Nalco/Exxon Energy Chemicals, L. P. - Executive Summary

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A. Executive Summary (?68.155) 
At the Nalco/Exxon Energy Chemicals L. P. Freeport plant, we are committed to operating and to maintaining our process in a manner that is safe for our employees, the public and the environment.  As part of this commitment, we have established a Risk Management Program (RMP) that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Program (the RMP rule).  One element of the RMP rule is a Risk Management Plan (RMPlan) which details accident prevention measures and safeguards.  This document is intended to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of our risk management program. 
1. Accidental Release Prevention and Emergency Response Policies 
Accidental release prevention and emergency response planning programs are vital to ensure the safety of our employees, the community and the environme 
nt.  The Nalco/Exxon Energy Chemicals L. P. Freeport plant implements reasonable controls to prevent foreseeable releases of the hazardous substances we use.  In the event of a significant accidental release, trained responders will act to control and contain the release.  We work with the local emergency response organizations to evaluate potential releases and to formulate appropriate responses to contain and to prevent and/or reduce the consequences of such a release.  Nalco/Exxon Energy Chemicals L. P., in conjunction with the local emergency planning and response organizations, has established a means to warn the surrounding communities in the event of a release which would threaten the public. 
2. Stationary Source and Regulated Substances 
Nalco/Exxon Energy Chemicals operates a manufacturing facility at the Freeport site in Brazoria County, Texas.  This batch-process facility produces a wide variety of materials for use in oil field and water treatment applications. Ethylene Ox 
ide and Propylene Oxide are reacted individually or in series with other raw materials to form the majority of our products. In our oxyalkylation process, Ethylene Oxide and Propylene Oxide are the only RMP regulated chemicals that are present above the EPA threshold quantity. There are no RMP-covered flammables used at this facility. Also, for the purpose of this RMPlan, the use of EO and PO is considered as one process for our site: 
Program Level    Regulated Substance    Type    Process Inventory 
3    Ethylene Oxide    Toxic    265,000 Pounds 
3    Propylene Oxide    Toxic    260,000 Pounds 
Note:  The Process Inventories for EO and PO are based on inventory management controls.  The storage tanks are equipped with interlocks to maintain levels below 90% capacity (approx. 260,000 lbs.). 
3. Key Offsite Consequence Analysis Scenarios 
The following are brief summaries of the Worst-Case and Alternate Release scenarios for our facility, including information about the key administrative controls and mitigatio 
n measures to limit the exposure distances for each scenario: 
Worst-Case Release Scenarios for Regulated Toxic Chemicals 
Ethylene Oxide:  
    Rupture of a full rail car, releasing 170,000 pounds of EO in 10 minutes, potentially resulting in an offsite impact. 
Propylene Oxide:  
    Rupture of a full rail car, releasing 170,000 pounds of PO in instantaneously, potentially resulting in an offsite impact. 
Worst-Case Release Scenarios for Regulated Flammable Chemicals 
Not Applicable 
Alternate Release Scenarios for Regulated Toxic Chemicals 
Ethylene Oxide:  
   A gasket leak on a 2 in. unloading hose, releasing 9,600 pounds of EO in 10 minutes, potentially resulting in an offsite impact.  
Propylene Oxide: 
   A gasket leak on a 2 in. unloading hose, releasing 9,400 pounds of PO in 10 minutes, potentially resulting in an offsite impact. 
Alternate Release Scenarios for Regulated Flammable Chemicals 
Not Applicable 
Key Administrative Controls and Mitigation Measures for Above Sc 
? Automatic shutoff devices and relief valves 
? Safety controls (alarms, interlocks and leak detectors) 
? Firewater deluge system 
? Site personnel emergency response training 
? Site personnel emergency shutdown training 
Additional Administrative Controls and Mitigation Measures at Ethylene Oxide storage 
? EO emergency vent scrubber  
? Refrigeration system on Ethylene Oxide storage 
4. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
Accident prevention is our top priority and a vital part of our business. A number of programs are in place at our facility to prevent accidental releases and to ensure safe operation.  These programs include: 
? Process Safety Information 
? Process Hazard Analysis 
? Incident reporting and investigation 
? Mechanical Integrity Program 
? Training Program 
? Emergency Response  
? Standard Operating Procedures 
? Critical Safe Work Permitting System 
? Management of Change System 
? Prestartup Safety Reviews 
? Contra 
ctor Safety Program 
? Compliance Audit Program 
? Employee Participation 
In addition to the accident prevention programs, we have implemented the following chemical-specific prevention measures: 
? Release Detection 
- Hydrocarbon detector with alarms 
- Process alarms 
- Remote camera 
? Release Containment and Control 
- Relief valves on process equipment discharging to flare 
- Emergency vent scrubber on EO storage  
- Automated and manual valves to allow for process isolation 
- Interlocks on specific process parameters to provide automatic shutdown 
- Curbing and diking to contain liquid releases 
- Redundant equipment and instrumentation (e.g. uninterruptible power supply on process control system, backup firewater pumps) 
- Atmospheric relief devices 
? Release Mitigation 
- Fire suppression and extinguishing systems 
- Deluge system for specific equipment 
- Trained emergency response personnel 
- Blast resistant control room to help protect personnel and control systems 
5. Five-Year Acc 
ident History 
In the past five years, our facility has not had any accidental releases that resulted in deaths, injuries, or significant property damage on site or offsite or any evacuations, sheltering in place, property damage, or environmental damage. 
6. Emergency Response Program 
Our facility maintains an emergency response and contingency plan, which meets all of the federal, state and local regulatory requirements and is communicated to all employees.  This plan and the emergency response training for site personnel provide protection for our employees, the public and the environment.   
Representatives of our facility are active members of Brazosport's Community Awareness and Emergency Response (CAER) group, the Brazoria County Petrochemical Council (BCPC), the Local Emergency Planning Committee (LEPC) and the Brazosport Emergency Planning Committee (BEPC).  All of these groups work to improve the communication between the chemical companies about emergency response and mitig 
ation.  Furthermore, we share information to better enable us to protect our workers, communities and environment and to prevent accidental releases. 
Regular drills involving on site emergency responders, the local fire department and the local industrial mutual aid team are conducted.  These drills are based on scenarios of fires, explosions and/or toxic releases and may involve any or all of the above response organizations. 
7. Planned Changes to Improve Safety 
The following improvements were identified during initial Process Hazard analyses at our facility:  
Improvements already completed include: 
1) Review of relief systems for adequacy and change as necessary to handle worst emergency case. 
2) Addition of more alarms and review of set points of existing alarms for adequacy. 
3) Addition of more instrumentation to better monitor process conditions at more points along the process train. 
4) Installation of backflow prevention measures to avert hazardous contamination or mixing o 
f incompatible chemicals. 
5) Revision of standard operating procedures to clarify process steps and to eliminate possible confusion or error. 
6) Established a mechanical integrity and preventive maintenance program to monitor critical equipment and instrumentation and to minimize unforeseen failures. 
7) Installation of vent flare to incinerate all vent gases and minimize hazardous material release during an emergency venting situation. 
8) Updated all plant drawings to reflect equipment and piping changes to provide an accurate tool for site personnel. 
Planned improvements include: 
1) Further automation of process equipment to minimize the opportunity for human error. 
2) Addition of more instrumentation to allow for closer monitoring of process conditions and installation of more interlocks to provide additional safeguards against accidents. 
3) Revalidation of the initial Process Hazard Analyses to verify that all hazards uncovered initially have been satisfactorily mitigated and to d 
etermine that no new hazards have been introduced.
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