Eval Company of America - Executive Summary

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Executive Summary 
EVALCA's environmental health and safety program includes policies, procedures, standards, and guidance materials designed to fulfill EVALCA's commitment to the environment, safety and the health of our employees and neighbors.  These materials include Risk Management Program (RMP) guidance to help our facility prevent and/or reduce the risk of accidents. 
This Risk Management Plan summarizes the management, administrative, procedural, and technological controls that, when integrated, minimize public risk of hazardous chemical release exposure.  The plan summary is organized to correspond with the specific EPA RMP definitions and requirements. 
Overall responsibility for all facility activities, including Risk Management Program activities, lies with the Plant Manager.  The Plant Manager has delegated the following responsibilities: 
7 RMP hazard assessment and document control to the Environmental Manager. 
7 Implementation of the RMP prevention program to the Techno 
logy Manager. 
7 Development & maintenance of the RMP emergency response program to the Human Resources Safety Manager. 
7 Training and communication of RMP related matters to Maintenance & Production Manager. 
More specific responsibilities are delegated to other staff positions as detailed in the plant Emergency Response Plan. 
Accidental Release Prevention and Emergency Response Policies 
EVALCA is committed to conducting its operations in a safe, responsible manner and reducing risks to health and the environment.  Compliance with all applicable legal requirements is mandatory and considered essential to upholding the company's commitment.  EVALCA's Environmental, Health and Safety programs include policies, procedures, standards and guidance materials designed to minimize the potential for an accidental release. 
Description of the Stationary Source & Regulated Substances 
EVALCA, located in Pasadena, TX, manufactures ethylene vinyl alcohol copolymer in a continuous chemical reactio 
n process.  Ethylene vinyl alcohol copolymer is used in the manufacture of consumer goods packaging  such as: laundry detergent bottles, ketchup bottles, and plastic lined boxes like those used for drink boxes.   
The only RMP regulated substance on site at EVALCA above the EPA threshold quantity is vinyl acetate monomer, classified as a toxic in the RMP Rule. Vinyl acetate monomer is used as a raw material for manufacturing ethylene vinyl chloride copolymer.  The maximum quantity held on site is about 900,000 pounds. 
Hazard Assessment 
The worst case scenario (WCS) for toxic materials in Program Level 3 at the facility is an instantaneous loss of inventory of the vinyl acetate monomer storage tank, a maximum of 900,000 pounds of vinyl acetate monomer.  A 5 foot high dike wall, currently surrounding this storage tank, was considered as a passive mitigation measure when evaluating this scenario.  The dike wall, currently in place, significantly mitigates the effects this scenario has o 
n neighboring facilities and the general public.  Modeling indicates that the plume from this release would have offsite impacts, but only to the nearby industrial facilities. 
The Alternate Release Scenario (ARS) modeled was a 0.1" flange or gasket leak within the vinyl acetate monomer metering station, resulting in a release of 256 pounds of vinyl acetate monomer over a 51 minute time period (10 minutes to isolate leak, and 41 minutes for emptying of isolated section).  Area detection monitors around the vinyl acetate monomer metering station and automated block valves in the line are part of a mitigation program that provides early warning and rapid isolation capabilities.  Modeling results indicate that the plume from this release would barely cross the facility boundary and would only affect the nearby industrial facilities. 
Accidental Release Prevention Program 
In general, EVALCA has implemented numerous steps to minimize the potential of a release of any chemical on site.  All 
storage tanks are located within diked areas, truck unloading facilities have been replaced by direct pipeline feeds, which are equipped with low pressure alarms and automated shut-off valves.  Furthermore, all of the process areas at this facility regulated by the EPA Risk Management Program regulation are also subject to the OSHA Process Safety Management (PSM) standard.   Processes containing Vinyl acetate monomer that are subject to the EPA RMP Rule have been incorporated into the existing OSHA PSM program, resulting in a program in compliance with both the OSHA and EPA regulations.  Specific elements of this program include the following: 
7 Employee Participation in process safety management and accident prevention. 
7 Process Safety Information 
7 Process Hazards Analysis (PHA) 
7 Documented Operating Procedures 
7 Training Programs for all Employees 
7 Contractor Requirements and Training 
7 Pre-startup Reviews 
7 Mechanical Integrity and Quality Assurance Programs 
7 Management of Ch 
ange Process 
7 Incident Investigation 
7 Compliance Audits 
7 Safe Work Practices 
Prevention steps for the Worst Case Scenario primarily consist of preventative tank maintenance and safe work procedures.  The vinyl acetate storage tank is located in a secure area and there are no flammable substances stored within this diked area.  In the unlikely event of a tank rupture, the dike surrounding the tank will minimize the spread of vinyl acetate monomer liquid and consequently significantly reduce the impact of the spill. 
A flange or gasket failure was selected as the Alternate Release Scenario. This scenario was selected because it has the most severe offsite impacts that are less severe than the WCS, and it will  be a good exercise for emergency response training.   Prevention steps and mitigation measures considered in the ARS evaluation include: 
7 Periodic visual inspections of equipment and piping 
7 Mechanical integrity programs in place during the design, purchase and installation  
of equipment and piping  
7 Local area detection monitors installed in the vicinity of the metering station 
7 Low flow and low pressure alarms to indicate a loss of flow or pressure in the pipeline. 
Five-Year Accident History 
EVAL Company of America (EVALCA) has an excellent accident prevention record.  Over the past 5 years at this facility, there have been no incidents involving vinyl acetate monomer which resulted in death, injuries, or property damage onsite or known offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. In fact there have been no incidents of this type in the life of the facility. 
Emergency Response Program 
Our emergency response program is based upon the OSHA 29 CFR 1910.38 standards, as well as meeting RMP requirements.  The emergency response plan includes procedures for notifying the local fire authority and any potentially affected neighbors and has been coordinated with local agencies.  
EVALCA maintains a wri 
tten emergency response program, which is in place to protect workers and the general public as well as the environment.  The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released.  The procedures address all aspects of emergency response, including proper first aid, medical treatment for exposure, evacuation plans, accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements.  The emergency response program is updated when additional process units are brought on line or when modifications are made to an existing process unit(s).  When the emergency response program is updated, employees are informed of the changes and trained appropriately through the management of change (MOC) process. 
Planned Changes to Improve Safety 
l safety has been a part of the working culture at the facility for many years, as is evident by our perfect safety record.  Reducing our employee's risk and the general public's risk to chemical exposure is an ongoing effort.  EVALCA resolves all findings from Process Hazard Analyses, some of which result in process modifications.  While these ongoing procedures may result in future safety improvements, EVALCA currently does not have any changes in the planning stages.
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