Evans Houston Corporation - Executive Summary |
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Executive Summary for Evans Houston 1. Accidental Release Prevention and Emergency Response Policies We at Evans Houston are committed to employee, public and environmental safety. This commitment is inherent to our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled The Evans Houston facility's primary activities are repackaging and warehousing of chemicals. Evans either repackages or warehouses up to a maximum of 11 regulated substances at our facility. These substances are listed below. Evans receives the regulated substances in bulk and packages the products for customer distribution. Drummed products are then warehoused or shipped depending on customer specifications. Inventory is dependent upon customer orders and not all regulated substances are present onsite at a given time. Chemical CAS No. Toxic Substances: Acrylonitrile 107-13-1 Allyl Alcohol 107-18-6 Cyclohexylamine 108-91-8 Ethylenediamine 107-15-3 Formaldehyde (37%) 50-00-0 Toluene 2,4 diisocyanate 584-84-9 Toluene 2,6 diisocyanate 91-08-7 Toluene diisocyanate 26471-62-5 Flammable Substances (Liquid Form): Isopropylamine 75-31-0 Pentane 109-66-0 1-Pentene 109-67-1 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario Evans is the operator of a stationary source that has more than the threshold quantity of a regulated substance in a process, as determined under 40 CFR 68.115 and therefore is subject to 40 CFR Part 68 - Chemical Accident Prevention Provisions. Evans is a Program 3 level facility because the processes covered under RMP are also subject to the OSHA process safety management standard, 29 CFR 1910.119. To evaluate the worst case and alternative scenarios, Evans used EPA's program RMP*Comp to calculate the off-site consequences. RMP*Comp is based on the look-up tab les and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. Scenarios for Toxic Substances The worst-case release scenario submitted for toxic substances as a class involves a catastrophic release from Acrylonitrile. The scenario involves the release of 40,557 lb. of Acrylonitrile in a liquid form over 10 minutes. The release is completely contained within a diked area. Evaporation from that pool within the dike occurs over 60 minutes. Calculations take into account the worst case weather conditions (stable, low wind speed) in an urban setting, and are calculated to a toxic endpoint of 0.076 mg/l. One alternative release scenario is submitted for each toxic substance that may be present in Program 3 processes cumulatively. Inventory is dependent upon customer orders and not all regulated substances are present onsite at a given time. The alternative release scenario for Acrylonitril e involves a release from a transfer hose failure while loading or unloading from a tank truck. The scenario involves the release of 20,000 lb. of Acrylonitrile. It is assumed that the release takes place for 10 minutes before it is brought under control. Secondary containment at the loading dock used to confine the size of the toxic liquid pool, from which surface evaporation takes place over 10 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves, sprinkler system(s), and sorbent to confine and control the release. These active mitigation controls are expected to limit the extent of the spill and reduce the amount released by 95%. Calculations are based on the most common weather conditions, in an urban setting and are calculated to a toxic endpoint of 0.076 mg/l. The alternative release scenario for Allyl alcohol involve s a release from a transfer hose failure while loading or unloading from a tank truck. The scenario involves the release of 22,200 lb. of Allyl alcohol. It is assumed that the release takes place for 10 minutes before it is brought under control. Secondary containment at the loading dock used to confine the size of the toxic liquid pool, from which surface evaporation takes place over 10 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves, sprinkler system(s), and sorbent to confine and control the release. These active mitigation controls are expected to limit the extent of the spill and reduce the amount released by 95%. Under the most common weather conditions, the maximum distance to the toxic endpoint of 0.036 mg/l of Allyl alcohol is less than the distance to the nearest public receptor. The alternative release scena rio for Cyclohexylamine involves a release from a transfer hose failure while loading or unloading from a tank truck. The scenario involves the release of 22,200 lb. of Cyclohexylamine. It is assumed that the release takes place for 10 minutes before it is brought under control. Secondary containment at the loading dock used to confine the size of the toxic liquid pool, from which surface evaporation takes place over 10 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves, sprinkler system(s), and sorbent to confine and control the release. These active mitigation controls are expected to limit the extent of the spill and reduce the amount released by 95%. Under the most common weather conditions, the maximum distance to the toxic endpoint of 0.16 mg/l of Cyclohexylamine is less than the distance to the nearest public recept or. The alternative release scenario for Ethylenediamine [1,2-Ethanediamine] involves a release from a transfer hose failure while loading or unloading from a tank truck. The scenario involves the release of 23,300 lb. of Ethylenediamine [1,2-Ethanediamine]. It is assumed that the release takes place for 10 minutes before it is brought under control. Secondary containment at the loading dock used to confine the size of the toxic liquid pool, from which surface evaporation takes place over 10 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves, sprinkler system(s), and sorbent to confine and control the release. These active mitigation controls are expected to limit the extent of the spill and reduce the amount released by 95%. Under the most common weather conditions, the maximum distance to the toxic endpoint of 0.49 mg/l of Ethylenediamine [1,2-Ethanediamine] is less than the distance to the nearest public receptor. The alternative release scenario for Formaldehyde (solution) involves a release from a transfer hose failure while loading or unloading from a tank truck. The scenario involves the release of 10,656 lb. of Formaldehyde (solution). It is assumed that the release takes place for 10 minutes before it is brought under control. Secondary containment at the loading dock used to confine the size of the toxic liquid pool, from which surface evaporation takes place over 10 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves, sprinkler system(s), and sorbent to confine and control the release. These active mitigation controls are expected to limit the extent of the spill and reduce the amount released by 95%. Under the most common weath er conditions, the maximum distance to the toxic endpoint of 0.012 mg/l of Formaldehyde (solution) is less than the distance to the nearest public receptor. The alternative release scenario for Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl] involves a release from a transfer hose failure while loading or unloading from a rail car. The scenario involves the release of 90,400 lb. of Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl]. It is assumed that the release takes place for 20 minutes before it is brought under control. The toxic liquid forms a pool, from which surface evaporation takes place over 20 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves, sprinkler system(s), booms and sorbent to confine and control the release. Under the most common weather conditions, the maximum distance to t he toxic endpoint of 0.007 mg/L of Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl] is less than the distance to the nearest public receptor. The alternative release scenario for Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl] involves a release from a transfer hose failure while loading or unloading from a rail car. The scenario involves the release of 90,400 lb. of Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl]. It is assumed that the release takes place for 20 minutes before it is brought under control. The toxic liquid forms a pool, from which surface evaporation takes place over the 20 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves, sprinkler system(s), booms and sorbent to confine and control the release. Calculations are based on the most common weather conditions, in an urban setting and are calculated to a toxic endpoint of 0.007 mg/l. The alternative release scenario for Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl] involves a release from a transfer hose failure while loading or unloading from a rail car. The scenario involves the release of 90,400 lb. of Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl]. It is assumed that the release takes place for 20 minutes before it is brought under control. The toxic liquid forms a pool, from which surface evaporation takes place over the 20 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves, sprinkler system(s), booms and sorbent to confine and control the release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.007 mg/l of Toluene diisocyanate (unspe cified isomer) [Benzene, 1,3-diisocyanatomethyl] is less than the distance to the nearest public receptor. Scenarios for Flammable Substances The worst case release scenario submitted flammable substances as a class involves a catastrophic release of Pentane from Warehouse H. The scenario involves the release of 58,000 lb. of Pentane. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with the entire released quantity participating in a vapor cloud explosion. Under worst case weather conditions (stable, low wind speed), in an urban setting, the endpoint is calculated to 1-psi overpressure. The alternative release scenario submitted for flammable substances involves a release of Pentane from a drum in Warehouse H. The release is assumed to result in a vapor cloud explosion. The scenario involves a 10-minute release of 290 lb. of Pentane. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Passive mitigation controls such as enclosures and dikes are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include deluge system(s) and fire monitors. Under neutral weather conditions, the maximum distance to the lower flammability limit of 2% by volume is less than the distance to the nearest public receptor. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Evans has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The repackaging and warehouse processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Evans is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our sta tionary source. Process Safety Information Evans Houston maintains a record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The checklist method is used to carry out our process hazard analyses. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated on a regular basis or when there is a change in the process. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Evans maintains written standard operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emer gency shutdown, emergency operations, normal shutdown and startup after maintenance. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Evans has a training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with those processes. New employees receive training and are tested for competency before starting work. Refresher training is provided on a regular basis and more frequently as needed. Mechanical Integrity Evans carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure valves, hoses and piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Evans to manage changes in chemicals being packaged, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as needed at Evans. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Evans will conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits will be carri ed out at least every 3 years and any corrective actions required as a result of the audits will be undertaken promptly. Incident Investigation Evans promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Evans believes that process safety management and accident prevention is a team effort. Company employees are encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses. Contractors On occasion, our company hires contractors to conduct special ized maintenance and construction activities. Prior to selection a performance audit is completed for contractors. Evans has a policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Evans has had an excellent record of preventing accidental releases over the last 5 years so that no accidental release has occurred during this period. 6. Emergency Response Plan Evans has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident return to wok procedure To ensure proper functioning, our emergency response equipment is regular ly inspected and serviced. In addition, the plan is updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Since the implementation of the various elements of our accidental release prevention program, there have been no developments or findings that indicate the immediate need to improve safety at our facility. We have a continuous improvement policy in place that includes safety issues. 8. Certification Statement The undersigned certifies that to the best of their knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Brian Ameen Title: Environmental Manager Date signed: June 17, 1999 |