Johann Haltermann, Limited - Executive Summary

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EXECUTIVE SUMMARY 
 
Johann Haltermann, Ltd. is located on the north side of the Houston Ship Channel, directly across from the San Jacinto Monument. The facility was opened in 1981.  
 
1.  Accidental release prevention and emergency response policies: 
 
Haltermann's prevention policy is that we will strive to prevent any uncontrolled release of hazardous chemical from this site.  Haltermann is subject to OSHA Process Safety Management (PSM) and EPA Risk Managment Plan regulations.  These legislations were enacted to prevent accidental releases of certain flammable and toxic chemicals.  Haltermann goes beyond the requirements of the law and works to accidental releases of any chemical. 
 
Haltermann's emergency response policy is to respond as quickly as possible with adequate resources to stop the incident from spreading.  No secrets will be held from the public.  The response plan includes notification of local authorities and any potentially affected neighbors. 
 
2.  The stationary source  
and regulated substances handled. 
 
Haltermann provides distillation and reaction services to customers on a tolling basis.  The facility does not currently make any products sold under the Haltermann name.  The units at Haltermann typically run campaigns that take about one to two weeks then switch to a new product.  These campaigns take many different raw materials and produce several types of finished products.  At any given time there could be as many as four RMP chemicals in the plant and as few as one.  Hydrogen is the only RMP chemical that is at the Haltermann site every day of the year, and even in this case it is below the EPA Threshold Quantity of 10,000 pounds.    
 
Chemicals are received and shipped by tank truck, rail car and barge.  Access to the site is restricted to company employees, authorized customers and designated contractors. 
 
The RMP handled or expected to handled in the near future are: 
 
- Ammonia (anhydrous) - Received by tank truck; not currently handled at Ha 
ltermann; plans are in place for a unit that will handle ammonia by year 2000. 
- Isobutylene (2-Methylpropene) - Received by tank truck; material is in the plant about 25% of the year. 
- Isopentane - Received by tank truck; material is in the plant about 15% of the year. 
- Hydrogen - Received by pipeline; the only RMP chemical in the plant every day of the year; there is less than the EPA threshold quantity (10,000 pounds) on site at any given time. 
- Propylene Oxide - Received by tank truck; not currently used at Haltermann but plans are in place for      a reactions unit in late 1999. 
- Vinyl Acetate - Received by Barge; this chemical is kept in storage tanks about 15% of the year. 
- Future Flammable Chemicals - There are several flammable chemicals that Haltermann is filing with the EPA on a predictive basis.  These chemicals have not been handled by Haltermann but there is a remote chance of handling them in the future.  These flammable chemicals include: 
 
 1,3-Pentadiene 
 2-But 
ene 
 2-Butene-trans 
 1,3-Butadiene 
 2-Butene-cis 
 1-Butene 
 2,2-Dimethylpropane 
 2-Methyl-1-butene 
 1-Pentene 
 2-Methyl-1-butene 
 2-Pentene, (E)- 
 2-Pentene, (Z)- 
 3-Methyl-butene 
 Acetaldehyde 
 Butene 
 Isoprene  
 Pentane 
 
Haltermann will notify the North Channel LEPC and amend its RMP with the EPA if handling any of the above flammable chemicals make its Worst Case Flammable Scenario or Alternate Release Flammable Scenario obsolete.  
 
3.  The worst-case release scenario(s) and the alternate release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. 
 
NOTE: If additional information is needed on the scenarios below please contact Haltermann at 281-452-5951. 
 
Toxic Worse Case Scenario 
 
 The Worst-Case Scenario (WCS) is a total failure of a 545,000 gallon storage tank of vinyl acetate.  The material is totally contained in a diked area.  The vinyl acetate vaporizes into a cloud.  Haltermann's trained re 
sponse personnel do nothing to stop the spill or keep the vapor cloud from spreading.  The release could reach residential areas in the Channelview area and citizens at the San Jacinto Monument.   
 
Flammable Worst Case Scenario 
 
 The worst-case scenario (WCS) is a total failure of a 110,000 gallon storage tank that holds isopentane.  The material forms a pool inside a diked tank farm and begins evaporating.  After 10 minutes the evaporated isopentane explodes.  The explosion will mainly effect Haltermann's industrial neighbors. 
 
Toxic Alternate Release Scenarios 
 
 The alternate release scenario (ARS) for Vinyl Acetate is a 500 pound per minute  leak from an unloading hose that is contained in a diked area.  The spill is isolated an contained in 15 minutes.  A layer of foam can be sprayed over the chemical to stop evaporation while the spilled liquid is pumped to a holding tank.  The release  will only effect Haltermann's industrial neighbors.    
 
 The alternate release scenario (ARS 
) for Ammonia is a 500 pound per minute leak from an unloading hose with all of the ammonia vaporizing.  The release is isolated and contained within 10 minutes.   Ammonia dissolves in water.  A water spray can be directed at the release point to knock down the amount of ammonia that is released to the air.   The release will only effect our industrial neighbors. 
 
 The alternate release scenario (ARS) for Propylene Oxide is a 500 pound per minute leak from an unloading hose that is contained in a diked area.  The spill is isolated and contained in 15 minutes. A layer of foam can be sprayed over the chemical to stop evaporation while the spilled liquid is pumped to a holding tank.  The release will only effect our industrial neighbors.  
 
Flammable Alternate Release Scenario 
 
 The Flammable Alternate Release Scenario (ARS) is a 500 pound per minute leak of Isopentane from an unloading hose that spills into a diked area and starts a fire.  The radiant heat from the fire can cause second 
degree burns in 40 seconds.  This release will only effect Haltermann's closest neighbors.   
 
4.  The general accidental release prevention program and the specific prevention steps. 
 
 Haltermann's prevention program is compliance with OSHA Process Safety Management, 29 CFR 1910.119 and the EPA's Risk Management Program.    
 
Haltermann prevents releases by designing processes to handle chemicals safely.   
 
We conduct safety reviews on the processes to ensure they are capable of handling chemicals safely.   
 
We have documented operating procedures for operating and our equipment safely.   
 
We maintain our equipment so it operates safely.   
 
We inspect our equipment so it does not degrade over time.    
 
We train our personnel to operate and maintain our equipment in a safe and proper manner.   
 
We test our employees for drugs and alcohol, and give them annual physicals to ensure they are capable of safely operating our equipment.   
 
We conduct audits of our systems and procedures to en 
sure they are effective.   
 
5.  Five-year accident history. 
 
 Haltermann has had no reportable accidents involving the regulated chemicals in the past five years.   
 
6.  The emergency response program. 
 
 Haltermann's emergency response program is based upon compliance with five government agencies (EPA, OSHA, Texas General Land Office, Texas Natural Resource Conservation Commission and Coast Guard) rules and regulations.   
 
Haltermann has an extensive Emergency Response Plan manual that details steps to be taken should any foreseeable emergency situation arise. 
 
Small incidents can be handled internally by our Emergency Response Team. Our team is highly trained in fire fighting and spill/leak response techniques. 
 
If the emergency is too large for our Emergency Response Team, Haltermann can call for assistance from the Channelview Fire Department and Channel Industries Mutual Aid (CIMA) which can supply equipment and manpower from over 180 local petrochemical plants from the Houston  
area.                                                                                                
 
Haltermann has procedures to notify the public and various government agencies in the event of an emergency that might get past the fence-line.  Procedures are also in place to help the public recover from an incident caused by a release from our plant. 
 
Haltermann conducts quarterly drills and participates in the annual CIMA drill.  Haltermann is an active member of the North Channel Local Emergency Planning Committee (LEPC).  The Channelview Fire Department visits the site usually once a year.   
 
7.  Planned changes to improve safety. 
 
Haltermann will fully implement a Behavioral Based Safety Modification program by the end of 1999, which has been shown to reduce safety incidents by as much as 100%.  
 
Haltermann is continuously improving its Process Safety and Emergency Response programs as knowledge is gained through audits, training, drills and industry experiences.  
 
Haltermann ha 
s checked its computers and suppliers for Year 2000 compliance and expects no significant problems associated with the year change.
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