BetzDearborn Inc. BEAUMONT - Plant - Executive Summary |
|
Executive Summary Accidental Release Prevention and Emergency Response Policies Our company senior management and the facility personnel are committed to safety and implementation of safe procedures. We operate under the policy for Safety, Health & Environment (SHE) of our parent company - Hercules Incorporated. Sections of our SHE policy states that we: " are dedicated to and working towards continuous improvement in our operations to prevent pollution; to reduce risk; and to enhance safety, health and environmental performance." "will evaluate the safety, health, and environmental impacts of new and existing products and operations and will work to reduce adverse impacts." "will work to continually reduce workplace injuries; incidents with the potential for causing property damage, material loss, or interruption of our business; waste; and releases to the environment." Facility Description and The Regulated Substances Handled BetzDearborn Inc., manufactures specialty wa ter-treatment chemicals that are primarily used for the treatment of water and wastewater in industrial process systems such as boilers, refineries and cooling towers. Most of our products are water based made by blending several raw materials within a mixing vessel and then packaging into various size containers. Depending on our customers' need, our package types can range from small 5-gallon pails to 6000 gallon truckload quantities. Similarly, the raw materials we receive from suppliers come in various size containers depending on customer demand for the product and the amount necessary to meet supply limitations and production demand. The BetzDearborn - Beaumont Plant covers a total of 106 acres of land, of which only about 40 acres is used for offices, warehouse(s), production facilities, outdoor material storage and parking lot. The balance of the property consists of access roads, open lawn and idle areas. At the facility, Ethylenediamine (EDA) is a liquid chemical store d on site in 55-gallon drums. It is used as a raw material in our manufacturing process to make products that are used by the oil industry. Our products which contain EDA help prevent the release of hydrogen sulfide to the environment when they are added to the manufacturing process in the oil industry. This material is stored in a protected area and removed from any combustion sources. We also store Epichlorohydrin, Propylene Oxide and Dimethyamine onsite in tanks. Each of these products have unique properties used by our customers to help treat their waste or process waters. Propylene oxide is used as a component of a polymerization inhibitor product used by the chemical industry. The use of such inhibitors help the chemical industry save energy and reduce waste and fouling in the equipment. Epichlorohydrin (EPI) and Dimethylamine (DMA) are "building block" chemicals we use to make some of our other products. Products made with EPI are used in the paper industry to help equip ment function efficiently. The benefit is the waste reduction. Products made with DMA are used to clean water in water treatment facilities. The Worst-Case Release Scenario(s) And The Alternative Release Scenario(s) At the facility, Epichlorohydrin, Propylene Oxide and Dimethylamine are delivered by railcar. Our "Worst Case" event involves a scenario where a railcar of EPI is lost as an instantaneous release to an uncontained pavement outdoors during material delivery. Using the U.S. EPA Offsite Consequence Guidance modeling data, the scenario that would have an offsite consequence. We did not consider any passive controls although these materials are normally stored in protected containment areas when not in transit. We also conservatively viewed that a whole tank car of any of these materials would be released without any intervention by plant personnel to stop the release or to control the spread of the release. Within the Ethylenediamine drum storage process, our "Worst Case" event involves a scenario where the contents of several drums are lost as an instantaneous release to an uncontained pavement outdoors during material transfer. Using the U.S. EPA Offsite Consequence Guidance modeling data, this scenario would have an offsite consequence. Although this material is normally stored in a protected containment area when not in transit, for the purposes of meeting the EPA requirements we did not consider any "passive" controls. We also conservatively viewed that an amount of several drums would be released without any intervention by plant personnel to stop the release or to control the spread of the release, even though our facility personnel are capable of responding to mitigate a release of this chemical in various ways. Because all plant operators are well trained in hazardous chemical handling procedures, forklift operation, and spill response, we think that a release event of this sort is unlikely to occur. "Alternative Scenarios" for Epic hlorohydrin and Propylene Oxide, events more likely to occur than the "Worst Case" considered release events of where a spill occurs during unloading but the release is terminated by plant operator within 20 minutes. Mitigation systems were not included in these scenarios. Using EPA methodology, these scenarios would have an offsite consequence but no public receptors would be involved. We chose to evaluate this scenario because the EPA required an "Alternate Scenario" that extended beyond the fenceline. Also as an "Alternative Scenario", an event more likely to occur than the "Worst Case" involving Ethylenediamine, we considered a release event of a single drum, again using the EPA methodology. Mitigation systems were not included in this scenario. The analysis indicates that this scenario would have an offsite consequence but no public receptors would be involved. We chose to evaluate this scenario because the EPA required an "Alternate Scenario" that extended beyond the fenc eline, although we feel an event involving a minor drum puncture of substantially less than a drum quantity would be more likely and would have no offsite consequences. As an "Alternative Scenario" for Dimethylamine, an event more likely to occur than the "Worst Case", we considered a release event of a single tank to be lost as gas, again using the EPA methodology. Mitigation systems were not included in this scenario. The analysis indicates that this scenario would have an offsite consequence but no public receptors would be involved. We chose to evaluate this scenario because the EPA required an "Alternate Scenario" that extended beyond the fenceline. The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The purpose of the program is to define steps that are taken to identify, evaluate, and prevent or mitigate releases of hazardous chemicals that could occur as a result of failures in processes, procedures, or equipment. The prevention prog ram includes elements that cover the compilation of process safety information related to the process, performance of process hazard review to identify and evaluate potential release scenarios, development and use of operating procedures, processes for insuring proper training of employees who are involved in handling hazardous chemicals, preventive maintenance for key equipment to limit the potential for failures that could cause releases, processes for managing changes in the process and conducting incident investigations for any release events that may occur. The prevention program also includes requirements for performing compliance audits of the implementation of the prevention program. The Five-Year Accident History At the BetzDearborn - Beaumont Plant we have not had any accidental releases that resulted in significant death, injury, property damage on-site or known offsite deaths, injuries, evacuations, sheltering-in-place, property or environmental damage in the past 5 yea rs due to the use or handling of Ethylenediamine, Propylene Oxide, Epichlorohydrin and Dimethylamine. The Emergency Response Program Our chemical release response program contains these elements: - Identification of emergency organization personnel structure and functional responsibilities - Quarterly inspections to determine any new sources of ignition and a check of safety control devices - Fire extinguisher training - Fire drills conducted by our facility - Spill and release control instructions - Evacuation procedures and external response notifications - Incident coordination with local emergency responders - Incident analysis and review with all plant personnel, and identification of procedure changes - Annual program review and re-training - In applicable regions: Hurricane preparedness and plant readiness procedures Planned Changes To Improve Safety Our plans for safety improvement include implementing a single layer-only operating practice when transporting RMP-regula ted substances on-site via forklift truck. Also, we intend to evaluate the feasibility of additional fire protection equipment to service RMP regulated processes |