Elf Atochem North America, Inc. Houston, TX Plant - Executive Summary |
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Introduction A Risk Management Program has been implemented at Elf Atochem's Houston, Texas production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The plan summary is organized to correspond with specific EPA RMP definitions and requirements, including: - Introduction; - Elf Atochem Policies to Protect Health, Environment, and Safety; - Faciltiy Identification and Regulated Substances in Covered Processes; - Hazard Assessment; - Prevention Program; - Five-Year Accident History; - Emergency Response Plan; and - Planned Changes to Improve Safety. Elf Atochem Policies for Health, Environment, and Safety Risk management and safety have been important concerns at Elf Atochem for many years. This Risk Management Plan formalizes and documents these activit ies. Elf Atochem is committed to conducting its operations in a safe, responsible manner and to reduce risks to health and the environment. This commitment to health, environment, and safety (HES) starts with the CEO. Senior management routinely dedicate time to review HES matters. This emphasis on safety is carried through to the facility level, where the Plant Manager and the Safety Committee regularly review safety performance, take corrective actions, and strive for continuous improvement. The success of Elf Atochem's HES programs is also reflected by a strong commitment to safety by employees and contractors. Elf Atochem's HES programs include policies, procedures, standards, and guidance materials designed to fulfill Elf Atochem's commitment to health, environment, and safety. These materials include Risk Management Program guidance to help our facilities prevent and/or reduce the risk of accidents. This facility is covered by Title V of the Clean Air Act, but has not rec eived a permit as of the date of this submittal. Facility Identification and Regulated Substances in Covered Processes The Elf Atochem Houston facility is located at 2231 Haden Road, Houston, Texas. The facility manufactures mercaptans and sulfides. Certain substances used and produced within the facility are regulated substances under 40 CFR 68, the EPA Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability and include: Carbon Disulfide (CS2) 2,540,000 lbs Hydrogen Sulfide (H2S) 13,000 lbs Carbon Disulfide (CS2) is a by-product of Hydrogen Sulfide (H2S) production. Hydrogen Sulfide (H2S) is manufactured on site to produce mercaptans. Hazard Assessment - Worst Case Scenario The worst-case accidental release scenario is associated with a catostrophic failure of a Carbon Disulfide (CS2) rail car. Carbon Disulfide (CS2) is manufactured and placed in rail cars for shipment to customers. Administrative controls l imit the CS2 quantity in rail cars to a maximum of 192,300 lbs. This quantity is assumed to be released over a 10 minute period in the worst-case scenario with a 24 minute evaporation rate in consideration of the extent of release. Hazard assessment data indicates that, under worst-case conditions, a release of CS2 could travel up to 16 miles before dispersing enough to no longer pose a hazard to the public and environmental receptors. It should be noted that the worst-case scenario is recognized by the regulatory agency and Elf Atochem as an extremely unlikely event. Mitigation and prevention procedures and measures are implemented by Elf Atochem to reduce the risk of the worst case event occuring. Worst-Case Release Mitigation Measures The multiple layers of preventive and mitigation measures in use at the Houston facility make it very unlikely that a significant release of CS2 similar to the worst case scenario will occur. In the unlikely event that such a release occurs, Elf Atochem has an array of mitigation measures in place to reduce any potential impacts. In compliance with regulatory criteria associated with RMP evaluations, active mitigation systems cannot be considered in modeling worst-case scenario impacts, however, the significant planning and subsequent implementation that Elf Atochem has made in active mitigation measures could effectively reduce the risk associated with an RMP worst-case related incident. Mitigation measures include: - A Carbon Disulfide (CS2) vapor supression system (deluge system), which can be supplemented by stationary and portable fire monitors, to remove airborne vapor with water sprays; - A pumping system and procedures which would allow CS2 to be pumped from a damaged rail car or tank into another storage tank or vessel to reduce the amountof CS2 which could be potentially released; - Gas detection devices placed strategically in the facility to provide early detection of a release; and - The facility has on-si te emergency responders 24 hours per day as well as a defined communications link with additional off-site responders and response equipment. Hazard Assessment - Alternative Release Scenario One Alternative Release Scenario (ARS) for each regulated toxic substance was also modeled during the hazard assessment. A description of each of these scenarios and the impact follows. The Alternative Release Scenario for Carbon Disulfide (CS2) was defined to be a failure of a 2" nozzle on the bottom of a CS2 storage vessel. The release plume was estimated to have an effective radius of .27 miles before dispersing sufficiently to no longer pose a hazard to the public or environmental receptors. The second alternative release scenario defined to be applicable for modeling consideration was for a release of Hydrogen Sulfide (H2S) associated with a flange leak on a reactor. The H2S plume from this leak was estimated at .43 miles before dispersing sufficiently to no longer pose a hazard to the public or environmental receptors. Alternative Release Scenarios - Mitigation Measures While the Alternative Release Scenarios are, by definition, more likely to occur than the Worst-Case Scenario, they are still very unlikely to occur due to the facility's existing release and accident prevention program. If a release should occur, Elf Atochem has an array of mitigation measures to reduce potential human health and environmental receptor impact, which include: - Vapor supression systems (deluge systems), which can be supplemented by stationary and portable fire monitors, to remove airborne vapor with water sprays; - Pumping systems and procedures which would allow materials to be pumped from a damaged rail car, or loaded tank, into another storage tank or vessel to reduce the amount potentially released; - Gas detection devices placed strategically in the facility to provide early detection of a release; and - The facility has on-site Emergency Response Teams 24 hours per day as well as a defined emergency communications link with additional off-site responders and response equipment. The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The Elf Atochem Houston facility has an accidental release prevention program in place to minimize the risk of hazardous chemical releases. This program is designed to address the requirements of 29 CFR 1910.119, Process Safety Management and the EPA Risk Management Program. This prevention program addresses those processes which handle regulated substances. The accidental release prevention program includes the following components and activities: - In-depth hazard analyses are completed every five years by qualified personnel using techniques approved under the OSHA PSM standard of 29 CFR 1910.119; - Written operating procedures are used for training and directing the work of operators, who receive refresher training every three years; - Operators, mechanics, and contractor perso nnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety; - A Management Of Change (MOC) system is in place to ensure that process operating changes are managed safely; - Critical equipment is inpsected on a planned, periodic basis to ensure proper operating condition; - Pre-start up reviews are performed to ensure that conditions for safe operation have been satisfied prior to starting new or modified equipment; - Incidents are investigated and actions taken as part of a continuous improvement effort; - Routine audits are conducted to ensure that safe practices are being followed; - Storage vessels are designed and constructed in accordance with American Society of Mechanical Engineers (ASME) pressure vessel standards using industry-standard materials of construction; - As part of the Mechanical Integrity program, pressure vessels and transfer lines are inspected and tested according to the American Petroleum Institute Standards; - The use of trained operators who monitor level indicators and metering devices are trained to prevent overfilling; - Relief valves and administrative controls are designed to prevent overpressure; - Tanks are vented to a common line which helps prevent unequal pressures and over pressure; - Access to the facility is restricted through security barriers and trained security personnel, thereby minimizing the risk to the tanks of vehicular damage or sabotage; and - A safety permitting system is used to ensure routine and non-routine work is carried out after identification and implementation of safe work practices. This systematic approach to process safety involves the facility employees. Management and facility personnel strive for continuing improvements in accident reduction. The training, qualification standards, and safety awareness of our operations, maintenance, and emergency response personnel are key elements in reducing and mitigating ac cidents. Worst-Case Scenario and Alternate Release Scenario for Flammable Materials The Elf Atochem Houston facility does not have any flammable substances present at or above the minimum threshold for RMP applicability. Five Year Accident History Hydrogen Sulfide: There have been no off-site releases of hydrogen sulfide from our facility for the past five years. There have been two personal injury (employee) incidents at the facility that meet the EPA RMP reporting requirements associated with release of hydrogen sulfide. There were no known off-site impacts associated with the incidents. Elf Atochem realizes that the community may also be interested in smaller releases of regulated chemicals that do not meet EPA criteria for the Five Year Accident History. We have been dilligent in reporting releases of hazardous materials and in internally investigating and addressing the causes of such releases. Carbon Disulfide: There have been no off-site releases of Carbon Disulfide (CS 2) from our facility for the past five years. Emergency Response Statement A written Emergency Response Plan is maintained at the facility. The plan was developed in cooperation with civil authorities and was coordinated with the community emergency response plan. The emergency response plan includes procedures for notifying civil authorities and the public in the event of an incident. The plan also includes documentation of proper first aid and medical treatment necessary to treat accidental human exposures; procedures for the use of emergency response equipment and for its inspection and testing. The plan also includes a description of the training program for all employees in relevant emergency response procedures and procedures for review and update, as appropriate, of the response plan, to reflect changes at the facility and to ensure that employees are informed of these changes. Planned Changes for Health, Environment and Safety Chemical safety has been a part of the wo rking culture at the facility for many years. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. Certification I certify to the best of my knowledge, the information, and belief formed after reasonable inquiry, that the information submitted is true, accurate, and complete. ____________________________________ ___________________________ Signature of Highest-Ranking Official on Site Date ____________________________________ ___________________________ Name (Print) Date ____________________________________ Title (Print) |