Alamo Plant - Executive Summary |
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Drilling Specialties Company's Alamo Plant is required to prepare a Risk Management Plant because the facility has Sulfur Trioxide in excess of the threshold quantity as stipulated in 40 Code of Federal Regulations (CFR) 68. The Alamo Plant uses Sulfur Trioxide (SO3) to manufacture Soltex, a drilling mud additive. The Alamo Plant is subject to "Program 3" reporting requirements as defined in 40 CFR 68 because the facility is also subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard as defined in 29 CFR 1910. The Risk Management Plan was prepared using the Environmental Protection Agency's (EPA) Off-Site Consequence Analysis (OCA) Guidance Document. The Worst-Case Release Scenario and the Alternate Release Scenario for SO3 both had off-site impacts as defined in the EPA Guidance Document. Process Controls such as Emergency Vents, Relief Valves, Check Valves, and the other items available at the Alamo Plant were not considered in determining the off-site impact of either scenario. Mitigation Systems such as Dikes, Enclosures, and Deluge Systems available at the Alamo Plant were also not considered in controlling the impact of the two scenarios. Only two (2) incidents involving SO3 have occurred over the past 5-years. Neither incident resulted in off-site impact and both spills of SO3 involved quantities less than 1 gallon. The Alamo Plant has an Emergency Response Plan for handling releases of hazardous substances. The plan provides the Alamo Plant with a system of readiness which includes procedures for orderly transition from normal to emergency operations, a design for delegation of emergency authority and responsibility, a method for interfacing with other emergency organizations, and a means of controlling the emergency. The Alamo Plant emergency organization is structured in accordance with the Incident Command System to address all aspects of internal and external emergencies. The Emergency Res ponse Plan also incorporates pre-emergency planning through the use of monthly What-If Scenarios and quarterly emergency response drills that include event simulation and actual hands on training. Employees are also trained to notify outside agencies, such as the Montgomery County Local Emergency Planning Commission, the Texas Natural Resource Conservation Commission, the National Response Center, and neighboring facilities. The Alamo Plant has a proactive Structured Safety Process that utilizes various techniques for the identification, assessment, and control of conditions that may adversely impact employees, the public, company assets, or the environment. All employees at the Alamo Plant actively participate in the identification of hazards and risks through the use of Accident Prevention Techniques (APTs), Task Safety Observations (TSOs), Job Safety Analysis (JSAs), What-If Scenarios, quarterly Emergency Response Drills, Safe Behavior Observations, Monthly Inspections, and Proc ess Hazard Analysis. All employees at the Alamo Plant are encouraged to identify and recommend corrections to any unsafe work practices, procedures, and equipment that they identify. All recommendations are addressed by Alamo Plant management during monthly employee meetings and changes to improve Plant safety are continuously being adopted and implemented. |