NEEC Sugar Land Plant - Executive Summary

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RMP Executive Summary 
1.0 Introduction  
At the Nalco/Exxon Energy Chemicals, LP Sugar Land plant, we are committed to  
operating and maintaining all of our processes (especially those using hazardous  
substances) in a safe and responsible manner. We use a combination of accidental release  
prevention programs and emergency response planning programs to help ensure the  
safety of our employees and the public as well as protection of the environment. This  
document provides a brief overview of the comprehensive risk management activities  
that we have designed and implemented for the handling and use of substances regulated  
by the EPA RMP, including the following: 
- A description of our facility and use of substances regulated by the EPA RMP rule 
- Our accidental release prevention and emergency response policies 
- A summary of the results from our assessment of the potential offsite consequences  
from accidental releases of substances regulated by the RMP rule 
- Our general accident 
al release prevention program and specific release prevention  
steps for the RMP regulated substances 
- A five-year history of accidents associated with substances regulated by the RMP rule  
- Our emergency response program 
- Planned changes to improve safety  
2.0 Stationary Source and Regulated Substances 
The Sugar Land plant produces numerous chemical products using a variety of raw  
materials and processing operations. From these different raw materials and operations,  
the plant annually produces more than 100 million pounds of specialty chemicals for our  
customers. Approximately 170 employees work year round to meet the needs of oilfield  
producers, refiners, and chemical plants.  
In our processes, we use the following chemicals that the EPA has regulated as either  
toxic or flammable substances under the RMP rule, in quantities in excess of the  
applicable threshold amount:  
Our accidenta 
l release prevention programs and our contingency planning efforts help us  
to effectively manage the potential hazards that are posed to our employees, the public,  
and the environment by our use of these chemicals. 
3.0 Offsite Consequence Analysis Scenarios 
For the RMP regulated chemicals that we handle, the EPA rule requires that we provide  
information about worst-case release scenario(s) and alternative release scenario(s) for  
our facility. It is worth noting that the RMP definition of a potential worst-case scenario  
results in an event that is far beyond any reasonable expectation. The alternate release  
scenarios represent more credible, although still unlikely, events. 
The following are brief summaries of these scenarios, including information about the  
key administrative controls and mitigation measures to limit the exposure distances for  
each scenario. 
3.1 Worst-case Release Scenario for Regulated Toxic Chemicals 
Our worst case toxic release scenario is the rupture o 
f a tank truck containing  
epichlorohydrin while unloading into our storage tank. The tank truck rupture would  
release 45,000 pounds of epichlorohydrin into a diked containment area with a surface  
area of 1430 square feet. This worst-case release would only reach offsite endpoints and  
public receptors within a distance of 0.4 miles from the containment area.  
3.2 Alternative Release Scenario(s) for Regulated Toxic Chemicals 
We have evaluated one alternative release scenario for each of our regulated toxic  
chemicals. These scenarios are summarized below. 
The alternative release scenario for epichlorohydrin is a break in the transfer piping,  
resulting in the release of 1500 pounds over a ten-minute period. This release would only  
reach offsite endpoints and public receptors within a distance of 0.1 miles from the  
release area. There are no residences within this distance. 
The alternative release scenario for cyclohexylamine is a break in the transfer piping,  
resulting in the  
release of 1500 pounds over a ten-minute period. This release would only  
reach offsite endpoints and public receptors within a distance of 0.1 miles from the  
release area. There are no residences within this distance. 
The alternative release scenario for ethylenediamine is a break in the transfer piping,  
resulting in the release of 1500 pounds over a ten-minute period. This release would only  
reach offsite endpoints and public receptors within a distance of 0.1 miles from the  
release area. There are no residences within this distance. 
3.3 Worst-case Release Scenario for Regulated Flammable Chemicals 
Our worst-case flammable release scenario is the rupture of a tank storing an aqueous  
solution of trimethylamine, which would result in the release of 55,000 pounds of  
trimethylamine. A subsequent vapor cloud explosion of the trimethylamine would result  
in a 1 psi overpressure at a distance of 0.3 miles from the tank. 
3.4 Alternative Release Scenario for Regulated Flammable Chem 
The alternative release scenario for trimethylamine is a break in the transfer piping,  
resulting in the release of 1500 pounds in one minute. A subsequent vapor cloud fire  
would result in a distance to the lower flammability limit of <0.1 miles from the release  
area. There are no residences within this distance. 
4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
We maintain a number of programs to help prevent accidental releases of regulated  
chemicals and to ensure safe operation. The accident prevention programs in place  
- Process safety information: We have a program in place to ensure that information  
is available regarding the hazards of the regulated chemicals, the processes which  
handle these chemicals, and the equipment in the process. This information is used to  
identify and understand hazards posed by these chemicals and processes. 
- Process hazard analysis: Under our procedure for process hazard analysis, we  
perform detailed hazard analyses to identify hazards, assess the likelihood of those  
hazards (including accidental releases), and to evaluate the consequences of these  
hazards. Analyses are performed on both new and existing processes. Hazard analyses for  
regulated chemical storage include a review of material unloading, storage, and transfer  
- Operating procedures: We have developed written procedures for the operation of  
all our processes. These procedures provide clear instructions for safely conducting  
activities involved with each covered process. These procedures are reviewed and  
certified at least annually.  We also have written procedures for safe work practices  
to provide for the control of hazards during operations such as lockout/tagout; confined 
space entry; opening of process piping; and control over the entrance into the plant by  
support personnel. 
- Training: Every employee involved in operating a covered process is trained in the  
written operatin 
g procedures. The training includes specific safety and health hazards,  
emergency operating procedures, and safe work practices. Refresher training is  
provided at least every three years. 
- Mechanical integrity: We have an extensive mechanical integrity program with  
written procedures to help ensure that our process equipment is inspected and  
maintained. Employees with mechanical integrity responsibilities are trained to  
ensure that they can perform their job tasks safely.  
- Management of change: We have a written management of change program to  
ensure that changes to a covered process are adequately reviewed before they are  
- Pre-startup safety review: Similar to management of change, we have a written  
procedure for the review of new or significantly modified equipment, before that  
equipment is started up. The review is conducted to confirm that the equipment is  
properly designed and installed and that the associated procedures are in place and are  
- Incident investigation: When an incident or near miss occurs, we have written  
procedures for reporting of the incidents and investigating them as appropriate. The  
purpose of these investigations is to determine the cause of the incident or near miss  
and to identity corrective actions which can help prevent a recurrence.  
- Hot work permit: We have a written procedure and permit for hot work operations  
which are conducted on or near a covered process. The procedure and permit are  
intended to ensure that the hot work is adequately reviewed before it starts and is  
monitored during the operation. 
- Contractors: We have written procedures and policies regarding our use of  
contractors in and around covered processes. These procedures are used to confirm  
that contractor employees are adequately trained, have safe work practices, and have  
been informed of the potential hazards.  
- Employee participation: We encourage all our employees to actively participate in  
the developm 
ent and use of our accidental release prevention programs.  
- Compliance audits: We have a program in place to evaluate compliance with the  
RMP rule every three years to verify that the procedures and practices are adequate  
and are being followed. 
As part of our prevention efforts, we have implemented the following chemical-specific  
prevention steps: 
- Control of emissions from production operations handling RMP chemicals 
- Vapor return for unloading of RMP chemicals to storage tanks 
These individual elements of our prevention program work together to help prevent  
accidental chemical releases.  
In addition to accidental release prevention, we have also implemented the following  
release mitigation steps: 
- Dikes around chemical storage tanks 
- Foam/water sprinkler systems throughout production buildings 
- Foam systems in flammable product and raw materials warehouses 
- Emergency communication and alarm system 
- Firewater monitors and fire hydrants 
- Fire extinguishers 
- Dedic 
ated firewater system with diesel engine backup 
- Over a million gallons of firewater stored onsite 
- Monitoring of onsite regulated chemical inventories 
- Onsite emergency response team 
- Reduction in the surface area of diked areas around regulated chemicals 
- Continuous emissions monitoring from the thermal oxidizers 
- A tank truck unloading containment area for epichlorohydrin and cyclohexylamine 
5.0 Five-Year Accident History 
We maintain records for all significant accidental chemical releases that occur at our facility.  
During the past five years, our facility has not experienced any accidental releases of  
EPA RMP covered materials that caused significant onsite impacts (i.e., death, injury, or  
significant property damage) or offsite impacts (i.e., death, injury, evacuation, sheltering- 
in-place, property damage, or environmental damage). 
6.0 Emergency Response Program 
We maintain an integrated contingency plan, which consolidates all of the various  
federal, state, and lo 
cal regulatory requirements for emergency response planning. Our  
program provides the essential planning and training for effectively protecting workers,  
the public, and the environment during emergency situations. Furthermore, we coordinate  
our plan with the community emergency response plan. We cooperate closely with the  
local fire department and participate in the county LEPC organization. 
We have an onsite emergency response team. Team members are trained and properly  
equipped to respond to a variety of emergency situations, including fires and chemical  
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