ZENECA Ag Products Bayport Site - Executive Summary |
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The Zeneca Ag Products Bayport Site located at 5757 Underwood Road in Pasadena, Texas, manufactures herbicides. The EPA Risk Management Plan (RMP) regulations apply to this facility because more than threshold amounts of certain toxic chemicals are stored in the facility. The Bayport Site stores more than threshold quantities of anhydrous ammonia, aqueous ammonia, chlorine and methyl chloride. These four chemicals are all listed as toxic chemicals. The RMP regulations require Zeneca Ag Products to register with EPA, implement accidental release prevention and emergency response programs, and prepare and submit certain information to local emergency planning officials and the general public. Zeneca Ag Products has registered with the EPA, implemented the required programs, and prepared and communicated the required information to the EPA, local emergency planning officials, and the public. All information in these submissions was current at the time of filing. Updated information i savailable at the Bayport Site. The Zeneca Ag Products Bayport Site has policies and procedures in place for the prevention of accidental releases of hazardous chemicals. The Bayport Site has complied with 40CFR68 and continues to maintain compliance through required reviews and audits. The goal of the accidental release prevention program is to insure that the plant systems are designed, operated, maintained, and modified correctly and safely. The policies and procedures used to prevent accidental releases include: 7 Process Safety Information - Complete documentation of the basis for design and safe operation of all systems is maintained to insure that accurate information is used in all aspects of design, operation, maintenance, and modification of the facility. 7 Process Hazard Analysis - Thorough analysis of all potential hazards involved in the operation and maintenance of the facility are conducted on a routine basis. Unacceptable risks are identified and corrective actions ar e taken when necessary. 7 Operating Procedures - Written operating procedures are available and kept up to date. Written operating instructions are issued when changes are required and a complete review and rewrite of the affected procedure is performed at the same time. 7 Training - Training is conducted on a routine basis and results are verified. Training records are maintained to insure that qualified personnel are operating plant systems. 7 Mechanical Integrity - A mechanical integrity program is in place to insure that all equipment is fit for the purpose that it was intended. This program includes standard maintenance procedures, certified craftsmen, written specifications, verification of materials, and equipment inspection. 7 Management of Change - A written procedure is in place to identify and document changes. This system insures that all changes are given a complete review before implementation. 7 Pre-startup Safety Review - A system is in place to insure that all safety c oncerns are resolved before new, modified or repaired equipment, or systems are put into service. 7 Audits - Regular audits are conducted on individual procedures and complete programs to insure that policies and procedures are in place, that the policies and procedures are correct and that the policies and procedures are being followed. 7 Incident Investigation - A written procedure is in place for identifying, investigating, and reporting all process safety incidents. 7 Employee Participation - A written policy and procedures are in place to promote employee involvement in the process safety activities on the Site. All employees have the opportunity to participate in a wide range of activities. 7 Hot Work - A written procedure is in place to insure safety during any activities involving hot work, such as welding or grinding. 7 Contractors - A written procedure is in place to insure that qualified contractors are selected and that activities that contractors are involved in are condu cted safely. In addition to the general policies and procedures mentioned above there are a number of specific procedures in place for the regulated chemicals. Specific procedures include: 7 Monitoring of all operating areas on every shift. All piping and equipment is monitored by looking, listening, and smelling to identify small leaks. All leaks are repaired as soon as possible to prevent the possibility of a small leak becoming an accidental release which would affect the public. Monitoring of areas containing ammonia are documented in a log book. 7 Quarterly monitoring of piping and equipment in methyl chloride service is conducted by "sniffing" piping connections and shaft seals with a chemical detector. Any leaks identified in this testing are documented and repaired within specified time periods. 7 Specific design practices are used for anhydrous ammonia and methyl chloride. Critical process valves are locked open or closed to prevent buildup of pressure if the material is he ated. Relief valves are used on all process vessels to protect against over-pressurization. Excess flow valves are used in outlet piping on large vessels to limit the flow of chemical in the event of a piping failure. All vessels are built to ASME codes. All piping is built to ANSI standards. 7 Additional safety systems are in place including backup power generators to allow emission control equipment to continue to function during a power failure, battery backup for instruments, and monitor fire nozzles permanently installed to allow rapid response to fire to prevent equipment failure. 7 DOT certified storage cylinders and concrete bunkers are used in chlorine service to prevent accidental damage during transportation, storage and operation. The Zeneca Ag Products Bayport Site has procedures, systems, and equipment in place for emergency response in the event that an accidental release should occur. A highly-trained Volunteer Emergency Response Team (VERT) is available on the Site 24 hours per day, 7 days per week. The VERT teams are trained in fire-fighting, rescue, and emergency responder techniques. The VERT teams regularly drill in simulated emergency response situations on-site and in Channel Industries Mutual Aid (CIMA) drills. The Zeneca VERT teams have participated with other CIMA member companies in local emergency response including the Phillips, Oxychem, and Hoyer incidents. Equipment available to the VERT teams includes a quick attack truck, foam cannon, hand-held wheel units, fixed hose houses and fixed monitor nozzles supplied from a fire water distribution system with a 2,000,000 gallon reserve capacity, hazardous materials trailer, incident command vehicle, and ambulance. Some VERT team members are trained to Emergency Medical Technician or First Aid Responder skill levels. In addition to the VERT teams, Zeneca has an Emergency Operations Center (EOC) which would coordinate off-site communication and support activities in the event of an emergency. All emergency procedures and planning are documented in an emergency manual including pre-plans and detailed procedures. The Zeneca Ag Products Bayport Site has prepared and submitted a 5 year accident history. No accidents occurred at the Bayport Site which were reportable under the RMP rules. The Bayport Site has had accidental releases of the four chemicals over the last 5 years. For example, in 1997, 1,000 pounds of anhydrous ammonia were released when piping failure and a leaking valve resulted in a release and an injury to an employee. The employee received a small second-degree burn to the upper leg area. The release resulted in no other injuries, complaints, or impact on the general public. Public officials were notified. This incident and other smaller incidents had no impact on the public and were not reportable in the RMP submission. The Zeneca Ag Products Bayport Site has submitted an off-site consequence analysis (OCA) including worst-case and alternate-release scenario s for the four regulated chemicals The scenarios used in the OCA were prepared using a review of the 5 year accident history, plant incident reports, process hazard analysis results, and brainstorming by experienced operations personnel. These reviews identified worst-case scenarios (WCS) and plausible alternative release scenarios (ARS) which were developed using the guidelines provided in EPA regulations. The accidental releases identified in the worst-case and alternate release scenarios were modeled using EPA look-up table methodology (Risk Management Program Guidance for Offsite Consequence Analysis). The worst-case scenario is failure of an anhydrous ammonia storage tank containing 65,000 pounds of anhydrous ammonia. The anhydrous ammonia is released within a period of 10 minutes and there are no credits taken for active or passive mitigation. Since this facility is located in a populated area, the toxic cloud formed by the evaporating ammonia would reach offsite endpoints and n earby public receptors. Complete OCA results that show the impact of the release on the public and information on Zeneca Ag Products accident prevention and emergency response programs are available at the Bayport Site by contacting the Site Administrative Assistant at 281/474-5151, extension 301. Zeneca Ag Products has implemented a zero-tolerance culture for incidents at the Bayport Site. Incidents which could result in accidental releases will not be tolerated. Efforts of all personnel on the Bayport Site are being focused on the elimination of these incidents. The Bayport Site has audit and review procedures in place which promote a philosophy of continuous improvement in safety and accident prevention. The Bayport Site is also expending significant resources to maintain and improve emergency response capabilities. Zeneca Ag Products Bayport Site plans to continue to expand communications to the general public in the local area. Plans include speaking to local community grou ps and schools, participating in public events, and working with local emergency planning officials. |