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Arkema Inc. - Crosby Plant

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Facility #1 : Arkema Inc. - Crosby Plant


Basic Facility Info facility_Basic_Facility_Info help link help link  
Facility ID100000124457
Deregistered (Yes/No)No
Facility NameArkema Inc. - Crosby Plant
Street Address Line 118000 Crosby Eastgate Road
CityCrosby
StateTX
Zip Code77532
CountyHarris County
Owner or Operator NameArkema Inc.
Parent CompanyArkema, Inc.
Latitude29.943722
Longitude-95.022722
Number of RMP Submissions8

Most Recent Submission Info facility_Most_Recent_Submission_Info help link help link  
RMP ID1000040822
Submission Typerevised submission for facility
Submission Date06/11/2014
Reason For Submission5-year update (40 CFR 68.190(b)(1))
Process Toxic Amount Total (lbs)66,260
Process Flammable Amount Total (lbs)85,256
Process Amount Total (lbs)151,516
Number of Potential Offsite Consequence Processes2
Potential Offsite Consequence Toxic Amount Total (lbs)66,260
Potential Offsite Consequence Flammable Amount Total (lbs)85,256
Potential Offsite Consequence Amount Total (lbs)151,516
All Process NAICS325199
Exec Summary Submission Date06/11/2014

Executive Summary facility_Executive_Summary help link help link (Facility #1 : Arkema Inc. - Crosby Plant, executive summary: all)

Executive Summary
INTRODUCTION



The Arkema Inc. (Arkema) - Crosby, Texas manufacturing facility (Crosby facility) has prepared this Risk Management Plan (RMP) to reduce the risk of accidental releases of hazardous materials. This RMP 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 the following:



-Arkema Inc Loss Control Program to Protect Health, Environment, and Safety;

-Facility Identification and Regulated Substances in Covered Processes;

-Hazard Assessment;

-Prevention Program;

-Five-Year Accident History;

-Emergency Response Plan; and

-Planned Changes to Improve Safety.



ARKEMA INC. LOSS CONTROL PROGRAM FOR HEALTH, ENVIRONMENT, AND SAFETY



Arkema 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 areas such as equipment design and installation, plant operating procedures, maintenance, and employee training associated with the processes at the Crosby plant. The RMP formalizes and documents these activities.



The Crosby facility employs practices, programs, and procedures in place for the prevention, mitigation and/or minimization of catastrophic consequences and releases from materials covered under either standard.



The Crosby facility has One primary operating production unit: MPU. In addition, the Wastewater Treatment System (WWTS) at the Crosby plant treats the wastewater from the production unit. The CPU Unit is demolished and the BPU unit is officially idled and decommissioned, however there are several tanks and vessels located in the pre-existing CPU Unit that operate in support of the MPU Processing Unit.



This commitment to Loss Control starts with AIMS, integrated
management systems pertaining to health, environment, and safety (HES). This program starts with the CEO. Senior management routinely dedicates time to review HES matters. This emphasis on safety is carried through to the facility level, where the Plant Manager and the Safety Team regularly review safety performance, take corrective actions, and strive for continuous improvement. The success of Arkema Inc.'s HES programs is also reflected by a strong commitment to safety by employees and contractors.



Arkema's HES programs include policies, procedures, standards, and guidance materials designed to fulfill Arkema's commitment to health, environment and safety. These materials include RMP guidance to help our facilities prevent and/or reduce the risk of accidents.



FACILITY IDENTIFICATION AND REGULATED SUBSTANCES IN COVERED PROCESSES



The Arkema Crosby facility is located at 18000 Crosby-Eastgate Road in Crosby, Texas. The facility manufactures liquid organic peroxides, which are primarily used in the production of plastic resins, polystyrene, polyethylene, polypropylene, PVC, and fiberglass. Certain substances used and produced within the facility are regulated substances under 40 CFR 68, the EPA RMP rule. Two substances, sulfur dioxide (SO2) and 2-methyl Propene (Isobutylene) are present at, or above, the minimum threshold quantity (TQ) for RMP applicability.



The MPU process includes a batch and a continuous process area. Isobutylene and/or SO2 are used to produce and/or process the majority of the products produced in both the MPU batch and continuous process areas. Arkema has included all equipment, lines, vessels, storage tanks, and reactors in Building 30 as part of the PSM and RMP covered processes associated with SO2 and Isobutylene related equipment throughout the continuous process structure and batch process structure. The site evaluated the prevention program for each RMP compound separately.



The storage vessels used for the raw mate
rials Isobutylene and Sulfur Dioxide are 30-T-71 and 17-T-19 respectively. The maximum inventory for Isobutylene is 85,256 lbs. This vessel is a raw material feedstock tank for the MPU batch and continuous processes and stores isobutylene in a pressurized vessel capable of containing the compound. The vessel is equipped with dual rupture disc and pressure relief valves. No further emission control is required for these pressure tanks under EPA BACT requirements. The Sulfur Dioxide feedstock vessel for all processes is located in CPU (17-T-19).



Additional specific equipment in Sulfur Dioxide Service:



EH-14 Evaporator used to vaporize sulfur dioxide that is transferred from 17-T-19 prior to distribution into the MPU Process for active oxygen destruction.



Spent Acid Treatment Tank (T-37) - The acid mother liquor from CF-1, Separated aqueous acid from T-30 or spent acid, is sent to 30-T-37 to be treated. SO2 is fed from 30-T-19 to 30-T-37 through a vaporizer at a controlled rate to destroy any active oxygen. Sulfur Dioxide emissions are routed to a sodium hydroxide scrubber 30-FS-95.



Spent Acid Treatment Tank (T-38)- Waste Acid is transferred from the MPU Continuous unit into T-38 at a controlled rate. Sulfur Dioxide is injected at the bottom of the tank at a rate of ~0.2 lb/min to destroy the Active Oxygen in the Waste Stream. Sulfur Dioxide emissions are routed to a sodium hydroxide scrubber 30-FS-95.



HAZARD ASSESSMENT

WORST-CASE RELEASE MITIGATION MEASURES



Assumptions:



There were five (5) key assumptions considered while assessing worst case release scenarios, and they are as follows:



A) A complete rupture of either the Isobutylene feedstock tank (30-T-71) or the Sulfur Dioxide feedstock tank (17-T-19).

B) All tank active safety systems failed

C) No Plant Emergency actions or systems activated and/or significantly delayed

D) Most favorable meteorological conditions for each worst case scenario and

E) Entire contents of each vessel we
re released during the worst case scenario



Rationale:



It is important to note that the rational and assessment methodology for each scenario has been revised based on the most current operations, reflecting changes made over the past 5 years, previous plant incidents, and amended process hazard assessment methodologies. The topography in all scenarios is based on a rural area verses an urban area to account for the adjacent farmland and lack of development within one mile of the Arkema Crosby facility. There was little change in the potentially affected residential population or distance to endpoint for all scenarios versus the previous RMP submission.



The multiple layers of preventive and mitigation measures in use at the Crosby facility make it very unlikely that either worst-case scenario will occur. In the unlikely event that such a release occurs, Arkema, Inc. has mitigation measures in place to reduce any potential impacts.



- Remote shut-off valves on tank piping designed to shutdown flow from the feedstock storage tanks, thereby reducing the amount potentially released;



- Area monitors that either prompt the control room to activate shutoff of vessel isolation valves and/or actually initiate automatic closing of the isolation valves.



- Excess flow valves on tank process feed lines from the storage vessels or within the process that shut off the flow of material in the case of high discharge pressure or loss of material containment. Thus this reduces the amount of material potentially released:



- Stationary fire monitors which are permanently and strategically placed water cannons with the capability to remove airborne vapor with water sprays or to lay suppressive water deluge from a distance of at least 70 feet from the fire;



-On-site emergency responders 24 hours per day as well as communications links with additional off-site responders and response equipment;



-The First Call Interactive Network enabling the facility to immedia
tely notify the surrounding neighbors.



HAZARD ASSESSMENT

ALTERNATIVE RELEASE SCENARIOS MITIGATION MEASURES



In the Toxic alternate cases, the site has historically used a 1.5, 2.0 or 3.0 inch process line rupture or a 1.5, 2.0 or 3.0 inch hole rupture in the vessel as the alternate case consideration. Current operations dictate that a flange leak or fitting failure demonstrates a more likely alternate case scenario. The site chose to evaluate hose failures for SO2 Unloading or a flange leak on the low-pressure side of the SO2 Feed System, including the Storage Tank and Feed Pump suction piping, and the high-pressure side of the system, including the Feed Pump discharge and the Feed Line. The breach in each case was taken to be one-eighth inch diameter. Low-pressure releases were driven by a 40-psig upstream pressure, and high pressure releases were driven by 65-psig upstream pressure.



In the flammable alternate cases, two potential impacts are associated with a BLEVE: 1) overpressure shockwave, due to the failure of the vessel wall or 2) a sudden release of the vessel contents, and a fireball, due to ignition of the released flammable vapor. The calculated overpressure impact from a BLEVE of the Isobutylene Storage Tank, extending out to the 1 psi overpressure endpoint specified by the RMP Guidance, is 483 feet, falling within the site boundaries. The BLEVE fireball radiation impact, extending out to the 3.42x106 (watts/m2)4/3-sec thermal radiation dose as specified by the RMP guidance, is 1,053 feet, also approaching the yard of the residence nearest to the site. The site chose to submit the case involving the radiation impact from a BLEVE of the Isobutylene Storage as the required flammable alternate case.



While the alternate release scenarios are, by definition, more likely to occur they are subject to the systems within the facility's existing release and accident prevention program. In compliance with regulatory criteria associated with RMP evalu
ations, active mitigation systems cannot be considered in modeling worst-case scenario impacts; however, the significant planning and subsequent implementation that Arkema, Inc. has made in active mitigation measures could effectively reduce the risk associated with an RMP worst-case related incident. Mitigation measures include the following:



- Remote shut-off valves on tank piping designed to shutdown flow from the feedstock storage tanks, thereby reducing the amount potentially released;



- Area monitors that either prompt the control room to activate shutoff or vessel isolation valves and/or actually initiate automatic closing of the isolation valves.



-Remote shut-off valves on tank piping designed to shut down all flow from the storage tanks, thereby reducing the amount potentially released;



-Excess flow valves on tank process feed lines from the storage tanks designed to close in the case of a line failure, thereby reducing the amount potentially released;



-Stationary fire monitors are permanently and strategically placed water cannons with the capability to remove airborne vapor with water sprays or to lay suppressive water deluge from a distance of atleast 70 feet from the fire.



-On-site emergency responders 24 hours per day as well as emergency communications links with additional off-site responders and response equipment;



-The First Call Interactive Network enabling the facility to immediately notify the surrounding neighbors.



THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS



The Arkema Crosby 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 the EPA RMP pursuant to 40 CFR 68 and 29 CFR 1910.119, Process Safety Management (PSM). The accidental release prevention program includes the following elements and activities:



- Quantitative process hazard analyses (PHAs usi
ng LOPA methodology) are completed on covered processes every five (5) years. Qualified PHA leaders are trained in PHA techniques approved under the EPA RMP and OSHA PSM standards.



- Written operating procedures are used for training and directing the work of operators, who receive refresher training every three years.



-Written operating procedures contain in-depth consequences of process deviation analysis.



-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety. This includes Level III training for all operators;



-A Management of Change (MOC) system is in place to ensure that process-operating changes are managed safely;



-Environmental and Safety Critical equipment is inspected on a planned, periodic basis to ensure proper operating conditions;



-Pre-start-up safety reviews are performed to satisfy conditions for safe operation prior to starting new or modified equipment or processes;



-Incidents are investigated and actions taken as part of a continuous improvement effort;



-Routine audits are conducted to evaluate that safe practices are being followed;



-Storage tanks and associated equipment are designed and constructed in accordance with industry codes, standards (American Society of Mechanical Engineers - ASME), and practices;



-As part of the facility's Mechanical Integrity program, pressure vessels and transfer lines are inspected and tested according to the American Petroleum Institute (API) certified inspectors using API standards;



-All plant process components are inspected and monitored on a regularly scheduled basis as part of the leak detection and repair program (LDAR);



-The risk of over pressure of pressurized storage tanks is addressed by monitoring the tank temperature and pressure controllers;



- Covered storage vessels are equipped with rupture discs and pressure relief valves;



-The risk of over
filling of vessels is addressed by the use of process interlocks, high level alarms monitored by trained operators who monitor tank level indicators and metering devices;



-The risks of unloading releases are minimized by the use of: a) vapor balancing systems b) interlocks and c) remote shutoff devices when unloading chemicals into storage tanks;



-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;



-A safety work permitting system is used to ensure routine and non-routine work is carried out after proper task identification, hazard assessment and implementation of safe work practices has taken place;



-Hazardous material delivery drivers are escorted into the plant. Access to all plant unloading lines is controlled via a key and lock system in the QC Laboratory to prevent inadvertent material transfers. Logistic personnel remain present during the entirety of the loading and unloading process.



This systematic approach to process safety involves all 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 accidents.



FIVE YEAR ACCIDENT HISTORY



There have been no accidental off-site releases of applicable RMP chemicals from our facility in the previous five years.



EMERGENCY RESPONSE STATEMENT



The Arkema Crosby facility maintains a written Emergency Response Plan. The plan includes procedures for notifying civil authorities and the public in the event of an incident; 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; descriptions of the training programs for all e
mployees in the relevant emergency response procedures; and the review and update of our response plan to reflect changes at the facility and to ensure that employees are informed of these changes. The appendix of the plan contains a listing of critical environmental, and critical safety equipment. The facility also conducts emergency drills on a regular basis.



PLANNED CHANGES FOR HEALTH, ENVIRONMENT, AND SAFETY



The facility has incorporated the environmental, safety, health, and quality into an integrated ""loss control"" management system at the Crosby facility. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts, employee involvement and participation, and hazard evaluation and assessment. Arkema's Integrated Management Systems (AIMS) provides the framework for the site comprehensive health, environmental, and safety program. OHSAS 18001 requirements have been incorporated into the integrated management system.





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. The most recent approved NSR Air Permit Compliance period began on December 9,2011. The Crosby facility current Title V permit, operating permit number O-01554 was issued on August 28, 2011 and is currently reviewed and inspected by the TCEQ on a frequent basis.
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees53
Owner or Operator NameArkema Inc.
Owner or Operator Address Line 118000 Crosby Eastgate Road
Owner or Operator CityCrosby
Owner or Operator StateTX
Owner or Operator Zip77532
Parent Dun and Bradstreet Number622121697
Second Parent Dun and Bradstreet Number0
Number of Full Time Employees53
Number of FTE CBI FlagNo
Covered by OSHA PSM StandardYes
Covered by EPCRA Section 302Yes
Covered by CAA Title VYes
CAA Title V Air Operating Permit IDO-01554
Last Safety Inspection Date20140212
Last Safety Inspection ByState environmental agency
OSHA Star or Merit RankingNo
LEPC NameNorth Channel LEPC

Submission - Contact Info facility_Submission_-_Contact_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611)
Owner or Operator Phone2813283561
Facility URLhttp://www.arkema.com
Facility Phone2813289422
Facility Dun and Bradstreet Number0
RMP ContactLeslie J. Comardelle, Jr.
RMP Contact TitlePlant Manager
RMP Contact EmailLeslie.comardelle-jr@arkema.com

Submission - Additional Info facility_Submission_-_Additional_Info help link help link  
RMP Complete FlagYes
Predictive FilingNo
No RMP Accidents Last 5 YearsYes
Complete Check Date20180402
Error Report Datenull
Postmark Date20140611
Anniversary Date20190611
Confidential Business InformationNo

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611)
Latitude29.943722
Longitude-95.022722
Valid Lat/LongYes
Lat/Long MethodInterpolation - Satellite
Lat/Long Location TypeStorage Tank
FRS Latitude29.9497
FRS Longitude-95.0182
FRS Lat/Long DescriptionFACILITY CENTROID
FRS Lat/Long MethodINTERPOLATION-MAP

Submission - Counts and Totals facility_Submission_-_Counts_and_Totals help link help link  
Number of RMP Accidents0
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Number of RMP Accidents0
Number of Processes2
Number of Process Chemicals0
Number of Toxic Worst-case Scenarios1
Number of Toxic Alternate Case Scenarios1
Number of Flammable Worst-case Scenarios1
Number of Flammable Alternate Case Scenarios1
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Total RMP Accident Deaths0
Total RMP Accident Injuries0
Total RMP Accident Evacuated/Sheltering In Place0
Total RMP Accident Property Damage$0

Processes facility_Processes help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611, process #1 : MPU Unit)
Process DescriptionMPU Unit
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)66,260
Flammable Amount Total (lbs)0
Process Amount Total (lbs)66,260
Number of Process Chemicals0
Number of Toxic Worst-Case Scenarios1
Number of Toxic Alternate Scenarios1
Number of Flammable Worst-Case Scenarios0
Number of Flammable Alternate Scenarios0

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDSulfur dioxide (anhydrous)
CAS number007446095
Chemical TypeToxic
Process Chemical Amount (lbs)66,260
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611, process #1 : MPU Unit, process chemical #2)
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Worst-Case Toxic Scenarios facility_Worst-Case_Toxic_Scenarios help link help link  
Percent Weight (Within Mixture)100
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
Release Duration (minutes)10
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
TopographyRural
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Confidential Business InformationNo

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611, process #1 : MPU Unit, process chemical #2, alternate toxic scenario #1)
Percent Weight (Within Mixture)100
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
Wind Speed3
Atmospheric Stability ClassD
TopographyRural
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsNo
Active Mitigation - Water CurtainNo
Active Mitigation - NeutralizationNo
Active Mitigation - Excess Flow ValvesYes
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownYes
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611, process #1 : MPU Unit, process NAICS code #1 : 325199)
NAICS Code325199: All Other Basic Organic Chemical Manufacturing

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date20131031
PHA Update Date20131031
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistYes
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Technique - OtherLayers of Protection Analysis (LOPA)
PHA Change Completion Date20151030
Hazard Identified - Toxic ReleaseYes
Hazard Identified - FireYes
Hazard Identified - ExplosionYes
Hazard Identified - Runaway ReactionYes
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureYes
Hazard Identified - CorrosionNo
Hazard Identified - OverfillingYes
Hazard Identified - ContaminationYes
Hazard Identified - Equipment FailureYes
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeNo
Hazard Identified - FloodYes
Hazard Identified - TornadoNo
Hazard Identified - HurricaneYes
Hazard Identified - OtherPower Failure or Power Surge
Process Controls - VentsYes
Process Controls - Relief ValvesYes
Process Controls - Check ValvesYes
Process Controls - ScrubbersYes
Process Controls - FlaresNo
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksYes
Process Controls - AlarmsYes
Process Controls - Keyed BypassNo
Process Controls - Emergency AirYes
Process Controls - Emergency PowerYes
Process Controls - Backup PumpNo
Process Controls - GroundingYes
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksYes
Process Controls - Excess Flow DevicesYes
Process Controls - Quench SystemYes
Process Controls - Purge SystemYes
Process Controls - NoneNo
Process Controls - OtherUPS or Back-up Power Sources
Mitigation Systems - SprinklersYes
Mitigation Systems - DikesYes
Mitigation Systems - Fire WallsNo
Mitigation Systems - Blast WallsNo
Mitigation Systems - Deluge SystemsYes
Mitigation Systems - Water CurtainsNo
Mitigation Systems - EnclosureNo
Mitigation Systems - NeutralizationNo
Mitigation Systems - NoneNo
Mitigation Systems - OtherFire Monitors
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Monitoring Systems - OtherSO2 Area Monitors
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryNo
Changes Since PHA - Process ParametersYes
Changes Since PHA - Process ControlsYes
Changes Since PHA - Process DetectionYes
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Procedure Review Date20131112
Training Review Date20140131
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - Otherweb-based training (WBT) module
Competency Testing - Written TestsYes
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date20130927
Maintenance Inspection Date20140514
Equipment TestedFire Pumps and Generators
Management of Change Most Recent Date20140512
Management of Change Review Date20140131
Pre-startup Review Date20140506
Compliance Audit Date20121108
Compliance Audit Change Completion Date20141219
Incident Investigation Date20140523
Incident Invest. Change Completion Date20140930
Participation Plan Review Date20140402
Hot Work Review Date20140506
Contractor Safety Review Date20140212
Contractor Safety Eval. Date20140211
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611, process #1 : MPU Unit, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
1000060874

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
- Quantitative process hazard analyses (PHAs using LOPA methodology) Are completed on covered processes every five (5) years. Qualified PHA leaders are trained in PHA techniques approved under the OSHA PSM and EPA Risk Management standards.



- Written operating procedures are used for training and directing the work of operators, who receive refresher training every three years.



-Written operating procedures contain in-depth consequences of process deviation analysis.



-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety. This includes Level III training for all operators;



-A Management of Change (MOC) system is in place to ensure that process-operating changes are managed safely;



-Environmental and Safety Critical equipment is inspected on a planned, periodic basis to ensure proper operating conditions;



-Pre-start-up safety reviews are performed to satisfy conditions for safe operation prior to starting new or modified equipment or processes;



-Incidents are investigated and actions taken as part of a continuous improvement effort;



-Routine audits are conducted to evaluate that safe practices are being followed;



-Storage tanks and associated equipment are designed and constructed in accordance with industry codes, standards (American Society of Mechanical Engineers - ASME), and practices;



-As part of the facility's Mechanical Integrity program, pressure vessels and transfer lines are inspected and tested according to the American Petroleum Institute (API) certified inspectors using API standards;



-All plant process components are inspected and monitored on a regularly scheduled basis as part of the leak detection and repair program (LDAR);



-The risk of over pressure of pressurized storage tanks is addressed by monitoring the tank temperature and pressure controllers;



- Covered storage vessels are sized with rupture discs and pressure relief valves;



-The risk of over filling of vessels is addressed by the use of process interlocks, high level alarms monitored by trained operators who monitor tank level indicators and metering devices;



-The risks of unloading releases are minimized by the use of: a) vapor balancing systems b) interlocks and c) remote shutoff devices when unloading chemicals into storage tanks;



-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;



-A safety work permitting system is used to ensure routine and non-routine work is carried out after proper task identification, hazard assessment and implementation of safe work practices has taken place;



-Hazardous material delivery drivers are escorted into the plant. Access to all plant unloading lines is controlled via a key and lock system in the QC Laboratory to prevent inadvertent material transfers. Logistic personnel remain present during the entirety of the loading and unloading process.

Processes facility_Processes help link help link  
Process DescriptionMPU Unit
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)85,256
Process Amount Total (lbs)85,256
Number of Process Chemicals0
Number of Toxic Worst-Case Scenarios0
Number of Toxic Alternate Scenarios0
Number of Flammable Worst-Case Scenarios1
Number of Flammable Alternate Scenarios1

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611, process #2 : MPU Unit, process chemical #1)
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)85,256
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Worst-Case Flammable Scenarios facility_Worst-Case_Flammable_Scenarios help link help link  
Model UsedEPA's RMP*Comp(TM)
Passive Mitigation - Blast WallsNo
Confidential Business InformationNo

Alternate Case Flammable Scenarios facility_Alternate_Case_Flammable_Scenarios help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611, process #2 : MPU Unit, process chemical #2, alternate flammable scenario #1)
Model UsedEPA's RMP*Comp(TM)
Passive Mitigation - DikesYes
Passive Mitigation - Fire WallsNo
Passive Mitigation - Blast WallsNo
Passive Mitigation - EnclosuresNo
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsNo
Active Mitigation - Water CurtainNo
Active Mitigation - Excess Flow ValvesYes
Active Mitigation - OtherAutomatic Shutoff Systems
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link  
NAICS Code325199: All Other Basic Organic Chemical Manufacturing

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date20131031
PHA Update Date20131031
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistYes
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Technique - OtherLayers of Protection Analysis (LOPA)
PHA Change Completion Date20151030
Hazard Identified - Toxic ReleaseYes
Hazard Identified - FireYes
Hazard Identified - ExplosionYes
Hazard Identified - Runaway ReactionYes
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureYes
Hazard Identified - CorrosionYes
Hazard Identified - OverfillingYes
Hazard Identified - ContaminationYes
Hazard Identified - Equipment FailureYes
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeNo
Hazard Identified - FloodYes
Hazard Identified - TornadoNo
Hazard Identified - HurricaneYes
Hazard Identified - OtherPower Failure or Power Sure
Process Controls - VentsYes
Process Controls - Relief ValvesYes
Process Controls - Check ValvesYes
Process Controls - ScrubbersYes
Process Controls - FlaresNo
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksYes
Process Controls - AlarmsYes
Process Controls - Keyed BypassNo
Process Controls - Emergency AirYes
Process Controls - Emergency PowerYes
Process Controls - Backup PumpNo
Process Controls - GroundingYes
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksNo
Process Controls - Excess Flow DevicesYes
Process Controls - Quench SystemYes
Process Controls - Purge SystemYes
Process Controls - NoneNo
Process Controls - OtherUPS or Back-up Power Sources
Mitigation Systems - SprinklersYes
Mitigation Systems - DikesYes
Mitigation Systems - Fire WallsNo
Mitigation Systems - Blast WallsNo
Mitigation Systems - Deluge SystemsYes
Mitigation Systems - Water CurtainsNo
Mitigation Systems - EnclosureNo
Mitigation Systems - NeutralizationNo
Mitigation Systems - NoneNo
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Monitoring Systems - OtherFour (4) LEL Detectors
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryNo
Changes Since PHA - Process ParametersYes
Changes Since PHA - Process ControlsYes
Changes Since PHA - Process DetectionYes
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Procedure Review Date20131112
Training Review Date20140131
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - Otherweb-based training (WBT) module
Competency Testing - Written TestsYes
Competency Testing - Oral TestsYes
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date20130927
Maintenance Inspection Date20140514
Equipment TestedFire Pumps and Generators
Management of Change Most Recent Date20140512
Management of Change Review Date20140131
Pre-startup Review Date20140506
Compliance Audit Date20131108
Compliance Audit Change Completion Date20141219
Incident Investigation Date20140523
Incident Invest. Change Completion Date20140930
Participation Plan Review Date20140402
Hot Work Review Date20140506
Contractor Safety Review Date20140212
Contractor Safety Eval. Date20140211
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611, process #2 : MPU Unit, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
1000060875

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
This process covers the MPU production unit only. All of Arkema Inc., Crosby Facility's prevention program elements, in accordance with 29CFR1910.119 for Process Safety Management and the EPA Risk Management Program pursuant to 40CFR68, apply to this production unit.

Emergency Response Plan Info facility_Emergency_Response_Plan_Info help link help link  
Facility In Community PlanNo
Facility Own Response PlanYes
Specific Facility Response PlanYes
Inform. Procedures in Response PlanYes
Emergency Care in Response PlanYes
Plan Review Date20130920
Response Training Date20140429
Local Response AgencyCrosby Volunteer Fire Department
Local Response Agency Phone2813284512
Subject To - OSHA EAPYes
Subject To - OSHA HAZWOPERYes
Subject To - CWAYes
Subject To - RCRAYes
Subject To - OPANo
Subject To - State EPCRAYes
Subject To - OtherDOT Regulations 49CFR171-180, Clean Air Act, 30 TAC Chapters 101,106,115,116,117,122,324,327 (TCEQ)


Search Criteria Used
RMP Facility ID100000124457

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