Akzo Nobel Chemicals Inc. - Executive Summary
INTRODUCTION TO RISK MANAGEMENT PLAN (RMP) REGULATED SUBSTANCES |
Akzo Nobel Chemicals produces a variety of products at our Pasadena, Texas facility - inorganic catalyst products for the petroleum industry, organic monomers for the lens manufacturing industry, and organic peroxides for the plastic manufacturing industry. Three of our organic chemical manufacturing processes use regulated chemicals above the RMP applicability threshold. The organic monomer manufacturing process contains a diked allyl alcohol bulk storage tank (RMP toxic chemical). One of our organic peroxide manufacturing processes contains a diked 2-methyl-1-butene bulk storage tank (RMP flammable chemical), while another one of our organic peroxide manufacturing processes utilizes a refrigerated building for drum storage of isopropyl chloroformate (RMP toxic chemical).
ACCIDENTAL RELEASE PREVENTION and EMERGENCY RESPONSE POLICIES
Senior management within Akzo Nobel is very committed to chemical, employee, and p
lant safety at our facility. Their commitment is demonstrated by:
* maintaining a staff of safety professionals onsite to properly manage all aspects of safety;
* implementation of the Chemical Manufacturing Association's Responsible Care Initiative, which
requires member facilities to implement several different management codes of practices that
address various aspects of pollution prevention and process safety management;
* annual reviews by senior management to verify the implementation and execution of CMA's
Responsible Care Initiative;
* availability of corporate health & safety professionals for consultations;
* encouraging active participation in both the Local Emergency Planning Commission (LEPC) and the
the Channel Industry Mutual Aid (CIMA) Emergency Response Association, which is the local
emergency response association that would respond to an emergency at our facility; a
* requiring periodic safety compliance audits be conducted by Corporate Health & Safety Department
to ensure the continued safety compliance of our facility.
Our organic manufacturing processes are subject to the United States Department of Labor Occupational Safety and Health Administration's (OSHA) Process Safety Management Standard (29 CFR 1910.119). The Process Safety Management Standard, which is commonly referred to as PSM, requires subject facilities to perform specific accident prevention activities. USEPA's Risk Management Plan (RMP) also requires applicable facilities to develop an accident prevention program; RMP essentially adopted all of PSM accident prevention program requirements as RMP program requirements. The accident prevention program requirements that Akzo Nobel has implemented include:
* Conduct comprehensive process hazard analyses to identify potential causes of accidents
* Develop and maintain detailed operating proc
edures for all processes
* Provide comprehensive employee training on subject processes
* Periodically verify, through non-destructive testing, the integrity of key process components
* Develop Management of Change written procedure for reviewing proposed process changes
* Conduct pre-startup reviews whenever any qualifying modification is made to the subject process
* Conduct PSM and RMP compliance audits every 3 years
* Conduct incident investigations whenever an incident could have resulted in a catastrophic release
* Employee participation in conducting process hazards analyses
* Ensuring contractors are fully trained and periodic review of their performances
Several different management systems have been developed to ensure that chemical, employee, and plant safety and environmental protection is a top priority in everything we do. Akzo Nobel has received accreditation from the International Standards Organization (ISO) for
both a Quality Management System (ISO 9001) and an Environmental Management System (ISO 14001). Both management systems allow for safety and environmental reviews to be performed before any requested process change can be made at our facility.
Akzo Nobel will also be undergoing a voluntary safety inspection by OSHA on June 28, 1999 to determine whether our existing safety programs meets all of OSHA's Voluntary Protection Plan (VPP) program requirements. This is a voluntary program that Akzo Nobel has undertaken to ensure that our facility's existing safety program meets or exceeds all of OSHA's safety requirements. Once accepted into OSHA's program, the site will undergo periodic inspections by OSHA to ensure the continuation of our safety efforts. Volunteering for OSHA's VPP program is yet another example of how the site has made a commitment in ensuring the highest degree of chemical, employee, and plant safety.
WORST CASE RELEASE SCENARIO
TOXIC CHEMICAL - Should our 55,00
0-pound capacity allyl alcohol bulk storage tank ever fail, the entire contents of the bulk storage tank would be contained within concrete diking; the associated release rate of material evaporating into the atmosphere would be approximately 1.78 pounds per minute. Based upon the exposed surface area of the allyl alcohol bulk storage containment diking and the above release rate, the USEPA's May 1996 Offsite Consequence Analysis Guidance predicts an offsite impact of 0.22 miles could occur should our bulk tank ever fail. This estimated offsite impact distance does not take into account any active mitigation controls that Akzo Nobel would employ to reduce both the onsite and offsite risks, such as utilization of fire-fighting foam to suppress the evaporation of allyl alcohol and hence reduce the overall exposure impacts.
FLAMMABLE CHEMICAL - Should our 41,000 capacity 2-methyl-1-butene tank truck ever fail, the entire contents would be contained within concrete diking; the associate
d release rate of material evaporating into the atmosphere would be approximately 497 pounds per minute. Based upon the exposed surface area of the 2-methyl-1-butene bulk storage containment diking and the above release rate, the USEPA's April 1999 Offsite Consequence Analysis Guidance predicts an offsite impact of 0.14 miles. The amount of material used to calculate the above release rate was in accordance with the guidance published in the May 26, 1999 Federal Register. The estimated offsite impact distance does not take into account any additional and existing mitigation controls that Akzo Nobel would employ to reduce both the onsite and offsite risks involved with an accidental release of this material, such as utilization of fire-fighting foam or the existence of a secondary containment sump. Utilization of fire-fighting foam which would suppress the evaporation of 2-methyl-1-butene and correspondingly reduce the overall exposure impacts. Use of the secondary containment sump
within the concrete diking of the tank truck unloading area would also reduce the overall exposure impacts. However, because the secondary containment sump requires a pump to remove any accumulated material, the overall capacity of this sump may not be totally available during a catastrophic failure of the 2-methyl-1-butene storage tank. Therefore, the reduced release rate associated with utilization of this secondary containment sump was not taken into account for the worst case flammable analysis. If the full containment capacity of the secondary sump would be taken into account, the associated release rate or the worst case flammable scenario would be reduced from 497 pounds per minute to 30 pounds per minute.
Akzo Nobel is presently considering the installation of a 53,000-pound capacity 2-methyl-1-butene bulk storage tank to eliminate tank truck storage of this material. The surface area of the containment for the proposed bulk storage tank would be less than the surface are
a of the containment for the tank truck storage currently being used for the worst case analysis (685 ft2 versus 2368 ft2). Therefore, the worst case off-site impact distance for the proposed 53,000-pound bulk storage tank would be less than the offsite impact distance indicated in the original RMP submittal; the revised worst case off-site impact distance would be approximately 0.09 miles versus the indicated 0.14 miles. Having a permanently installed 2-methyl-1-butene bulk storage tank will improve the safety associated with handling this material and also reduce offsite impacts should a catastrophic event ever occur.
ALTERNATE RELEASE SCENARIOS
Allyl Alcohol - various equipment/operating scenarios were evaluated to determine which, if any, could cause off-site impacts. The entire organic monomer manufacturing process area is contained on a concrete slab with concrete diking; the surface area of the concrete containment is larger than the surface area of any one-centimeter de
ep pool of material that would form from failure of any applicable process equipment or vessel. Therefore, failure of the process vessel that would cause the largest pool of material to collect within the containment, which would also cause the largest amount of material to volatilize into the atmosphere (largest release rate), was selected for the alternate release scenario (i.e. failure of Azeo Buffer Tank). Since the effective surface area of the containment for the entire organic monomer manufacturing processing area is larger than the surface area of any "pooled" material that could physically form, no reduction in release rate (evaporation into the atmosphere) would be experienced. Therefore, even though passive mitigation is available and indicated within the RMP, no reduction in release rate occurred. Also, no active mitigation (application of fire-fighting foam or immediately draining any spilled material into our wastewater treatment system) was taken into account for t
he alternate release scenario of allyl alcohol.
2-Methyl-1-Butene - since this material is only used in one process vessel that is operated on a batch basis, the amount of material dosed into the vessel was selected as the quantity released for alternate release scenario purposes. Even though the associated process area is contained on a concrete slab, no passive mitigation controls were considered in the evaluation. Also, even though that fire-fighting foam would be applied as a precautionary measure during any release of this material, no active mitigation controls were considered in the evaluation.
Isopropyl Chloroformate - since this material is only used in drum quantities, the amount of material contained in one 55-gallon drum was selected as the quantity released. Even though the material is stored in a closed refrigerated building and the process area is contained on a concrete slab, no passive mitigation effects were considered for the alternate release scenario. The fu
ll extent of the release rate associated with a one-centimeter deep pool of material was evaluated rather than using 10% of the release rate quantity allowed by the Offsite Consequence Analysis Guidance (releases inside closed buildings).
FIVE-YEAR ACCIDENT HISTORY
Akzo Nobel Chemicals has not had any accidental releases of either allyl alcohol, 2-mehtyl-1-butene, or isopropyl chloroformate which required any of our employees to seek medical attention or resulted in any off-site impacts to be experienced.
EMERGENCY RESPONSE PROGRAM
Akzo Nobel Chemicals is subject to various Occupational Safety and Health Administration (OSHA) and United States Environmental Protection Agency (USEPA) emergency response program regulations. A detailed written emergency response plan has been developed and addresses how we would promptly and efficiently respond to onsite emergencies.
All onsite Emergency Response Team members are trained in accordance with federal emergency response training requir
ements given at 29 CFR 1910.120; bi-monthly and annual emergency response training is conducted to maintain the overall readiness of the emergency response personnel and equipment. The site also conducts four real-time emergency drills annually, with at least two of the exercises involving simulated hazardous material releases. Akzo Nobel is a member of the Channel Industries Mutual Aid (CIMA) Association, and participates in an annual drill involving member CIMA companies. Our site also undergoes periodic site inspections by CIMA to ensure our overall level of emergency response readiness.
Should an emergency event ever occur onsite, the public would be informed of the event by a representative of Akzo Nobel Chemicals placing a recorded message on the local Community Awareness Emergency Response line (281-476-CAER or 281-476-2237). The person with overall responsibility for coordinating our response to an onsite emergency (Incident Commander) has the responsibility of ensuring t
hat all agency and community notifications are promptly made.