ICI Acrylics, Inc. - Executive Summary |
|
EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At ICI Acrylics, Inc. - Beaumont, Texas site, 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: * 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 o verview of our emergency response program * 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 * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility produces Methylmethacrylate (MMA) using a variety of chemicals and processing operations. Another part of the facility regenerates spent material for reintroduction into the MMA process. 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: Toxics Oleum is a cloudy, oily liquid with an acrid odor. It is a mixutre of sulfuric acid and sulfur trioxide and is corrosive. ICI Acrylics, Inc. uses oleum as a raw material i n the produciton of MMA. ICI is capable of storing 3,000,000 pounds of Oleum on site. Flammables Trimethylamine (TMA) is a colorless liquid under pressure, and has a fishy, ammoniaical odor. It is used in chemical manufacturing and is flammable and corrosive. ICI Acrylics uses TMA in the production of MMA. ICI is capable of storing 70,000 of TMA pounds on site. 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. 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: Regulated Toxic Release Scenar ios Oleum Worst Case Scenario * Complete failure of tank system * Failure of all safety systems * Worst possible weather condition (no wind, low humidity) * Total release of the entire contents of tank * 25 miles or greater distance of concern * Impacted Public: industrial, commercial, residential & environmental receptors Oleum Alternative Case Scenario * Tank overfill during maintenance of secondary tank * Overfill interlock minimizes release * Average weather conditions * Total release of 1000 pounds of Oleum * Distance of concern - 0.48 miles * Impacted public - Other tenants of the Dupont Industrial Park Accident Prevention In - Place * Dual Storage tank system with maximum total of both tanks not to exceed storage capacity of a single tank alone * Overfill and process control interlocks * Emergency shutdown procedures * Comprehensive process training programs for operations pe rsonnel * Crisis management drills * Emergency response measures * Comprehensive written operating procedures * Agressive preventive maintenance * Routine hazard reviews Regulated Flammable Release Scenarios Trimethylamine Worst Case Scenario * Complete failure of a pressurized TMA storage tank * Failure of all safety systems * Total release of the entire contents of tank (70,000 pounds) * Entire volume vaporizes instantaneously and explodes * Distance of concern - .31 miles * Impacted public - other tenants of the Dupont Industrial Park Trimethylamine Alternative Case Scenario * Tank truck hose uncouples during unloading * Pressure interlock minimizes release * Average weather conditions * Total release of 100 pounds * Distance of concern - Less than .06 miles (< 317 feet) * Impacted public - other tenants of the Dupont Industrial Park Accident Prevention In-Place * Containment dike * Overfill / overpresssure process control i nterlocks * Emergency shutdown procedures * Comprehensive process training programs for operations personnel * Crisis management drills * Emergency response measures * Comprehensive written operating procedures * Agressive preventive maintenance * Routine hazard reviews 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. 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: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Ho t work permit * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: * Containment dike * Overfill / overpresssure process control interlocks * Emergency shutdown procedures * Comprehensive process training programs for operations personnel * Crisis management drills * Emergency response measures * Comprehensive written operating procedures * Agressive preventive maintenance * Routine hazard reviews 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. FIVE-YEAR ACCIDENT HISTORY ICI keeps records for all significant accidental chemical releases that occur at our facility. Each incident of this typ e is formally investigated to identify and correct the root cause of the event. The EPA's definition of accidental release is one that results in death, injuries, significant property damage, evacuations, shelter-in-place or environmental damage. There have been no significant accidental chemical releases involving RMP chemicals at the Beaumont site in the past five years. 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. CERTIFICATION The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true accurate, and com plete. Signature ___________________________________________________ Keith Rogers Title Plant Manager ICI Acrylics, Beaumont Site Date _____________________ RMP DATA ELEMENTS The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: * Registration * Offsite consequence analysis * Five-year accident history * Program 3 prevention program * Emergency response program |