ISP Technologies Inc, Texas City - Executive Summary |
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ISP TEXAS CITY PLANT Risk Management Plan 1. EXECUTIVE SUMMARY The ISP Texas City Plant is committed to operating in a manner that is safe for Texas City Plant workers, the public, and the environment. For example, as a member of the Chemical Manufacturers Association and the Synthetic Organic Chemical Manufacturers Association, ISP implements the principles of Responsible Care . to ensure a safe and environmentally sound operation. In addition, as part of this commitment, the Texas City Plant has established systems to help ensure safe operation of the processes at this facility. One part of these systems is a risk management program (RMP) that helps manage the risks at the Texas City Plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) rule 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at the Texas City Plant. This document is intended to satisfy the RMPlan executive summary requirements of the RMP rule and to provide the public with a description of the risk management program at the Texas City Plant. 1.1.1 Accidental Release Prevention and Emergency Response Policies The Texas City Plant is committed to the safety of Texas City Plant workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. The Texas City Plant implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, our trained personnel will respond to control and contain such releases. Texas City Plant evaluates each situation, evacuates workers as necessary, responds based on our capabilities and training, and if necessary, contacts the Texas City fire department to alert the local industrial mutual aid society (IMAS) to assist in controlling and containing the release and to prevent and/or reduce the consequences of the release. Texas City Plant, the local emergency planning committee (LEPC), and the fire department have also established a system to use for warning the community if an accident occurs that could threaten the community. The Texas City Plant Manager has overall responsibility for the development and implementation of the risk management program for EPA-regulated processes at company facilities. However, the specific responsibilities for certain aspects of that program have been delegated by the Plant Manager to other personnel who report either directly, or through other management personnel, to the Plant Manager. Those relationships are depicted on the organization chart maintained by the Plant Manager's staff. Specific responsibility for the implementation of the process safety management (PSM) and accident prevention program has been delegated to the plant Technical Services Ma nager. Similarly, responsibility for the RMP hazard assessment and risk management plan has been delegated to the plant Technical Services Manager. The emergency response program, including compliance with the RMP aspects of that effort, is the responsibility of the Plant Safety Manager. In keeping with our policy that safe operation is part of everyone's job, many other personnel are also involved in RMP activities on an ongoing basis. 1.2 The ISP Texas City Plant Regulated Substances The ISP Texas City Plant is a chemical manufacturing facility located in Texas City, Texas. Chemicals manufacturing commenced on this 330 acre site in 1967. ISP Texas City employs approximately 150 hourly and salaried personnel. We use the following chemicals as our feed materials: methanol, formaldehyde, ammonia, acetylene, butanediol, ethanol, isopropyl alcohol, propyl acetate, vinyl pyrrolidine, vinyl acetate, and propane. The ISP Texas City Plant makes a variety of products: butyrolactone, 2-py rrolidone, vinyl pyrrolidone, polyvinylpyrrolidones, various pharmaceutical intermediates, and personal care intermediates. Some of these feed materials and products are toxic or flammable substances that EPA has specifically listed in the RMP rule and are present in our process units above the specified EPA threshold quantity. In total, we have six (6) process units that are covered by the RMP rule. The following are the RMP substances we handle in covered processes: acetylene, anhydrous ammonia, formaldehyde, methylamine, propane, and vinyl acetate. 1.3 Offsite Consequence Analysis Texas City Plant performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance that could affect the public or the environment. The offsite consequence analysis consists of evaluating both worst-case scenarios and alternate case scenarios. The Texas City Plant does not expect a worst-case release scenario to ever occur. An alternative release scenario represents a release that might occur during the lifetime of a facility like the Texas City Plant. Alternate case scenarios can be used to help the improve the community emergency response plan. We have shared that information with the LEPC and other organizations involved in emergency response activities. It is also available to local residents and businesses. If you are interested in this information, please contact our Technical Services Department at (409) 945-3411. The main objective of performing the offsite consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance: When considering explosion of a flammable substance, people at the endpoint distance are likely to be knocked down by the blast. Windows could shatter, and the potential for structural damage to buildings exists, although a building coll apse is unlikely. People could be seriously injured by being knocked down by the force of the blast, by flying glass, or by falling objects. When considering the fire hazard of a flammable substance, people at the endpoint distance are likely to receive second-degree burns over the exposed parts of their bodies if they cannot quickly find cover or otherwise escape the heat of the flame. These burns are likely to require hospitalization. When considering the release of a toxic substance, most people at the endpoint distance would be able to walk away from the exposure without any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely. Some people who are particularly susceptible to the substance released could be incapacitated. At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effects would be less. Worst-case Release Scenarios The worst -case scenario associated with toxic substances in RMP-covered processes at the plant is a vessel failure in the 2-pyrrolidone Unit, resulting in a release of anhydrous ammonia, over a 10-minute period. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating this scenario. The impact of worst case toxic releases is summarized in the table below. The worst-case scenario associated with a release of flammable substances in RMP-covered processes at the plant is a vapor cloud explosion involving the full inventory of the largest storage tank containing acetylene. This scenario analysis does not take credit for any administrative controls to limit the storage inventory in the tank; therefore, the full tank inventory is assumed to release and ignite, resulting in an explosion. Although we have numerous controls to prevent such releases and to ma nage their consequences, no credit for mitigation measures was taken into account in evaluating this worst-case scenario. The impact of the worst case flammable release is summarized in the table below. RMP Chemical Toxic/ Flammable Release RMP Program Level Worst Case Scenario (see Footnote Below) Anhydrous Ammonia Toxic 3 1 Acetylene Flammable 3 2 Notes: 1) Will travel far offsite. 2) Since this facility is located in a populated area, the overpressure effects would reach offsite public and/or environmental receptors. We did not identify any worst-case scenarios that would affect public receptors other than the receptors affected by the scenarios reported above. Alternate Cas e Scenarios Three toxic and one flammable alternative release scenarios were evaluated as required by the RMP Rule. The alternate case scenario for toxic substance anhydrous ammonia is failure of the transfer hose, resulting in a release of anhydrous ammonia over a 30-minute period. The release duration is the approximate time necessary to identify, isolate, and stop the release. No other mitigation measures were taken into account in evaluating this scenario. The impact of alternate case toxic releases is summarized in the table below. The alternate case scenario for toxic substance formadehyde is failure of the transfer hose, resulting in a release of formaldehyde over a 30-minute period. The release duration is the approximate time necessary to identify, isolate, and stop the release. No other mitigation measures were taken into account in evaluating this scenario. The impact of alternate case toxic releases is summarized in the table below. The alternate case scenario for toxic substance vinyl acetate is failure of storage tank loading procedure, resulting in a release of vinyl acetate over a 30-minute period. The release duration is the approximate time necessary to identify, isolate, and stop the release. No other mitigation measures were taken into account in evaluating this scenario. The impact of alternate case toxic releases is summarized in the table below. The alternate case scenario for flammable substances at the plant is a failure of the gas holder between flights, resulting from the release of acetylene. The release will be detected by the operators immediately, and will be self-correcting. The impact of the alternate case flammable release is summarized in the table below. RMP Chemical Toxic/ Flammable Release RMP Program Level Alternate Case Scenario (see Footnote Below) Anhyd rous Ammonia Toxic 3 1 Formaldehyde Toxic 3 1 Vinyl Acetate Toxic 3 1 Acetylene Flammable 3 2 Notes: 1) Will not travel very far offsite 2) Since this facility is located in a populated area, the overpressure effects would reach offsite public and/or environmental receptors 1.4 Accidental Release Prevention Program The following is a summary of the general accident prevention program in place at the Texas City Plant. Because processes at the Texas City Plant that are regulated by the EPA RMP regulation are also subject to the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, and because the OSHA PSM requirements are very similar t o the EPA RMP requirements for chemical manufacturing facilities, this summary addresses each of the OSHA PSM elements. The PSM program at this facility has been extended by the Texas City Plant, where necessary, to satisfy EPA's Program Level 3 accident prevention program requirements. Employee Participation The Texas City Plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of process hazard analysis (PHA), incident investigation, and plant and process inspection teams. Employees have access to all information created as part of the Texas City Plant accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the Texas City Plant and addresses each accident prevent ion program element. In addition, the Texas City Plant has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. Process Safety Information The Texas City Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the Texas City Plant are assigned responsibility for maintaining up-to-date process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the Texas City Plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in their Process Operating Manuals. The Texas City Plant ensures that the process is maintained within these limits by using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The Texas City Plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for esta blishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis The Texas City Plant has a comprehensive PHA program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage those hazards. The Texas City Plant primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques available. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes re commendations for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team recommendations reviewed with plant management for evaluation and resolution. Implementation of safety improvements in response to PHA findings is based on corporate risk acceptance criteria. This ensures that potential accident scenarios with the highest risks receive immediate attention. All approved safety improvements being implemented in response to PHA team recommendations are tracked until they are complete. The final resolution of each recommendation is documented and retained. To help ensure that the process controls and/or process hazards do not deviate significantly from the original design safety features, the Texas City Plant periodically updates and revalidates the PHA results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and re commendations from these updates are documented and retained. Operating Procedures The Texas City Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and annually certified as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made to the process. In addition, the Texas City Plant operating procedures provide guidance on how to respond to events that result in exceeding safe operating limits for specific process or equipment parameters. The written operating procedures are readily available to operators in the process units and for other personnel to use as necessary t o safely perform their job tasks. Training To complement the written procedures for process operations, the Texas City Plant has implemented a company training program for all employees involved in operating a process. New or transferred employees receive basic training in Texas City Plant operations. The new or transferred employee is then given classroom training on the unit(s) to which they will be assigned. After successfully completing this training, a new operator begins the second phase of training, on-the-job training (OJT). This training consists of hands on training coupled with evaluations of both actual in the field evaluation of knowledge and skills and written evaluations of knowledge and skills. During OJT the new or transferred employee is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The Texas City Plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the Texas City Plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Texas City Plant personnel of any hazards that the y find during their work. This is accomplished by providing contractors with (1) information about safety and health hazards, (2) emergency response plan requirements, and (3) safe work practices prior to their beginning work. In addition, the Texas City Plant evaluates contractor safety programs and performance during the selection of a contractor. Texas City Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews The Texas City Plant conducts a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information. The purpose of the review is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The review team uses checklists to verify all aspects of readiness. A review involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The Texas City Plant has established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health ha zards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, management will correct the deficiency before placing the equipment back into service (if possible), or management of change will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Texas City Plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is su itable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The Texas City Plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control welding and other spark-producing activities, and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Texas City Plant has a comprehensive system to manage changes to process es. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change. Incident Investigation The Texas City Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective a ctions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to Texas City Plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Texas City Plant periodically conducts audits to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are c onducted at least every 3 years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to Texas City Plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. 1.5 Chemical-Specific Prevention Steps The processes at the Texas City Plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the Texas City Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures or human errors. In addition to the accident prevention program activities, the Texas City Plant has safety features on many units to help (1) contain/control a release, (2) qu ickly detect a release, and (3) reduce the consequences of a release. The following types of safety features are used in various processes: Release Detection * Hydrocarbon detectors with alarms in selected areas Release Containment/Control * Process relief valves that discharge to a flare to capture and incinerate process materials to prevent overpressure damage to equipment * Scrubber to neutralize chemical releases * Manual and automatic valves to permit isolation of the process * Automated shutdown systems for specific process parameters (e.g., high level, high temperature) * Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank) * Curbing or diking to contain liquid releases * Redundant equipment and instrumentation where needed (e.g., uninterruptible power supply for process control system, redundant firewater pumps) * Release mitigation systems * Fire suppression and extinguishing systems * Deluge system for sp ecific equipment * Trained emergency response personnel * Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 1.6 Five-year Accident History No releases of regulated substances have occurred from Texas City Plant in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site. 1.7 Emergency Response Program The Texas City Plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, plant evacuation plans and acco unting for plant personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the Texas City Plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to plant processes or facilities. The emergency response program changes are administered through the management of change process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Texas City Plant is coordinated with the Texas City fire department, local emergency planning committee (LEPC), and with offsite responders, Texas City I MAS, who would be called to support emergency response efforts if required. This coordination includes periodic meetings of the LEPC, which includes local emergency response officials, local government officials, and industry representatives. The Texas City Plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to participating in periodic LEPC meetings, the Texas City Plant conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. 1.8 Planned Changes to Improve Safety Texas City Plant constantly strives to improve the safety of its operations through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers. The Texas City Plant resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned during the next 5 years: * Construct formaldehyde tank wagon loading pad with sump to reduce the downwind hazard if a leak or spill occurs * Revise process instrumentation and/or controls for various storage tanks * Install new acetylene analyzer system in the Plant South Area * Annual review and revisions to personnel training programs |