Elf Atochem North America, Inc. - Executive Summary
Executive Summary |
A Risk Management Plan has been implemented at Elf Atochem, North America, Inc.'s Beaumont, Texas facility to reduce the risks associated with accidental releases of highly hazardous chemicals. This Risk Management Plan summarizes the managerial, 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 United States Environmental Protection Agency (EPA) Risk Management Plan definitions and requirements:
* Elf Atochem's Policies to Protect Health, Environmental, and Safety
* Facility Identification and Regulated Substances in Covered Processes
* Hazard Assessment
* Prevention Program
* Five-Year Accident History
* Emergency Response Plan
ELF ATOCHEM POLICIES FOR HEALTH, ENVIRONMENT, AND SAFETY
Elf Atochem is committed to employee, public, and environmental safety by conducting its operations
in a safe and responsible manner. This commitment is inherent to a comprehensive risk management program that covers equipment design, installation, operating procedures, preventive maintenance, and employee training associated with processes at the Beaumont plant. The Risk Management Plan formalizes the management system that documents these activities.
This commitment to health, environment, and safety (HES) starts with the Chief Executive Officer. Senior Management routinely dedicates time to review HES matters. This emphasis on safety is carried on at all levels of the plant. The Beaumont plant has a safety committee that meets monthly to discuss HES topics. The success of the plant's HES program is also demonstrated by a strong commitment to safety by our employees and site contractors.
Elf Atochem's HES programs include policies, procedures, standards, and guidance materials to ensure our commitment to health, environment, and safety. These materials include Risk Managem
ent Program guidance used by our facility in the development and implementation of risk prevention and reduction programs associated with potential accidental releases.
FACILITY IDENTIFICATION AND REGULATED SUBSTANCES IN COVERED PROCESSES
The Elf Atochem - Beaumont facility is located at 2810 Gulf States Road in Beaumont, Texas. This facility manufactures Methyl Mercaptan and Ethyl Mercaptan. Methyl Mercaptan is used to produce photographic chemicals, pharmaceuticals, and Methionine, a synthetic amino acid used in animal feed supplement. Ethyl Mercaptan is used to produce agrichemicals such as biodegradable herbicides and pesticides. 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 for the Beaumont plant include:
Methyl Mercaptan 74-93-1
Hydrogen Sulfide 7783-06-4
Carbon Disulfide 75-15-0
Ethyl Mercaptan 75-08-1
TOXIC WORST CASE SCENARIO
The worst case accidental release scenario submitted for Program 3 toxic substance involves a catastrophic failure of the Methyl Mercaptan storage tank. Methyl Mercaptan is stored as a liquid in the storage tank. Administrative controls limit the quantity of Methyl Mercaptan stored to 90% of the tank liquid capacity. This quantity ( 1,300,000 pounds ) is assumed to be released over a ten minute time period and that the entire quantity is released as a vapor.
Hazard assessment data indicates that, under worst case conditions, the release could produce a Methyl Mercaptan vapor plume that could travel up to 19 (EPA Look-up Table) miles before dispersing enough to no longer pose a hazard to the public and the environment. It should be noted that the worst case scenario is recognized by the regulatory agency and Elf Atochem as an extremely unlikely event. It is noted that the worst case scenari
o is an extremely unlikely event and Elf Atochem has mitigation and prevention programs implemented to reduce the likelihood of a worst case incident from occurring.
FLAMMABLE WORST CASE SCENARIO
The worst case accidental release scenario submitted for Program 3 flammable substances involves a catastrophic failure of an Ethyl Mercaptan storage tank. It is stored as a liquid. Administrative controls limit the quantity of Ethyl Mercaptan stored to 90% of the tank liquid capacity. This quantity ( 2,000,000 pounds ) is assumed to be released over a 10 minute time period as a vapor.
Hazard assessment data indicates that, under worst case conditions , the potentially affected area is a maximum distance of 0.90 (EPA Look-up Table) miles which corresponds to end point distance of a 1 psi overpressure. Again, it is noted that the worst case scenario is an extremely unlikely event and Elf Atochem has implemented mitigation and prevention programs to reduce the likelihood of a worst case
incident from occurring.
WORST CASE RELEASE MITIGATION MEASURES
The multiple layers of preventive and mitigation measures in use at the Beaumont plant make it very unlikely that a significant release involving Methyl Mercaptan and Ethyl Mercaptan will occur. In the unlikely event that such a release occurs, Elf Atochem has mitigation measures in place to reduce potential impacts to the community.
In accordance with the guidelines used to define worst case incidents, active mitigation measures were not considered in modeling the worst case scenarios. However, the significant mitigation measures implemented at the Beaumont plant will effectively reduce the risk and consequences associated with a RMP worst case incident. Mitigation measures include:
* Fixed water deluge systems on storage vessels and stationary fire monitors that can be used to suppress vapor.
* Mechanical Integrity Program
* Trained Emergency Response Team on-site at all times.
* Member of area
TOXIC ALTERNATIVE RELEASE SCENARIO - METHYL MERCAPTAN
The alternative release scenario submitted for Program 3 toxic substance ( 44% Methyl Mercaptan mixture ) involves a 1 inch leak in the piping between the Methyl Mercaptan reactor and the Reactor effluent product separator. This scenario involves the release of 12,900 pounds of Methyl Mercaptan. Under atmospheric stability class D, conditions the vapor plume was estimated to travel 0.30 miles based on a 60 minute release. This distance provides for material to disperse sufficiently to no longer pose a hazard to the public or environmental receptors.
TOXIC ALTERNATIVE RELEASE SCENARIO - HYDROGEN SULFIDE
The alternative release scenario submitted for Program 3 toxic substance ( 56% Hydrogen Sulfide mixture) involves a 1 inch leak in the piping between the Methyl Mercaptan reactor and Reactor effluent product separator. This scenario involves the release of 15,500 pounds of Hydrogen S
ulfide. Under atmospheric stability class D conditions the vapor plume was estimated to travel 0.30 miles based on a 60 minute release. This distance provides for material to disperse sufficiently to no longer pose a hazard to the public or environmental receptors.
TOXIC ALTERNATIVE RELEASE SCENARIO - CARBON DISULFIDE
The alternative release scenario submitted for Program 3 toxic substance ( Carbon Disulfide ) involves a 1 = inch transfer hose leak at the Carbon Disulfide Unloading Station from the piping system to the Storage Tank. This scenario involves the release of 11,810 pounds of Carbon Disulfide. Under atmospheric stability class D conditions the vapor plume was estimated to travel 0.20 miles based on a 10 minute response by employees to operate the Emergency Shutdown System and to isolate and depressure line. This distance provides for material to disperse sufficiently to no longer pose a hazard to the public or environmental receptors.
FLAMMABLE ALTERNATIVE RELEA
SE SCENARIO - ETHYL MERCAPTAN
The alternative release scenario submitted for Program 3 flammable substance ( Ethyl Mercaptan ) involves a 1 inch hole in the bottom of the Reactor effluent product separator. This scenario involves the release of 10,840 pounds of Ethyl Mercaptan and subsequent flash fire that potentially affects an area of 100 feet. This distance provides for material to disperse 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 mitigation measures in place to reduce potential human health and environmental receptor impact. The prevention program elements in place at Beaumont are:
* Fixed water deluge systems on storage ve
ssels and stationary fire monitors that can be used to suppress vapor.
* Mechanical Integrity Program
* Trained Emergency Response Team on-site at all times.
* Member of area Mutual-Aid organization.
* Vapor Scrubbing System
* Flare System
* Excess Flow Valves on Storage Tanks
* Emergency Shutdown Systems
* Area Gas Detectors
* Planned Inspection Programs
THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS
The Elf Atochem Beaumont plant 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 the OSHA 29 CFR 1910.119. Process Safety Management Standard and the EPA Risk Management Program 40 CFR 68. The accident prevention program includes the following elements and activities:
In-depth process hazard analysis studies conducted every five years by personnel knowledgeable with the process. The team util
izes study techniques approved under the OSHA Process Safety Management Standard.
Written operating procedures are certified on an annual basis and are used to train affected personnel to perform their job tasks in a safe manner. All personnel working in a covered process have been certified to work their jobs.
A Management of Change Program is in place to ensure that process operating changes are managed safely and that no additional risks result from the change.
Critical equipment is inspected on a planned, periodic basis to ensure safe operating conditions.
Pre-Startup Safety Reviews are conducted by plant personnel on all changes that affect the Process Safety Information.
Routine investigation of incidents is conducted as part of continuous improvement.
Routine audits are conducted to evaluate that safe operating practices are being followed.
All equipment including, pressure vessels, piping systems, pumps, compressors, and instrumentation are designed in accordance with
industry codes and standards.
A safety permitting system is in place to control work activity.
A process control system is monitored on a 24 hour basis by plant personnel.
FIVE-YEAR ACCIDENT HISTORY
As of June 1994, there has been one accidental off-site release from the Beaumont plant. On April 14, 1998 the facility had a release of 26 pounds of Hydrogen Sulfide which resulted in the voluntary shelter in place of six employees of our industrial neighbor located north of the plant. There have been no releases involving Methyl Mercaptan, Ethyl Mercaptan, or Carbon Disulfide during the past five years.
EMERGENCY RESPONSE STATEMENT
The Elf Atochem- Beaumont facility maintains a written Site Emergency Response Plan. The plan includes the procedures for notifying civil authorities and the public in the event of an accidental release. Material Safety Data Sheets (MSDS) are maintained to provide appropriate medical treatment and first aid necessary in response to an accidental huma
n exposures. All employees and contractors are trained in the plan and drills are conducted on an annual basis. The plan provides response guidelines for employee use to respond to liquid spills, gas releases, and fires. The plan is updated as necessary based on review of incidents or drills.
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. Furthermore, the Beaumont Plant is in the process of preparing its Title V permit application to be submitted to the EPA in April 2000.