Rhodia, Baytown Facility - Executive Summary
General Executive Summary for Risk Management Plan (RMP) at the Rhodia Baytown facility. |
Date of report 2/18/00 Rev.1
1. Accidental Release Prevention and Emergency Response Policies
We at the Rhodia Baytown Facility are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive Process Hazard Management 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.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass manufacturing of sulfuric acid and the regeneration of spent sulfuric acid.. We have 2 regulated substance that could be present at our facility Ammonia (anhydrous) and Ethyl Mercaptan. Ammonia is used to reduce emissions from the sulfuric acid plant.
Ethyl Mercaptan is part of a mixture that is used as a feed stock to recover sulfur to make sulfuric acid.
The maximum inventory of Ammonia (anhydrous) at our facility is 175,000 lb. The maximum inventory of Ethyl Mercaptan is 160,000 lb.
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
To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations and the EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from the ammonia storage tank at the facility. In this scenario 175000 lb. of Ammonia (anhydrous) is released. The toxic liquid released is assumed to form
a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 80 % of the maximum capacity of the source by a system of administrative controls . This release does have an impact outside the facility and in the community.
The alternative release scenario for Ammonia (anhydrous) involves a release from an unloading hose. The scenario involves the release of 300 lb. of toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by excess flow valve(s). These active mitigation systems have the effect of minimizing the duration of the release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.1 miles. This would not have an impact on the community.
The worst case release
scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from Baytown Acid Plant. In this scenario 160,000 lb. of Ethyl mercaptan is released. 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. The impact corresponding to an endpoint of 1 psi overpressure would not effect the community.
The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Baytown Acid Plant. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 160000 lb. of Ethyl mercaptan [Ethanethiol]. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.25 miles and would not effect the community.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has
taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Rhodia Baytown Facility maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analysis (PHA)
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Checklist, HAZOP and Fault Tree. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner. The most rec
ent PHA/update was performed on 05/01/1997.
For the purposes of safely conducting activities within our covered processes, Rhodia Baytown Facility maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
Rhodia Baytown Facility has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every year and more frequently as needed.
Rhodia Baytown Facility carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these chec
ks includes among others; pressure vessels, storage tanks, 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 Rhodia Baytown Facility to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 12/01/1998. 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-start up safety reviews related to new processes and to modifications in e
stablished processes are conducted as a regular practice at Rhodia Baytown Facility. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Rhodia Baytown Facility conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 10/14/1999. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
Rhodia Baytown Facility 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. Al
l reports are retained for a minimum of 5 years.
Rhodia Baytown Facility truly believes that process safety management and accident prevention is a team effort. Company employees are strongly 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 in particular.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Rhodia Baytown Facility has a strict 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
Rhodia Baytown Facility has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period.
6. Emergency Response Plan
Rhodia Baytown Facility carries 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 decontamination of affected areas.
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
7. Planned Changes to Improve Safety
In order to encou
rage continuous improvement in all elements of Process Safety the facility regularly reports progress of improvement efforts that are described in the Process Safety Management Plan. Many of these improvements are results of audits and other reviews such as Management of Change, Process Hazard Analysis, Accident Investigations and others.