Rohm and Haas Company Bayport Plant - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies The Bayport Plant Environment Policy states: "We will operate and maintain our plant with no spills, releases, or odors that impact our community by practicing operating discipline and the use of preventive and predictive maintenance. We will comply with all environmental regulations and policies. Operating our plant without spills or releases is equivalent to operating with zero injuries and of higher priority than production. It is our responsibility to operate and maintain our plant without spills to prevent any impact on ourselves, our coworkers and the community around us. Our business and customers expect us to operate in this manner." In addition we have environmental "cardinal rules" that cover proper operation of pollution control equipment, data integrity, reporting of all spills and releases, and change management for all process revisions. Bayport Facility and Chemicals Handled The Bayport plant is a chemi cal manufacturing facility. Primary products are specialty monomers, herbicides, and biocides. End use applications range all the way from contact lenses and cosmetics to oil field drilling fluids and soy bean crops. We handle chlorine in 180,000 lb. rail cars, ethylene oxide and propylene oxide in 165,000 lb. rail cars, nitric acid in 75,000 lb. capacity tank and monomethylamine in a 41,325 lb. capacity tank. Worst Case and Alternative Case Release Scenarios The worst case toxic release scenario is the EPA defined complete release of 180,000 lb. chlorine from a rail car in 10 minutes with complete failure of our emergency systems and our highly trained personnel standing by and watching without responding. For this case, per EPA look up tables, the chlorine would carry 14 miles and impact over 600,000 people. The alternative release case for chlorine is the release of 61 lb. of chlorine from a hose failure. In this case the emergency shut down systems function (excess flow val ves, chlorine detectors, remote shut off valves, trained personnel, etc.). While the projected release leaves our property, no residences are impacted. For ethylene oxide and propylene oxide the alternative release scenarios are failure of our air pollution control device. With detection (process control instrumentation) and response (shut down of unit operation) neither of the 3750 lb. releases travel off site, and thus no residences are impacted. For nitric acid, the alternative release scenario is 1499 lb. of nitric acid from a failed 2" transfer hose. With detection (operating procedures require personnel monitor transfer) and response (shut down of transfer by closing valves and stopping pump) the release does not travel offsite and thus no residences are impacted. The worst case flammable release scenario is the EPA defined complete release of 41,325 lb. monomethylamine from a tank in 10 minutes with complete failure of our emergency systems and our highly trained personn el standing by and watching without responding. For this case, per EPA look up tables, the monomethylamine would carry 0.26 miles. No residences would be impacted. The alternative release case for monomethylamine is the release of 13,300 lb. of monomethylamine from a hose failure. In this case the emergency shut down systems function (excess flow valves, detectors, remote shut off valves, trained personnel, etc.). The projected release travels 0.02 miles, does not leave our property and no residences are impacted. Accidental Release Prevention Programs Included in the Bayport plants accidental release prevention plans are fully automated processes with level and flow measurement and control, minimum inventories of chemicals, excess flow control valves, automatic emergency shut-off valves, redundant safety interlocks, preventative maintenance programs, chemical detectors, remotely operated valves to isolate and minimize a release, and annual training of employees. Included in the Bayport plants emergency response program are fully trained exterior and interior fire brigade, fully trained Technician level HAZMAT team for both onsite and offsite response, fully trained Emergency Medical Technician Basic team, fully trained High Angle and Confined Space Rescue team, fully trained incident commanders, onsite fire truck with foam capability, onsite mobile equipment for HAZMAT response, member CIMA (Channel Industry Mutual Aid), water spray deluge systems, sewer spill isolation valves and catch basin, notification systems including plant wide alarms and portable radios, neighbor and community notification procedures including use of CAER line, and chemical detectors strategically located. Five Year Accident History We have had 2 releases of chlorine that impacted our industrial neighbors. No residences were impacted. These releases were 5 and 7 lb. and required shelter in place for a brief period of time as a precaution. Emergency Response Program Our em ergency response efforts are coordinated with CIMA (Channel Industry Mutual Aid), La Porte LEPC, and area industrial neighbors (we have a reciprocal plan to share fire water with the Good Year plant across the road from us). Our emergency plans are reviewed at least annually. Our public notification system consists of calling the LEPC, State of Texas, Harris County, CAER line, and industrial neighbors. Planned Changes to Safety Program New plant emergency notification system being installed with planned start up summer of 1999. HAZOP's for our various processes are frequently updated. |