Noltex La Porte Plant - Executive Summary
Noltex is a manufacturer of ethylene vinyl alcohol co-polymers (EVOH). EVOH is used in packaging food and other products requiring preservation. Noltex uses vinyl acetate (a listed RMP toxic chemical) and ethylene (a listed RMP flammable chemical), along with other non-RMP-regulated chemicals in the manufacture of EVOH. Our site is located on approximately 20 acres, employs 95 company personnel and 40 contract maintenance personnel. Access to the facility is controlled and limited to employees, contractors, and escorted visitors. Noltex complies with all applicable safety, environmental, and transportation regulations related to the manufacture and distribution of EVOH. |
Noltex has expressed the desire and commitment to safe operation of our facility in our Vision and Mission Statements and our Quality Policy. The safety, health, environmental, and emergency response programs at Noltex are managed as a comprehensive and integrated factor in the conduct of our business. We apply
the principles of continuous improvement to all our management practices. Our release prevention program applies to all processes and chemicals used at Noltex and includes such diverse elements as: employee selection criteria; technical specifications which meet or exceed codes, standards, regulations, and common industry practices; fabrication and construction quality control; employee training programs in safety, environmental practices, process safety, process operations, and emergency response; standard operating procedures in operating and maintaining the facility; maintenance of process and mechanical integrity; employee involvement in safety and emergency response planning; coordination with and participation in mutual aid and community outreach activities; incident investigation and recommendation closure systems.
The offsite consequence analysis for toxic and flammable chemicals were performed using commercially available software models and the EPA Offsite Consequence Anal
ysis Guidance Document. The values for endpoint radii for our worst case scenarios and alternative release scenarios were taken as the greater of the values determined from the two methods.
The worst case scenario for vinyl acetate involves the instantaneous release of the contents (1,200,000 pounds) of a 154,000 gallon tank which is contained within a dike capable of holding the released material. This results in a release rate of 196.5 pounds of vinyl acetate per minute for sixty minutes. This scenario would cause a vapor cloud to go offsite which can affect the surrounding community. No administrative controls related to tank level management and no passive mitigation other than the dike was considered in the development of the scenario although the release prevention program is fully implemented for the process.
The alternative release scenario for vinyl acetate involves the release of 4,782 pounds of vinyl acetate in 10 minutes through a .5 inch hole in a 2 inch diameter pi
pe. No passive mitigation is considered but active mitigation through the efforts of our process operators and emergency response team are expected to to control the release within ten minutes although evaporation will continue for approximately one-half hour. This will produce a vapor cloud which will travel offsite but would be expected to have minimal impact on our immediate neighbors.
The worst case scenario for ethylene is the loss of 9,000 pounds of ethylene from our process, forming a flammable vapor cloud which detonates with a ten per cent efficiency. The endpoint of 1 psi overpressure stays predominantly on our property boundary. No administrative or passive mitigation was considered although the release prevention program is fully implemented fo rthe process.
The alternative release scenario for ethylene involves the release of 9000 pounds of ethylene from our process in 15 minutes, producing a flammable vapor cloud which reaches to a distance of approximately 100 feet
. Thus, the flammable range of the cloud stays entirely on our property.
Along with the release prevention elements listed above, the EVOH process is a highly controlled via our computer-based distributed control system. Many process vessels have redundant alarms and interlocks (i.e, temperature as well as pressure, level as well as temperature, etc) General accidental release prevention program and chemical-specific steps
There have been no releases of regulated materials involving offsite impact or employee injury in the preceding five years.
Noltex maintains an emergency response team comprised of 47 employees. The various members receive training in incident command, fire-fighting, hazardous material emergency response, confined space rescue, and medical emergency treatment. Written safety, environmental, process safety management, and emergency response procedures are always available for review by all employees. Noltex is a member of the East HArris County Manufacturers'
Association (EHCMA), La Porte Local Emergency Planning Committee (LPLEPC) and the Channel Industries Mutual Aid (CIMA). Noltex is a supporter of the CAER Line, a public notification system used in emergency and non-emergency situations.
Planned improvements in safety and environmental programs include improved training systems, improved emergency response drill program, automated environmental recordkeeping systems, improved internal auditing programs, improved compliance assurrance programs, and increased employee involvement in safety and emergency response planning.