Stolthaven Houston Inc. - Executive Summary |
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1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Stolthaven Houston Inc., we are committed to operating and maintaining all of our processes involved in chemical storage and handling 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, including: ? A description of our facility and use of substances regulated by EPA's RMP regulation ? A summary of results from our assessment of the potential offsite consequences from accidental chemical releases ? An overview of our accidental release prevention programs ? A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule ? An overview of our emergency response program ? An over view of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment ? The certifications that EPA's RMP rule requires us to provide ? The detailed information (called data elements) about our risk management program 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility stores (Acrylonitrile, Epichlorohydrin, Isopropanolamine, Vinyl Acetate Monomer and Toluene-diisocyanate) using large above ground storage tanks. The facility does not perform any RMP chemical processing operations. These chemicals have been identified by the EPA as having the potential to cause significant off-site consequences in the event of a substantial accidental release: Toxics: Acrylonitrile (CAS # 107-13-1), Epichlorohydrin (CAS # 106-89-8), Vinyl Acetate Monomer (CAS # 108-05-4), and Toluene-diisocyanate (CAS # 584-84-9) Flammables: Isopropylamine (CAS # 75-31-0) Our accidental release p revention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public and the environment by our storage of these chemicals. 3.0 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. 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: Worst-Case Release Scenario - Regulated Toxic Chemicals The facility worst-case scenario is for Acrylonitrile. The quantity is 14,116,284 pounds and is the entire amount that could be lost due to a catastrophic failure of the largest storage tank. The worst-case weather conditions are assumed, and the maximum estimated exposure distance is then computed by the EPA method. Then a list of the potentially impacte d receptors is generated and the local emergency planning committee (LEPC) is provided the information. Additionally the LEPC is provided information for administrative controls and mitigation measures to limit the exposure distances for this scenario. Alternative Release Scenario(s) - Regulated Toxic Chemicals The facility alternate case scenario(s) are for Acrylonitrile (toxic). The toxic quantity is 1,000 pounds and is the entire amount that could be lost due to a catastrophic failure of a loading hose. The worst-case weather conditions are assumed, and the maximum estimated exposure distance is then computed by the EPA method. Then a list of the potentially impacted receptors is generated and the local emergency planning committee (LEPC) is provided the information. Additionally the LEPC is provided information for administrative controls and mitigation measures to limit the exposure distances for this scenario(s). Worst-Case Release Scenario(s) - Regulated Flammable Chem icals The facility worst-case scenario(s) is for Isopropylamine (flammable). The flammable quantity is 3,780,000 pounds and is the entire amount that could be lost due to a catastrophic failure of a storage tank. The worst-case weather conditions are assumed, and the maximum estimated exposure distance is then computed by the EPA method. Then a list of the potentially impacted receptors is generated and the local emergency planning committee (LEPC) is provided the information. Additionally the LEPC is provided information for administrative controls and mitigation measures to limit the exposure distances for this scenario(s). Alternate Case Release Scenario(s) - Regulated Flammable Chemicals The facility alternate case scenario(s) is for Isopropylamine (flammable). The flammable quantity is also 1,000 pounds and is also the entire amount that could be lost due to a catastrophic failure of a loading hose. The worst-case weather conditions are assumed, and the maximum estimated exposure distance is then computed by the EPA method. Then a list of the potentially impacted receptors is generated and the local emergency planning committee (LEPC) is provided the information. Additionally the LEPC is provided information for administrative controls and mitigation measures to limit the exposure distances for this scenario(s). We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all contingency cases and represent the worst possible case for toxic and flammable chemicals. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems addresses each of the key features of successful prevention programs including: ? Process Safety Information ? Process Hazard Analysis ? Operating Procedures ? Training ? Mechanical Integrity ? Spill C ontainment ? Management of Change ? Pre-Startup Review ? Environmental Vapor Controls ? Compliance Audits ? Incident Investigation ? Employee Participation ? Hot Work Permit ? Contractors These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5.0 FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five (5) years: There have been no accidental chemical releases of covered substances during the past five (5) years. If there had been an incident, then we would have conducted a formal inci dent investigation to identify and correct the root cause(s) of the event(s). 6.0 EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local 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 and the local emergency planning committee (LEPC). 7.0 PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we have recently completed and/or implemented at the facility to help prevent and/or better respond to accidental chemical releases: ? PHA and adaptation of PHA recommendations ? Environmental Vapor Controls ? Employee Suggestion Program |