Air Products Incorporated - Executive Summary |
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Federal RMP Executive Summary Air Products and Chemicals, Incorporated Pasadena, Texas Polyvinyl Alcohol Facility The Air Products and Chemicals, Incorporated facilities in Pasadena, Texas contain two RMP covered processes which include a polyvinyl alcohol (PVOH) manufacturing plant and a gaseous hydrogen manufacturing plant. 1. Accidental release prevention and emergency response policies: The PVOH plant must maintain greater than 15,000 pounds of vinyl acetate monomer to safely and efficiently manufacture polyvinyl alcohol. In the quantities handled by our facility, vinyl acetate monomer is considered to be a toxic liquid by the EPA. In addition, hydrogen, in the amount handled by the facility, exceeds the threshold quantity set by the EPA for a flammable gas. It is our policy to adhere to all applicable federal, state, and local rules and regulations as well as our own environmental, health, and safety standards. Air Products manages the safety of our facility by designing for safe operation, operating the plant safely, maintaining the plant, and by auditing our operations. Our accident prevention program is based on OSHAs Process Safety Management regulation and our emergency response program is based on OSHAs HAZWOPER regulation including an Advanced Interior / Exterior Fire Brigade per NFPA 600. The emergency response plan includes procedures for the request of local fire support through Channel Industries Mutual Aid so that appropriate measures can be taken by local emergency responders if necessary. Air Products is committed to continuous improvement in all aspects of safety and environmental performance. Air Products is a member of the Chemical Manufacturers Association and subscribes to the Responsible Care Program. The Pasadena facility is actively involved with local organizations concerned with the safety of our community and the environment such as the East Harris County Manufacturers Association, the Pasadena Local Emergency Plann ing Committee (LEPC), and the Pasadena Citizens Advisory Council. This document has been prepared in accordance with EPAs Risk Management Plan regulation (40 CFR, Part 68). The substances and processes considered during the preparation of this RMP and the scenarios described were selected based on criteria established in the regulation. 2. The facility and the regulated substances handled: Our facilities are located on Highway 225 in Pasadena, Texas. To produce polyvinyl alcohol, vinyl acetate liquid is polymerized in reactors to form polyvinyl acetate. The polyvinyl acetate is then converted to polyvinyl alcohol as a wet solid material which is processed and dried into a granular or powder-like material. The product is shipped by railcar and bulk trucks to industrial customers for applications such as coating fibers in the textile industry and making water-based adhesives. Vinyl acetate monomer is present on site in the storage tank, piping and processing unit to maintain c ontinuous and efficient production of polyvinyl alcohol. Hydrogen is used by our customers in their manufacturing processes. To produce gaseous hydrogen, natural gas is received by our plant via pipeline and used as our feedstock. The feedstock is mixed with steam and sent to the reformer furnace. In the reformer furnace, the feedstock and steam are heated in the presence of a catalyst, where a chemical reaction takes place that converts the mixture into hydrogen, carbon monoxide, and carbon dioxide. The carbon monoxide and carbon dioxide are then separated from the hydrogen in adsorbers. The pure hydrogen is then delivered to the customer via our pipeline. 3. The worst case release scenario(s) and the alternative release scenario(s): The worst case scenario (WCS) for an RMP listed toxic liquid at the Pasadena facility, as defined by the EPA, involves the release of vinyl acetate monomer (VAM) from the failure of the largest vessel containing vinyl acetate monomer. The VA M storage tank, which has a theoretical capacity of 241,000 pounds, is the vessel that contains the largest quantity of VAM at our facility. The actual working capacity is 169,000 pounds, and is administratively controlled through operating procedures and level alarms. An earthen dike around the tank along with a sump will contain the full contents of the tank and will limit the exposed surface area of a pool of VAM and thus reduce the release rate. The EPA Offsite Consequence Analysis Guide was used to determine that this release would result in offsite impact. The worst case release scenario is highly unlikely due to several factors which include a mechanical integrity program to maintain the vessel integrity, operator presence in the field to watch for leaks or spills, and a system to pump any fluid found in the diked area to another vessel. The WCS for an RMP listed flammable chemical at the Pasadena facility, as defined by the EPA, is a catastrophic failure of one of the pres sure swing adsorption vessel, releasing (3,800 pounds) of gaseous hydrogen which is assumed to form a vapor cloud and ignite resulting in a vapor cloud explosion (VCE). ). The maximum distance to the EPA-defined end point (1 psi overpressure) for this event reaches no receptors off-site. Although we have active controls directed at preventing such releases, no credit for active or passive mitigation measures were taken into account in evaluating this WCS. The alternate release scenario (ARS) for VAM at our facility is the overpressure of a PVOH polymerization reactor due to a power failure and a subsequent release of VAM vapors from the emergency vent recovery vessel. Based on a three minute release, this scenario could result in the release of 7500 pounds of VAM. The EPA Offsite Consequence Analysis Guide was used to determine that this type of incident would result in offsite impact if no active or passive mitigation was used. Even though the EPA allows credit for active mitigat ion methods, no such credit was taken in order to determine a potential offsite impact. The PVOH polymerization reactors are equipped with safety systems including remote computer control and monitoring of process parameters including temperature, pressure and level, diluent addition to control the reaction, reaction stopper injection system, cooling water for heat removal, pressure relief systems, and an emergency vent recovery vessel for containment. In addition, the facility has fire monitors to cool the vessels and provide water spray to mitigate a vapor release. 4. The general accidental release prevention program and specific prevention steps: The PVOH plant is covered as a Program Level 3 and the Hydrogen plant is covered as a Program Level 1 as defined by the RMP regulation. Our accident prevention program is based on OSHAs Process Safety Management regulation. Air Products manages the safety of our facility by designing for safe operation, operating the plant safely, m aintaining the plant safely, and by auditing our operations. Our facility is designed for safe operation through the use of emergency shutdown systems and alarms, water deluge systems, fail-safe valves, and dikes for the unlikely case of a liquid leak. Systems and equipment are designed to applicable engineering standards and codes. Safety reviews are conducted for all new installations and modifications to existing processes. Our plant is operated safely by trained and certified operators who follow standard operating procedures with defined safe operating limits. Process safety meetings are held regularly for all operating and maintenance personnel including contractors. Investigations are conducted for all incidents. We maintain operational safety through preventive maintenance and equipment inspection programs. We hold contractors to the same high safety training standards as our employees. We implement task observation and accident prevention techniques. We routinely a udit our operations for compliance with federal, state, and local regulation. We also have a program to audit the plants performance against corporate environmental and safety standards. 5. Five year accident history: There have been no releases of vinyl acetate monomer nor have there been any releases of flammable gases from the Air Products Plant in Pasadena in the past five years that have had an adverse impact on the community. There have been no incidents at the facility that meet the EPA Risk Management Program reporting requirements. 6. The emergency response program: The facilitys emergency response program is based on the OSHA HAZWOPER standard and has established an Advanced Interior / Exterior Fire Brigade per NFPA 600. At this facility we have 34 trained emergency responders on the Emergency Response Team. This includes a fire brigade, rescue team, a haz-mat team, and 9 personnel certified by the Texas Department Of Health as EMS personnel. In an emergency, an emergency response team member establishes a "Unified Command" with an operations person from the affected area and assumes on-scene command of the incident. On-site emergency resources include a rescue truck, and a 500 gallon foam trailer. In addition to these resources, the facility is a member of Channel Industries Mutual Aid (CIMA) and coordinates programs with the Pasadena LEPC, the Pasadena Fire Dept. and CIMA members. A plant wide joint drill was held in 1995 with the CIMA organization The plant Emergency Response Team members participate with the CIMA organization drills twice a year at various plants in the area. The Pasadena Fire Dept. personnel visit the plant twice per year for joint training. 7. Planned changes to improve safety: Currently, we have no plans to install new mitigation, control equipment nor to change technology. The Polyvinyl Alcohol facility was started up in 1991 and the Hydrogen facility was started up in 1996. Process safety is evaluate d regularly through conducting operational plant hazard reviews and studying incidents which have occurred within the chemical industry. We recently completed a project to eliminate onsite storage of ammonia to reduce the quantity maintained at our facility to less than 10,000 pounds. This risk reduction project was a result of our on-going process safety evaluations. |