would be affected.
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 Safety information
- Process hazard analysis
- Operating procedures
- Mechanical integrity
- Management of change
- Pre-startup review
- Compliance audits
- Incident investigation
- Employee participation
- Hot work permit
As part of our prevention efforts, we have implemented the following chemical-specific prevention steps:
In the vinyl acetate process:
- internal floating roofs on storage tanks to reduce emissions
- diked containment around each tank
- use of nitrogen blanketing in all storage tanks to avoid flammability
In the formaldehyde process:
- foam system in the drum
- remote isolation capabilities
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 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. We are in compliance with the OSHA process safety management rule and this RMP rule.
FIVE-YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at our facility. During the past five years here has not been a release involving materials covered under EPA's RMP that either had any offsite impact or a significant plant impact.
For each incident, whether it involves a covered chemical or not, we have conducted formal incident investigations to identify and correct the root causes of the events.
EMERGENCY RESPONSE PROGRAM
We maintain an i
ntegrated 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 protection workers, the public, and the environment during emergency situations. The Emergency Response program for Celanese's Bayport Terminal is combined with Celanese's Clear Lake Plant (a few miles away) for improved response. The combined Emergency Response is a member of CIMA (Channel Industries Mutual Aid), a consortium of area companies that coordinates and help each other during emergencies in which the individual plant's resources may not be sufficient to effectively handle the response.
PLANNED CHANGES TO IMPROVE SAFETY
Recommendations to improve the prevention of, and response to accidental chemical releases are generated through various mechanisms including Process Hazard Analysis, Incident Investigation, and employee recommendations.
is a list of improvements that have been implemented at the facility to help prevent and/or better respond to accidental chemical releases:
- Improved seals on floating roofs of storage tanks
- Installation of foam system in the drumming warehouse
- Installation of process controls to automatically stop transfers if vapor collection becomes unavailable
The following is a list of improvements that are being implemented at the facility to help prevent and/or better respond to accidental chemical releases:
- Reformatting Standard Operating Procedures to make them clear and concise and improve inclusion of human factors,
- Providing guidelines for conduct of shift relief to maximize the quality and quantity of information shared at shift change.
- Setting minimum standards for equipment labeling.