Solutia - Chocolate Bayou - Executive Summary |
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Solutia Inc. - Chocolate Bayou - Alvin, TX 12/15/2000 Rev_1 Solutia has officially adopted the following six commitments, expressing our intention to operate responsibly. ? We will ensure that our operations and distribution systems are safe for employees, visitors, site contractors, communities and the environment. ? We will make products that are safe when used responsibly. ? We will keep our operations open to our communities and foster open communications with all of our stakeholders. ? We will continuously improve our raw material and energy utilization efficiencies, to reduce our impact on the environment and improve the sustainability of our businesses. ? We will encourage active participation in and positive contributions to safety, health and environmental stewardship by our employees. ? We will search worldwide for new technologies that bring environmental, safety and health value to all of our stakeholders. By a cting on these commitments, we expect to match the best practices of our peer companies and to adhere to the Responsible Care guidelines developed by the Chemical Manufacturers Association. Solutia Products at Chocolate Bayou: Acrylonitrile is an important ingredient used to make nylon carpet fibers and acrylic fabrics. Nitrilotriacetate acid is used as a "detergent builder" to improve a detergent's ability to clean. Formalin is a chemical intermediate used within the plant to produce other products such as Solutia's Nitrilotriacetate acid and Monsanto's Disodium imminodiacetate. Guest Companies' Products Produced At Chocolate Bayou: Linear alkylbenzene is an ingredient used to make detergents. This material is the "surfactant" that enhances a detergent's ability to remove dirt and grease. This business is owned and marketed by Huntsman and operated by Solutia Inc. MHBA is an abbreviation for 2-hydroxy-4 - (methylthio) butanonic acid, which is an amino acid nutrient source use d in animal feeds. The MHBA facility is owned by Novus International, Inc and operated by Solutia Inc. Disodium imminodiacetate is used to produce Roundup, the world's largest selling herbicide. This product is owned and marketed by Monsanto Company and operated by Solutia Inc. 1.0 Accidental Release Prevention and Emergency Response Policies At Solutia Inc - Chocolate Bayou, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) 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: o A description of our facility and use of substances regulated by EPA's RMP regulation o A summary of results from our assessment of the potential offsite consequences from accidental chemical releases o An overview of our accidental release prevention programs o A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule o An overview of our emergency response program o An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment o The certifications that EPA's RMP rule requires us to provide o The detailed information (called data elements) about our risk management program 2.0 Stationary Source and Regulated Substances Our facility produces a variety of chemicals in our processing operations. Solutia operates the entire facility for Solutia, Novus, Huntsman, and Monsanto. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Note: The totals reflected below represent chemical in process, storage, or transportation containers. Toxics Chemical Quantity (LB) Container Use Acrylonitrile Process 657,000 Process Vessels Finished Product Storage 41,993,000 4 - Tanks Finished Product Transportation 7,200,000 1 - Barge Finished Product Ammonia (anhydrous) Process 93,000 Process Vessels Raw Material Storage 364, 000 2 - Storage Vessels Raw Material Hydrocyanic Acid Process 145,648 Process Vessels By Product/Raw Material Storage 225,000 Tank Raw Material Formaldehyde (solution) Process 698,777 Process Vessels Finished Product Transportation 1,632,900 9 - Railcars Finished Product Hydrogen Fluoride (concentration >= 50%) Process 100,000 Process Vessels Raw Material Sulfur Dioxide Storage 14,000 7 - Cylinders Raw Material Flammables Chemical Quantity (LB) Container Use Propylene Process 78,280 Process Vessels Raw Material Storage 818,846 3 - Storage Tanks Raw Material Our accidental release prevention 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 use of these chemicals. 3.0 Key Offsite Consequence Analysis Scenarios Solutia used RMP*Comp (1.06) to perform the offsite consequences analyses required under the EPA's Risk Management Planning (RMP) rule, which implements section 112 r of the 1990 Clean Air Act. 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(s) - Regulated Toxic Chemicals Acrylonitrile Worst-Case Scenario A storage tank of Acrylonitrile [2-Propenenitrile] has an instantaneous liquid spill to the ground and volatilization occurs with the duration being 10-minute release. This worst-case scenario would have off-site impacts. Alternative Release Scenario(s) - Regulated Toxic Chemicals Acrylonitrile Alternative Release Scenario: Alternative Release scenario for Acrylonitrile [2-Propenenitrile] involves a failure of a relief vent, on a vessel, that breaks off due to corrosion releasing Acrylonitrile. This alternative release scenario would have off-site impacts. Ammonia (anhydrous) Alternative Release Scenari o: Alternative Release scenario for Ammonia (anhydrous) involves an incident in which a tractor with a backhoe strikes the ammonia pipeline inflicting a two inch hole in the pipe and releasing Ammonia. This alternative release scenario would have off-site impacts. Hydrocyanic Acid Alternative Release Scenario: Alternative Release scenario for Hydrocyanic Acid is the failure of piping, creating a one-inch hole. This alternative release scenario would have off-site impacts. Formaldehyde (solution) Alternative Release Scenario: Note: RMP*Comp will only allow the use of 37% Formaldehyde and our facility has 50% Formaldehyde. Solutia used the RMP*Comp for the calculation. Alternative Release scenario for Formaldehyde (50% solution) involves a nozzle to breaking and creating a four inch hole releasing the substance. This alternative release scenario would have off-site impacts. Hydrogen Fluoride (concentration >= 50%) Alternative Release Scenario: Alternative Release scenario for Hydrogen fluoride (concentration >= 50%) involves the failure of piping creating a one inch hole and releasing Hydrogen Fluoride. This alternative release scenario would have off-site impacts. Sulfur Dioxide Alternative Release Scenario: Alternative Release scenario for Sulfur Dioxide involves the failure of the vessel creating a 0.5 inch hole and releasing Sulfur Dioxide. This alternative release scenario would have off-site impacts. Worst-case Release Scenario(s) - Regulated Flammable Chemicals Propylene [1-Propene] worst-case scenario A storage vessel of Propylene has an instantaneous spill to the ground and volatilization occurs with the duration being 10-minute release. This release scenario would have off-site impacts. Propylene Alternative Release Scenario(s) - Regulated Flammable Chemicals Alternative Release scenario for Propylene [1-Propene] is the failure of valve creating a one inch hole. This alternative release scenario would have off -site impacts. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 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 address each of the key features of successful prevention programs including: o Process safety information o Process hazard analysis o Operating procedures o Training o Mechanical integrity Program o Management of change Process o Pre-startup review o Compliance audits o Incident investigation o Employee participation o Hot work permit o Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Acrylonitrile * Process operators conduct area patrols to inspect equipment. * Ground level and aerial water hydrants pr ovide spill mitigation. Also, foam spray connections provide spill mitigation. * Piping and vessels are identified and inspected on scheduled basis. The schedule is designed to identify potential failures. * Several Acrylonitrile detection sensors are located throughout the tank areas that sound alarms in control room if an Acrylonitrile leak occurs. * Interlocks system Ammonia (anhydrous) * Process operators conduct area patrols to inspect equipment. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potential failures. * Ground level and aerial water hydrants provide spill mitigation. * Remote isolation of major vessels and pumping system. * Several ammonia detection sensors or located throughout the process area that sound alarms in control room if a ammonia leak occurs. * Interlock system Hydrocyanic Acid * Process operators conduct area patrols to inspect equipment. * Piping is identified and inspec ted on scheduled basis. The schedule is designed to identify potential failures. * Ground level and aerial water hydrants provide spill mitigation. * Remote isolation of major vessels and pumping system. * Several hydrocyanic acid detection sensors located throughout the process and piping area that sound alarms in control rooms if an hydrocyanic acid leak occurs. * Interlock system. Sulfur Dioxide * Process operators conduct area patrols to inspect equipment. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potential failures * Only 2000 lbs. are connected with process at one time. * Ground level and aerial water hydrants provide spill mitigation. * Interlock system * Sulfur Dioxide detection sensors Formaldehyde (solution) * Process operators conduct area patrols to inspect equipment. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potential failures. * Remote isolatio n of major vessels and pumping system. * Ground level and aerial water hydrants provide spill mitigation. Hydrogen Fluoride (concentration >=50%) * Process operators conduct area patrols to inspect equipment. * Water spray system to mitigate releases over small bore piping systems. * Piping is identified and inspected on scheduled basis. The schedule is designed to identify potential failures. * Ground level and aerial water hydrants provide spill mitigation. * Remote isolation of major vessels and pumping system. * Several hydrogen fluoride detection sensors or located throughout the process area that sound alarms in control room if an hydrogen fluoride leak occurs. Propylene * Detectors (hydrocarbon) * Reducing inventory * Piping identified * Remote isolation * Interlocks * Road Barricades 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 manageme nt 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. In the past five years we have had two chemical releases involving materials covered under EPA's RMP rule that resulted in a OSHA recordable injury to an employee. Due to the OSHA recordable injuries we are including these incidents in our RMP executive summary. These two incidents would have no off-site impact. In 1999, a release of Crotonaldehyde that lasted for one minute resulted in a OSHA recordable injury but no off-site impact. As of July 30, 2000, Crotonaldehyde is no longer a covered chemical at this site. In 1998, a release of Formaldehyde (solution) that lasted for 45 minutes resulted in a OSHA recordable injury but no off-site impact. For each of these incidents, we have conducted formal incident investigations to identify and correct the root causes of the events. 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. The Integrated Contingency Plan (ICP) for the Solutia Inc. (Solutia) Chocolate Bayou Plant. The purpose of the ICP is to ensure the safety of those that may be affected by an emergency and to protect the environment from adverse consequences of an emergency. Consolidation of emergency response information into a single document will help to minimize any confusion that those involved in emergency response may have regarding which set of guidelines are app ropriate for an incident. The types of emergencies covered by the ICP include: * Explosion * Fire * Spill or Leak * Bomb threat * Weather Emergencies - Hurricane - Tornado - Flood - Freeze * Utility Emergencies - Nitrogen in the Instrument Air - Steam Curtailment - Electrical Curtailment or Interruption * Medical Emergencies * Offsite Transportation Spill (Rail, Highways, and Waterways) * Offsite Pipeline Spill In general, the ICP follows the National Response team's Integrated Contingency Plan Guidance and addresses the Federal and state Requirements. The ICP consists of an Introduction, a Core Response Plan, and supporting sections. The Introduction discusses purpose and provides basic identification and location information about the facility. The Core Response Plan summarizes the systems and resources used for emergency management here at the Chocolate Bayou Plant an d include flow charts that identify all steps that may be required when responding to an emergency. A complete notification list and telephone directory is also found in the Core Response Plan. The supporting sections contain a wide variety of detailed information relevant to emergency situations. Topics addressed include: * Detailed discussion of facility design, hazards, and preventive measures. * Ensuring safety of plant personnel, responders, and those in the community through adequate notification. * The roles and responsibilities of positions in the various response management systems * Specific actions to be taken by responders in various pre-identified emergency situations. * Resources and equipment available during a response. * Training and exercises/drills used to maintain preparedness. * Process used to evaluate plan performance and to make appropriate modifications. * Agreements with outside assistance providers. * Documentation of plan approvals and cert ifications. * Indexes that identify the locations of information within the ICP to satisfy various regulatory requirements. 7.0 Planned Changes to Improve Safety The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: * Revise vent system in our AN intermediate storage. * Improve the isolation capabilities of the AN-2/3 propylene feed system * Complete Facility Siting needs for location. * Maintain a capital and maintenance program to enhance reliability of operating units, therefore reducing upset conditions. * Maintain OSHA Star Status * Maintain ISO 14000 Status 8.0 Certification Solutia Inc Chocolate Bayou has no Program 1 or 2 process. To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. Steve Ward Signature Print Name Site Manager Dec 15, 2000 Title Date |