Enron Methanol Company - Executive Summary

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RMP Executive Summary - Enron Methanol Company 
 
Enron Methanol Company's policy is to protect its employees, property, environment and the general public from any harm that may occur as a result of an emergency affecting this plant.  This plan complies with the policy of providing a safe work environment for all employees, contractors, visitors and neighbors.  It extends to the design, training and implementation of a comprehensive emergency management program that saves lives and reduces property damage in the unlikely event of an emergency. 
 
Prevention is the primary goal.  However if an emergency should ever occur, the immediate goal is to contain the emergency and its effects within facility boundaries, mitigate the incident as quickly as possible and prevent any threat to the general public and neighbors.  It is Enron Methanol Company's policy to operate in an environmentally responsible manner consistent with environmental knowledge, policy and regulation that best serves the nee 
ds of the employees, community and the company.  Life preservation is the prime consideration, so all procedures will be carried out in a manner to minimize risk to employees and emergency response personnel.  Rescue and medical activities have priority over all other actions.  
 
 
The Enron Methanol Company plant produces methanol from natural gas.  The process produces a syngas containing hydrogen and methane. Hydrogen and methane do not individually meet the threshold quantity requirements; however, the syngas mixture does and is therefore regulated as a flammable mixture under RMP.  Syngas is produced and consumed within the process and is not stored in significant quantities.  Finished methanol is not regulated under the RMP rules.   
 
This facility has no substantial amount of any toxic materials that are covered by this regulation.  
 
 
A worst case scenario is designed to be a theoretical exercise which calculates the potential impact on the community based upon extreme conditions p 
rescribed by the EPA.  Weather conditions are assumed to be the least favorable possible, existing safety systems and procedures can not be considered, and trained emergency personnel are assumed to stand idly by.  These assumptions make the worst-case scenario highly unlikely.  
 
Worst Case scenario (Flammable): 
 
Chemical: Syngas (a mixture including Hydrogen and Methane) 
 
Assumptions: 
7 Catastrophic failure of the largest single vessel containing syngas 
7 Immediate failure of 2 <" thick steel vessel walls 
7 Failure of all active safety systems 
7 Worst-case weather conditions (stable, low wind speed) 
7 Emergency response team and operations take no actions 
7 Total release - entire contents of vessel (2,812 lbs.) followed by a Vapor Cloud Explosion 
 
This endpoint extends to offsite areas. 
 
Alternative Case Scenario (Flammable): 
 
Chemical: Syngas (a mixture including Hydrogen and Methane) 
 
Assumptions: 
7 Case chosen is located near facility boundary to result in off site consequences 
7 F 
ailure of >" thick stainless steel vessel walls 
7 Active and passive safety systems work 
7 Emergency shutdown system isolates release in 10 minutes 
7 Most common weather conditions 
7 Total release - 95 lbs. followed by Vapor Cloud Explosion 
 
This endpoint extends to offsite areas. 
 
 
Enron Methanol Company follows OSHA PSM regulations in addition to other health, safety and environmental regulations appropriate to a chemical manufacturing facility.  By Corporate policy, we operate safely and with concern for the environment.  We take this responsibility seriously.  The plant is designed following recognized design practices and procedures.  Detailed operating procedures and training assure that the facility will be operated safely during normal and emergency situations.  A sophisticated control system monitors the operation of the plant and if necessary an emergency shut down system will accomplish a safe and orderly shut down.  Enron Methanol Company has conducted process hazard analys 
es to determine the risks that exist in our process and opportunities to reduce those risks.  Enron Methanol Company uses modern maintenance practices, tools and systems to keep equipment operating reliably and detect repair needs in their early stages.  To improve equipment reliability, Enron Methanol Company conducts mechanical integrity inspections and failure analysis to determine the root cause of failures.  Qualified personnel who have been trained in plant maintenance procedures maintain the plant.  A Management of Change system controls changes to equipment and procedures. 
 
 
There has been one incident at Enron Methanol Company in the last 5 years that meets the EPA Risk Management Program (RMP) reporting requirements: 
 
On October 12, 1994, an explosion occurred at the facility.  Community effects included road closures, shelter in place orders and black smoke.  The number of people affected in the community was estimated at 500 based on reports published after the explosion.   
Only minor injuries were reported.  During the seven month period following the incident, the facility was rebuilt using the latest available technology.  Several vessels were removed or replaced with smaller vessels resulting in a smaller process inventory.  The revisions include an upgraded plant control system and monitoring capabilities. 
 
 
The Emergency Planning and Response plan consists of four elements: prevention, preparedness, response and recovery.   
 
Prevention is supported by policies and procedures intended to assure the plant is operated in a safe manner.  Inspections and audits of practices assure that the policies and procedures are being followed.  Periodic reviews of the procedures and training serve to reinforce the importance of operating the plant in a safe manner. 
 
Preparedness includes development of emergency procedures, obtaining and installing emergency equipment and notification devices, development and training of a plant emergency response team, coordinatio 
n with neighboring companies, local authorities and CIMA (Channel Industries Mutual Aid).  The plant has a written Emergency Planning and Response Manual and a team trained to implement the plans contained in the manual.  The facility has a system of alarms, radios and telephones that can be used to communicate with employees neighboring facilities and local agencies.  Periodic drills are conducted for likely scenarios, and emergency pre-planning is conducted for many recognized emergency events.  A review is conducted following each drill to assess the effectiveness of these preparations.  
 
Response is conducted under the Incident Command System (ICS) as outlined in 29 CFR 1910.120.  There are ICS trained personnel on site at all times.  The Local Emergency Planning Committee (LEPC) and CIMA are the points of contact for offsite agencies. 
 
Recovery procedures include incident investigation, damage assessment, clean-up and restoration.  In addition, a review of the emergency response i 
s conducted to evaluate and improve the response plans for the future. 
 
 
Area gas detectors have been installed to rapidly detect leaks that might occur.   
 
A process simulator is being developed to allow more comprehensive operator training. 
 
We are constantly reviewing and revising existing procedures, developing new procedures, and researching methods to increase employee awareness.   
 
Enron Methanol Company has demonstrated a willingness to be involved with community programs, and to be a responsible good neighbor.  These practices are part of the management commitment.
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