Rohm and Haas Lone Star Plant - Executive Summary |
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Rohm and Haas Lone Star Risk Management Plan Executive Summary 1800 Tidal Road Deer Park, TX 77536 (713) 767-1600 Contact Person: Kevin Winston @ (713)767-1602. Table of Contents I. EPA 40 CFR Part 68, Subpart G-RMP A. 68.155 Executive Summary 1. Paragraph (a) 2. Paragraph (b) 3. Paragraph (c) 4. Paragraph (d) 5. Paragraph (e) 6. Paragraph (f) 7. Paragraph (g) Paragraph (a) The accidental release prevention and emergency response policies at our Vinyl Acetate source instruct in detail what employees should do to prevent and assure that risk of emergencies do not transpire. In the plant VA offloading procedure there are several specific instructions which include the required maximum tank level in which more material can be added to the tank, a step that instructs one to ground all vessels being transferred to and from, continuous monitoring of the VA vessels during transfer, and safe detachments from the VA vessels take place with the help of dripless fittings. The emergency response policies are all located in Plant Emergency Response Plan. All emergency response instructions are written to insure that mitigation efforts are carried out in the safest and most environmental friendly steps. The following is an example of our vapor release procedure: EMERGENCY RESPONSE ACTION PLAN FOR VAPOR RELEASE IF YOU DISCOVER A VAPOR RELEASE: 7 Notify Group Leader. 7 Immediately check %LEL with combination O2/combustible gas meter. 7 Group Leader will notify Rohm & Haas Texas Safety Dispatch for informational purposes only or to respond. 7 If Safety Dispatch is requested to respond, Group Leader or designee will sound the Emergency Evacuation Alarm. 7 Group Leader or designee will notify Rohm & Haas Texas Safety Dispatch with the following information: Location of Emergency at Lone Star Type and extent of Emergency Injuries, if any, and type Your name and location Wind Direction Recommended avenue of approach for emergency responders A request to notify downwind personnel as needed What is being done to control the situation DO NOT HANG UP until the Dispatcher tells you to. 7 Follow the Group Leader's instructions. IF RELEASE IS LOCATED IN PROCESS BUILDING AND CONDITIONS PERMIT: 7 Secure operations on Provox. Follow the shutdown procedure. 7 Close elevator door if on 3rd floor. 7 Listen for Group Leader to announce location of vapor release. 7 Follow the Group Leaders instructions. 7 NOTE: It may be necessary to shutdown the office/warehouse HVAC system and shelter-in-place. IF RELEASE IS NOT LOCATED IN PROCESS BUILDING: 7 Contact Group Leader for operations shutdown authorization. 7 Secure operations on Provox if requested. Follow shutdown procedure if requested. 7 Follow the Group Leaders instructions. DO NOT USE ELEVATOR!!! Paragraph (b) The stationary source is a 22,000 gallon Vinyl Acetate Tank and the regulated substance is Vinyl Acetate. Paragraph (c) The worst case scenario is a storage tank failure. The alternative release scenarios are flange leaks on the discharge side of the transfer pump, transfer hose rupture, and a runaway reaction of Vinyl Acetate. See paragraph (a) example of administrative controls and mitigation procedures. Paragraph (d) The Plant general accidental release prevention program is the same as what is dialogued in paragraph (a). Chemical-specific prevention steps are included in the VA offloading procedure. Paragraph (e) No Vinyl Acetate releases have occurred at the Lone Star Plant that had an adverse impact on the community. Paragraph (f) The plant emergency response program is detailed in The Lone Star Plant Emergency Response Manual. This manual covers everything from mitigation efforts to notification requirements to local an d federal agencies respectively. Paragraph (g) Fervent efforts to improve safety occur throughout each year because of company corporate environmental, health, and safety audits that must transpire each quarter of the year, and PSM audits every three years. Findings from these audits create action items that improve safety across the plant. |