Roche Vitamins Inc., Freeport, Texas - Executive Summary |
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Roche Vitamins Inc. Freeport Site, a division of Hoffmann La Roche LTD, located at 1000 County Road 227 Freeport Brazoria County Texas is a manufacturer of raw beta-carotene. The plant sits on 770.50 acres off of highway 332. Beta-carotene is a pro-vitamin A with anti-oxidant properties and can be used as a colorant in foods and in feed for live stock. Regulated substances used or stored at this plant are anhydrous ammonia (54,180 Pounds) and acetylene (11,468 pounds). Roche Vitamins Inc., Freeport Site believes that prevention is the key element of all activities and measures have been incorporated to ensure safety and environmental protection. All levels of employees have the responsibility to exercise maximum care and good judgement in protecting the environment. It is the intent of the management of this plant to protect the environment while maintaining an effective operating plant. It is the responsibility of each employee to comply with this policy. We believe that envir onmental protection is an integral part of, and in no manner separated from, the operations of this plant. In recognition of this and in the interest of appropriate management practices, we will constantly work toward: 7 Proper operation of this plant in order to protect the environment. 7 Consistent adherence to required operating practices and procedures designed to prevent environmental incidents. 7 Conscientious observance of all federal (EPA), state (TNRCC), corporate, and plant environmental standards. 7 Minimize the generation and disposal of all waste materials, and where feasible, reuse and/or recycle materials. The corporate safety and environmental policy state prevention, continual improvement and compliance with laws and guidelines as priorities for all Roche sites. Roche Vitamins Inc. Freeport Site used PHAST, an industry-specific guidance, to create the worst case and the alternative release scenarios. ERPG-2: The maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing developing irreversible or other serious health effects or symptoms which would impair an individual's ability to take protective action. The worst case release scenario for anhydrous ammonia was conducted using two ammonia storage tanks that rupture and spill their contents instantly. The ERPG-2 /.14 mg/l would be 1.4 miles encompassing some industrial areas. There are no residents within the ERPG-2 circle. This release happening is very unlikely; the tanks were built to withstand pressures up to 250 psi. The system is mostly welded with flanges only at pumps. There is a leak detection system that will notify operations if a leak occurs, there is also a foam system covering the system. The alternative release scenario for anhydrous ammonia was conducted using a process leak found by the ammonia detectors. A total release of 1,133 pounds of ammonia, the ERPG-2/.14 mg/l would be .1 miles. This release would not impact anything offsite. This scenario was selected as the alternative because a leak at a flange would be more likely due to the pressure rating on the vessels. The worst case release scenario for acetylene was conducted using a release from two storage trailers which house 11,000 pounds of acetylene in cylinders manifolded together that instantly explode. The area impacted by the explosion could experience forces of 1 pound per square inch (psi)* or greater at distances up to .15 miles from the storage area. There are no residences within this impact area; it is kept completely within Roche's property. This scenario is unlikely to happen due to training and written procedures by Roche and the company delivering the acetylene, to ensure the trailers are at the correct pressure and show no signs of leakage. The alternative release scenario for acetylene was conducted using a release from one of the storage trailers which houses 5,500 pounds of a cetylene in cylinders manifolded together that instantly explode. The area impacted by the explosion could experience forces of 1 pound per square inch (psi)* or greater at distances .1 miles from the storage area. There are no residences within this impact area; it is kept completely within Roche's property. This scenario was selected as the alternative because one leaking cylinder on one trailer would be more likely to happen. Roche Vitamins Inc. Freeport Site is governed by OSHA's Process Safety Management Standard (PSM). Employees participate in all 14 elements of PSM including but not limited to Emergency Response and Incident Investigations, Process Hazard Analysis, and Pre-Startup Safety Reviews. Hoffmann La Roche Ltd. has specific standards set up to control and/or prevent environmental or safety incidents. One, the K-9, is a risk assessment on all systems, not just ones covered under OSHA's PSM standard or the EPA's Risk Management Plan (RMP). The K-9 like the Process Hazard Analysis must be reviewed and updated (if necessary) every five (5) years. The Freeport site works by Self Directed Work Teams and cross train in different areas of the plant, the working knowledge of the plant has increased and has helped eliminate environmental and safety hazards before they become an incident. All employees of the plant are trained periodically and are involved in training others in the areas they have expertise in. Roche Vitamins Inc. Freeport Site has had one accidental release of anhydrous ammonia in the last five years; the release was 1206 pounds on February 8, 1998. No one offsite was injured and no areas had to be evacuated. |