Rhodia Inc. Vernon, Texas Facility - Executive Summary |
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Rhodia Inc. - Vernon, Texas Plant PLANT GEOGRAPHICAL DESCRIPTION: The Vernon Plant is located on approximately forty-two acres on the north side of the city of Vernon, Wilbarger County, Texas. The property is bounded on the north by the Burlington Northern/Santa Fe Railway, on the west by Harrison Street, on the south by Sullivan Street, and on the east by the acreage of private landowners. This land is in two sections bisected by the Texas Department of Transportation ditch which eventually empties into the Pease River which is located approximately two miles north and east of the plant site. The North thirty five acres contain all plant processes, storage and waste water treatment facilities. Runoff water and/or a possible spill is channeled to a nominal 500,000 gallon concrete basin to catch the first flush of possibly contaminated rain water or emergency use water (ie., deluge, fire hydrant/sprinkler, etc.) ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY: The V ernon Plant is required to meet compliance with the Rhodia Inc. Process Hazard Management Program (PHMP). PHMP meets or exceeds the minimum requirements as listed in 29CFR1910.119 OSHA's Process Safety Management of Highly Hazardous Chemicals standard for the same regulated substance - Propylene Oxide - that is also covered by the Clean Air Act (CAA) Section 112 (r) or as more commonly referred to as the Risk Management Plan (RMP) program. The Vernon Plant conducts annual self-assessments (audits) of the PHMP and develops action plans to ensure prompt correction to any deficiencies noted during these self-assessments. Rhodia's PHMP includes the following 16 elements: 1. Unit Safety Files 2. Employee Participation 3. Process Safety Information for Chemicals 4. Process Safety Information for Technology 5. Process Safety Information for Equipment 6. Process Hazard Analysis 7 . Standard and Emergency Operating Procedures 8. Operator Training Program 9. Contractor Safety Program 10. Pre-startup Safety Reviews 11. Mechanical Integrity / Maintenance Management Program 12. Work Permit System (ie., cutting/welding, line breaking, confined space, etc.) 13. Management of Change Procedures 14. Incident Investigation Procedures 15. Emergency Response Plans 16. Audit Procedures PROCESS AND REGULATED SUBSTANCES HANDLED: The Vernon Plant processes both domestically produced guar beans and imported guar endosperm by derivatization with propylene oxide and other chemicals. Propylene Oxide, the only substance on the plant site that is regulated by the RMP rule, is stored in two 30,000 gallon above ground storage tanks. In addition to propylene oxide, the Vernon Plant also uses other non-regulated chemicals in it's processes to manufacture a variety of products, both derivatized and non-derivatized, that are sold to a number of different industries which include, but are not limited to, the following; oil field chemicals, textiles, mining, food, cosmetics and fire fighting industries. Propylene oxide is an extremely flammable liquid, that if released becomes an immediate fire/explosion hazard. It is clear and colorless and has an "ether" like odor to it. It will react with strong acids, bases, peroxides, anhydrous metal chlorides, copper and its alloys, brass, bronze and other type acetylide forming metals. Overexposure may cause; severe eye irritation, irritation to the respiratory tract and other mucous membranes, immediate irritation and blistering of the skin. This material may be a slight health hazard if ingested in large quantities. This product has been shown to induce tumors in laboratory animals and is considered by IARC and NTP to be a potential carcenigen. SCENARIO DESCRIPTIONS: Worst Case: This s cenario assumes a rupture to a fully loaded 30,000 gallon propylene oxide storage tank, resulting in 185,200 pounds of propylene oxide being released suddenly and forming a pool which will evaporate over a period of about 2 hours and 35 minutes. This scenario takes into cosideration that the winds are from the north and relatively calm at 3.4 mph, resulting in the release end point of concern (ERPG-2) going out approximately 0.84 miles from the plant (this is according to acceptable predictive modeling using PHAST software). Utilizing a semi-circle drawn on a USG map of Wilbarger County and the City of Vernon and using demographic data supplied by the City of Vernon Manager it was determined that approximately 1,135 people could be affected by this worst case scenario. Shive Elementary School, several businesses and U.S. Highway 287 also fall within this area. Alternate Release Scenario: This scernario envisions a transport truck bumping into the plant's overhead transfer pipe rack , which is located between the storage tank area and the processing unit that consumes the propylene oxide, breaking the pipe that delivers propylene oxide from the storage tank to the process, resulting in approximately 29,160 pounds being released from the 2 inch diameter pipe over a time period of 60 minutes. This scenario takes into consideration that the wind is from the north at 12 mph resulting in the release end point of concern (ERPG-2) going out 0.13 miles fron the propylene oxide storage tanks (this is according to acceptable predictive modeling using PHAST software). Utilizing the same USG map and drawing a semi-circle out from the leak source to the south (toward Vernon), it was determined that the release end point of concern (ERPG-2) would be confined within the plant fence line and would likely not affect the public population. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND PROPYLENE OXIDE SPECIFIC PREVENTION STEPS: Management at the Vernon Plant is confident tha t by utilizing the 16 elements of Rhodia Inc.'s PHMP that process incidents can be prevented. In addition, all plant employees have received training on all 16 elements, and thier participation is required in every aspect of the Process Hazard Management Program. The Operator Training and Pay Performance Program at the Vernon Plant is very extensive, ongoing and includes the following: > 40 hours of Entry Level Operator Training > Operator Job/Skills Performance Demonstration and Testing > Propylene Oxide Testing/Certification > D.O.T. Hazardous Material Awareness Training > Hazardous Waste Operations and Emergency Response Training (HAZWOPER HAZMAT Technician Level) The Vernon Plant also has an extensive Preventative Maintenance program which includes systema tic testing and maintenance of process safety controls and devices. The propylene oxide handling and storage operations are equipped with the following process safety controls and devices: > Pressure Relief Valves > Excess Flow Prevention Valves > High Temperature / High Pressure Indicators and Alarms > High Temperature / High Pressure Shutdown and Flood System > Nitrogen Purging System > AG-80 Propylene Oxide Leak Detection/Alarm System > Computerized Process Controls with Hardwired Safety Trips FIVE YEAR ACCIDENT HISTORY: The Vernon Plant has not experienced any accidents in the Propylene Oxide Handling and Storage Operations over the last five year period. PLANNED CHANGES TO IMPROVE SAFETY: PHMP requires annual deve lopment of Process Safety Management Plans. The Vernon Plant's 1999 plans is as follows: > Conduct a re-validation of the 1994 Hazards Operability Study (PHA) for the Propylene Oxide Handling and Storage Operations before the end of the 4th quarter. > Re-train Plant Operators on the Critical Operating Parameters. > Conduct a Management of Change Audit. > Update Process Safety Information as changes are made or as new information becomes available. > Involve employees in all process safety efforts. |