Celanese Pasadena Plant - Executive Summary |
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Federal RMP Executive Summary Celanese, Ltd. Pasadena, Texas Polyvinyl Alcohol Plant The Celanese Pasadena Plant located along Highway 225 in Pasadena, Texas has one RMP covered process: a polyvinyl alcohol (PVOH) manufacturing plant. 1. Accidental release prevention and emergency response policies: The PVOH plant must maintain greater than 15,000 pounds of vinyl acetate monomer in inventory 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. 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. Celanese 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 OSHA?s Process Safety Management regulation and our emergency re sponse program is based on OSHA?s HAZWOPER regulation. 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. Celanese is committed to continuous improvement in all aspects of safety and environmental performance. Celanese is a member of the American Chemistry Council (ACC) 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 Manufacturer?s Association, the Pasadena Local Emergency Planning Committee (LEPC), and the Pasadena Citizen?s Advisory Council. This document has been prepared in accordance with EPA?s 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 b ased on criteria established in the regulation. 2. The facility and the regulated substances handled: The facility is 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 storage tanks, piping and the processing unit to maintain continuous and efficient production of polyvinyl alcohol. 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 VAM 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 off-site 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. There are no flammable chemicals at the Pasadena fa cility, as defined by the EPA. The alternate release scenario (ARS) for VAM at our facility is the overpressure of a PVOH polymerization reactor 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 mitigation 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 containme nt. 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 Level 3 Program as defined by the RMP regulation. Our accident prevention program is based on OSHA?s Process Safety Management regulation. The facility is designed for safe operation through the use of emergency shutdown systems and alarms, water deluge systems, fail-safe valves, and storage tank dikes. Systems and equipment are designed to applicable engineering standards and codes. Safety reviews are conducted for all new installations and modifications to existing processes. The plant is operated safely by trained operators who follow documented 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. Safe operations are maintained through preventive maintenance and equipment inspection programs. Contractors are held to the same high safety training standards as our employees. We routinely audit our operations for compliance with federal, state, and local regulation. We also have a program to audit the plant?s performance against corporate environmental and safety standards. 5. Five year accident history: There have been no releases of vinyl acetate monomer from the Plant 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. Previously the facility was operated by Air Products and Chemicals, Inc. 6. The emergency response program: The facility?s emergency response program is operated jointly with its neighbor, Air Products and Chemicals, Inc., and is based on the OSHA HAZWOPER and NFPA 600 standards. There are ~ 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 assumes on-scene command of the incident and establishes a "Unified Command" with an operations person from the affected area. 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. 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 t echnology. The Polyvinyl Alcohol facility was started up in 1991. Process safety is evaluated regularly through conducting operational plant hazard reviews and studying incidents which have occurred within the chemical industry. |