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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
County FIPS Code48201
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

Submission Info facility_Submission_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #1 : 20140611)
RMP ID1000040822
Submission Typerevised submission for facility
Receipt Date20140611
Reason For Submission5-year update (40 CFR 68.190(b)(1))
Deregistration Datenull
Deregistration Effective Datenull
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

Submission - Basic Facility Info facility_Submission_-_Basic_Facility_Info help link help link  
Facility NameArkema Inc. - Crosby Plant
Street Address Line 118000 Crosby Eastgate Road
CityCrosby
StateTX
Zip Code77532
County FIPS Code48201
CountyHarris County
Parent CompanyArkema, Inc.

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
Graphics IndicatorNo
Attachment IndicatorYes
Certification Received FlagYes
Submission MethodRMP*eSubmit
CBI Substantiation FlagNo
Electronic Waiver FlagNo
Postmark Date20140611
Anniversary Date20190611
Confidential Business InformationNo
Unsanitized Version ProvidedNo
Software Version Number3.10.1

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
Lat/Long Horizontal Accuracy25
Lat/Long Horizontal Reference2
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 ID1000050290
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 Record ID1000060874
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 Record ID1000560874
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  
Toxic Scenario ID1000041041
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)
Toxic Scenario ID1000043430
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)
Process NAICS ID1000050753
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Prevention Program ID1000043000
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 ID1000050291
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 Record ID1000060875
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 Record ID1000560875
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  
Flammable Scenario ID1000030809
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)
Flammable Scenario ID1000028930
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  
Process NAICS ID1000050754
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 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)
Prevention Program ID1000043001
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)

Submission Info facility_Submission_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #2 : 20090622)
RMP ID54835
Submission Typerevised submission for facility
Receipt Date20090622
Reason For Submission5-year update (40 CFR 68.190(b)(1))
Deregistration Datenull
Deregistration Effective Datenull
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

Submission - Basic Facility Info facility_Submission_-_Basic_Facility_Info help link help link  
Facility NameArkema Inc. - Crosby Plant
Street Address Line 118000 Crosby Eastgate Road
CityCrosby
StateTX
Zip Code77532
County FIPS Code48201
CountyHarris County
Parent CompanyArkema, Inc.

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 two primary operating production units: BPU and MPU. In addition, the Wastewater Treatment System (WWTS) at the Crosby plant treats the wastewater from the production units. 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 Units.

This commitment to Loss Control starts with AIMS which the integr
ated 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 materials Is
obutylene 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 to 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 worse 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 worse case scenario and
E) Entire contents of each vessel were released during the
worse 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 decade, previous plant incidents, and amended process hazard assessment methodologies. The `topography? in all scenarios now 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. This change is visible and evidenced by the change in the potentially affected residential population and distance to endpoint in the toxic worse case scenario. The previous RMP yielded a potentially affected residential population of 21,686 and a distance to end point of 7.3 miles for the Toxic Worse Case scenario. Based on the most current and revised review, the potentially affected residential population for the toxic worse case scenario is 1,121,757 and 23 miles for the distance to endpoint. There was little change in the potentially affected residential population or distance to endpoint for all other scenarios.

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 or 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:

- Stati
onary 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 atleast 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 immediately 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 size 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?s 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 yar
d 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 evaluations, 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 A
rkema 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 using 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 standard
s;

-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.

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.

On June 20,2006 a major fire occurred in a product storage building. This incident
involved the combustion of Arkema products, some of which were manufactured with Isobutylene and/or SO2. The consequences of the fire included major equipment and building damage. The incident yielded major business and product losses. A detailed incident investigation was conducted. There were no off-site RMP regulatory consequences concerning covered chemical associated with this incident. An official memorandum documenting this review was filed in the Crosby Environmental Files documenting this internal review.

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 employees 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 use of the term ?Loss Control? to refer environmental, safety, health, and quality and loss control 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. In 2008 the site revised and amended its comprehensive health, environmental, and safety program under Arkema?s Integrated Management systems (AIMS).


CERTIFICATION

I certify to the best of my knowledge, the information, and belief formed after re
asonable inquiry that the information submitted is true, accurate, and complete. The most recent approved NSR Air Permit Compliance period began on August 21,2006. The Crosby facility submitted its original Title V permit application to the EPA on May 18, 2000 and has been assigned an operating permit number O-01554 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 Date20070501
Last Safety Inspection ByOSHA
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 #2 : 20090622)
Owner or Operator Phone2813283561
Facility URLhttp://www.arkema.com
Facility Phone2813289422
Facility Dun and Bradstreet Number0
RMP ContactWendal Turley
RMP Contact TitlePlant Manager
RMP Contact Emailwendal.turley@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 Date20120822
Error Report Datenull
Graphics IndicatorNo
Attachment IndicatorYes
Certification Received FlagYes
Submission MethodRMP*eSubmit
CBI Substantiation FlagNo
Electronic Waiver FlagNo
Postmark Date20090618
Anniversary Date20140618
Confidential Business InformationNo
Unsanitized Version ProvidedNo
Software Version Number3.10.1

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #2 : 20090622)
Latitude29.943722
Longitude-95.022722
Valid Lat/LongYes
Lat/Long MethodInterpolation - Photo
Lat/Long Location TypeAdministrative Building
Lat/Long Horizontal Accuracy25
Lat/Long Horizontal Reference2
Lat/Long Source Map Scale24000
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 Chemicals2
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 #2 : 20090622, process #1 : MPU Unit)
Process ID79986
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 Chemicals1
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 Record ID106736
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 #2 : 20090622, process #1 : MPU Unit, process chemical #2)
Process Chemical Record ID606736
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  
Toxic Scenario ID52094
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
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 #2 : 20090622, process #1 : MPU Unit, process chemical #2, alternate toxic scenario #1)
Toxic Scenario ID61457
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
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 #2 : 20090622, process #1 : MPU Unit, process NAICS code #1 : 325199)
Process NAICS ID81939
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Prevention Program ID47205
Safety Info Review Date20081031
PHA Update Date20081031
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 Date20091031
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 MonitoringYes
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Procedure Review Date20090531
Training Review Date20090131
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 Date20081231
Maintenance Inspection Date20090612
Equipment TestedSO2 storage tank rupture discs & pressure relief valves
Management of Change Most Recent Date20090603
Management of Change Review Date20091205
Pre-startup Review Date20090529
Compliance Audit Date20090326
Compliance Audit Change Completion Date20091231
Incident Investigation Date20080801
Incident Invest. Change Completion Date20090301
Participation Plan Review Date20081002
Hot Work Review Date20080625
Contractor Safety Review Date20090612
Contractor Safety Eval. Date20090501
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #2 : 20090622, process #1 : MPU Unit, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
106736

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 ID79987
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 Chemicals1
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 #2 : 20090622, process #2 : MPU Unit, process chemical #1)
Process Chemical Record ID106737
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 Record ID606737
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  
Flammable Scenario ID13774
Model UsedEPA's OCA Guidance Reference Tables or Equations
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 #2 : 20090622, process #2 : MPU Unit, process chemical #2, alternate flammable scenario #1)
Flammable Scenario ID10403
Model UsedEPA's OCA Guidance Reference Tables or Equations
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  
Process NAICS ID81940
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #2 : 20090622, process #2 : MPU Unit, process NAICS code #1 : 325199, prev. program 3 #1)
Prevention Program ID47206
Safety Info Review Date20081031
PHA Update Date20081031
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 Date20091031
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 Date20090514
Training Review Date20090131
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 Date20081204
Maintenance Inspection Date20090131
Equipment TestedLEL Detectors/Monitors (January 09)
Management of Change Most Recent Date20090228
Management of Change Review Date20090603
Pre-startup Review Date20090128
Compliance Audit Date20090326
Compliance Audit Change Completion Date20091231
Incident Investigation Date20090321
Incident Invest. Change Completion Date20090521
Participation Plan Review Date20081002
Hot Work Review Date20080625
Contractor Safety Review Date20090612
Contractor Safety Eval. Date20090501
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #2 : 20090622, process #2 : MPU Unit, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
106737

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 ATOFINA Chemicals, 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 Date20081231
Response Training Date20080731
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)

Submission Info facility_Submission_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #3 : 20081007)
RMP ID52732
Submission Typerevised submission for facility
Receipt Date20081007
Reason For Submission5-year update (40 CFR 68.190(b)(1))
Deregistration Datenull
Deregistration Effective Datenull
Process Toxic Amount Total (lbs)56,000
Process Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)138,000
Number of Potential Offsite Consequence Processes2
Potential Offsite Consequence Toxic Amount Total (lbs)56,000
Potential Offsite Consequence Flammable Amount Total (lbs)82,000
Potential Offsite Consequence Amount Total (lbs)138,000

Submission - Basic Facility Info facility_Submission_-_Basic_Facility_Info help link help link  
Facility NameATOFINA Chemicals, Inc. - Crosby Plant
Street Address Line 118000 Crosby Eastgate Road
CityCrosby
StateTX
Zip Code77532
County FIPS Code48201
CountyHarris County
Parent CompanyATOFINA Delaware, Inc.

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

Executive Summary
INTRODUCTION

A Risk Management Program has been implemented at ATOFINA Chemicals, Inc.'s Crosby, Texas production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan 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:

-Introduction;
-ATOFINA Chemicals, Inc.'s Policies 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.

ATOFINA CHEMICALS, INC. POLICIES FOR HEALTH, ENVIRONMENT, AND SAFETY

ATOFINA Chemicals, Inc. 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 Risk Management Plan formalizes and documents these activities.

This commitment to health, environment, and safety (HES) 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 ATOFINA Chemicals, Inc.'s HES programs is also reflected by a strong commitment to safety by employees and contractors.

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

FACILITY IDENTIFICATION AND REGULATED SUBSTANCES IN COVERED PROCESSES

The ATOFINA Chemicals, Inc. 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 40CFR68, the EPA Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability and for the Crosby plant include Sulfur Dioxide (SO2) and 2-Methyl Propene (Isobutylene).

HAZARD ASSESSMENT
WORST-CASE RELEASE MITIGATION MEASURES

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

In compliance with regulatory criteria associated with RMP evaluations, active mitigation systems cannot be considered in modeling worst-case scenario impacts; however, the significant planning and subsequent implementation that ATOFINA Chemicals, Inc. has made in active mitigation measures could effectively reduce the risk associated with an RMP worst-case related incident. Mitigation measures include:

-Stationary fire monitors that could remove airborne vapors with water sprays;

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

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

HAZARD ASSESSMENT
ALTERNATIVE RELEASE SCENARIOS MITIGATION MEASURES

While the Alterna
tive 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, ATOFINA Chemicals, Inc. has mitigation measures to reduce potential human health and environmental receptor impact. The prevention program elements in place at Crosby are:

-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 that could remove airborne vapor with water sprays;

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

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

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

The ATOFINA Chemicals, Inc. 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 29CFR1910.119, Process Safety Management and the EPA Risk Management Program pursuant to 40CFR68. The accidental release prevention program includes the following elements and activities:

-In-depth hazard analyses are completed every five years by qualified personnel using techniques approved under the OSHA PSM standard of 29CFR1910.119;

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

-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting
safety;

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

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

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

-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;

-The risk of over pressure of pressurized storage tanks is addressed by monitoring the tank temperature and pressure controllers or by a system of relief valves;

-The risk of over filling of vessels is addressed by the use of trained operators who monitor tank level indicators and metering devices;

-The risk of unloading releases are addressed by using a vapor recovery system 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 sabbotage;

-A safety permitting system is used to ensure routine and non-routine work is carried out after identification and implementation of safe work practices; and

-Hazardous material delivery drivers are escorted into the plant and for the duration of the unloading by plant logistics personnel and access to all plant unloading lines is controlled vi
a a key and lock system in the QC Laboratory to prevent inadvertant material transfers.

This systematic approach to process safety involves all the 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 ATOFINA Chemicals, Inc. 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 employees 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 facility also conducts emergency drills on a regular basis.


PLANNED CHANGES FOR HEALTH, ENVIRONMENT, AND SAFETY

Safety has been a part of the culture at the Crosby facility for many years. An example of Crosby's dedication to safety is that in March of 2004, the facility acheived 21 years without a plant employee lost time incident. Recently in May of 2004, the facility celebrated the completion of one year without an employee OSHA Recordable injury. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. The Crosby facility continues to implement methods to reduce risk, as demonstrated by the installation of remote access
controls for these tank systems.


CERTIFICATION

I ceritify to the best of my knowledge, the information, and belief formed after reasonable inquiry, that the information submitted is true, accurate, and complete. The Crosby facility submitted its Title V permit application to the EPA on May 18, 2000 and has been assigned an operating permit number O-01554, which is currently being reviewed by TCEQ.
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees53
Owner or Operator NameATOFINA Chemicals, 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 Employees90
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 Date19770824
Last Safety Inspection ByOSHA
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 #3 : 20081007)
Owner or Operator Phone2813283561
Facility Phone2813283561
Facility Dun and Bradstreet Number0
RMP ContactRandy Nycz
RMP Contact TitlePlant Manager
RMP Contact Emailrandy.nycz@atofina.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 Date20081017
Error Report Datenull
Graphics IndicatorNo
Attachment IndicatorYes
Certification Received FlagYes
Submission MethodRMP*Submit
CBI Substantiation FlagNo
Electronic Waiver FlagNo
Postmark Date20081002
Anniversary Date20131002
Confidential Business InformationNo
Unsanitized Version ProvidedNo
Software Version Number3.8

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #3 : 20081007)
Latitude29.943722
Longitude-95.022722
Valid Lat/LongYes
Lat/Long MethodInterpolation - Photo
Lat/Long Location TypeAdministrative Building
Lat/Long Horizontal Accuracy25
Lat/Long Horizontal Reference2
Lat/Long Source Map Scale24000
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 Chemicals2
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 #3 : 20081007, process #1 : CPU and MPU Units)
Process ID76860
Process DescriptionCPU and MPU Units
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)56,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)56,000
Number of Process Chemicals1
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 Record ID101924
Process Chemical IDSulfur dioxide (anhydrous)
CAS number007446095
Chemical TypeToxic
Process Chemical Amount (lbs)56,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #3 : 20081007, process #1 : CPU and MPU Units, process chemical #2)
Process Chemical Record ID601924
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  
Toxic Scenario ID50121
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
Release Duration (minutes)10
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
TopographyUrban
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 #3 : 20081007, process #1 : CPU and MPU Units, process chemical #2, alternate toxic scenario #1)
Toxic Scenario ID59175
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
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 #3 : 20081007, process #1 : CPU and MPU Units, process NAICS code #1 : 325199)
Process NAICS ID78709
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Prevention Program ID45292
Safety Info Review Date20040331
PHA Update Date20020328
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20030410
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
Changes Since PHA - Reduced InventoryYes
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 Date20040331
Training Review Date20031114
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 Date20021120
Maintenance Inspection Date20030612
Equipment TestedRemote actuated valves
Management of Change Most Recent Date20031030
Management of Change Review Date20040429
Pre-startup Review Date20031030
Compliance Audit Date20031117
Compliance Audit Change Completion Date20041231
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20031230
Hot Work Review Date20031230
Contractor Safety Review Date20030815
Contractor Safety Eval. Date20030825
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #3 : 20081007, process #1 : CPU and MPU Units, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
101924

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
This process includes two production units, the Continuous Perester Unit (CPU) and the Multi-Purpose Unit (MPU). All elements of ATOFINA Chemicals, Inc. Crosby Facility's prevention program, in accordance with 29CFR1910.119 for Process Safety Management and the EPA Risk Management Program pursuant to 40 CFR 68, apply to both units with the following exception: the date of the last PHA for CPU is 03/28/2002 and for MPU is 12/08/2003. The CPU is currently idle.

Processes facility_Processes help link help link  
Process ID76861
Process DescriptionMPU
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)82,000
Number of Process Chemicals1
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 #3 : 20081007, process #2 : MPU, process chemical #1)
Process Chemical Record ID101925
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)82,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical Record ID601925
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  
Flammable Scenario ID13201
Model UsedEPA's OCA Guidance Reference Tables or Equations
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 #3 : 20081007, process #2 : MPU, process chemical #2, alternate flammable scenario #1)
Flammable Scenario ID9931
Model UsedEPA's OCA Guidance Reference Tables or Equations
Passive Mitigation - DikesNo
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  
Process NAICS ID78710
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #3 : 20081007, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1)
Prevention Program ID45293
Safety Info Review Date20031208
PHA Update Date20031208
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistYes
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20041231
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
Mitigation Systems - SprinklersYes
Mitigation Systems - DikesNo
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
Changes Since PHA - Reduced InventoryYes
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 Date20040331
Training Review Date20031114
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 Date20021120
Maintenance Inspection Date20040308
Equipment TestedPumps
Management of Change Most Recent Date20040401
Management of Change Review Date20040429
Pre-startup Review Date20040401
Compliance Audit Date20031117
Compliance Audit Change Completion Date20041231
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20031230
Hot Work Review Date20031230
Contractor Safety Review Date20030815
Contractor Safety Eval. Date20030825
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #3 : 20081007, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
101925

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 ATOFINA Chemicals, 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 Date20030814
Response Training Date20031103
Local Response AgencyCrosby Volunteer Fire Department
Local Response Agency Phone2813281000
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, CAA

Submission Info facility_Submission_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #4 : 20060621)
RMP ID45947
Submission Typecorrection for prior submission
Receipt Date20060621
Reason For SubmissionChange in emergency contact information
Deregistration Datenull
Deregistration Effective Datenull
Process Toxic Amount Total (lbs)50,000
Process Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)132,000
Number of Potential Offsite Consequence Processes2
Potential Offsite Consequence Toxic Amount Total (lbs)50,000
Potential Offsite Consequence Flammable Amount Total (lbs)82,000
Potential Offsite Consequence Amount Total (lbs)132,000

Submission - Basic Facility Info facility_Submission_-_Basic_Facility_Info help link help link  
Facility NameArkema Inc. - Crosby Plant
Street Address Line 118000 Crosby Eastgate Road
CityCrosby
StateTX
Zip Code77532
County FIPS Code48201
CountyHarris County
Parent CompanyArkema Delaware Inc.

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

Executive Summary
INTRODUCTION

A Risk Management Program has been implemented at Arkema Inc.'s Crosby, Texas production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan 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:

-Introduction;
-Arkema Inc.'s Policies 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. POLICIES FOR HEALTH, ENVIRONMENT, AND SAFETY

Arkema Inc. 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 Risk Management Plan formalizes and documents these activities.

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

FACILITY IDENTIFICATION AND REGULATED SUBSTANCES IN COVERED PROCESSES

The Arkema Inc. 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 40CFR68, the EPA Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability and for the Crosby plant include Sulfur Dioxide (SO2) and 2-Methyl Propene (Isobutylene).

HAZARD ASSESSMENT
WORST-CASE RELEASE MITIGATION MEASURES

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

In compliance with regulatory criteria associated with RMP evaluations, 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:

-Stationary fire monitors that could remove airborne vapors with water sprays;

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

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

HAZARD ASSESSMENT
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 unlike
ly to occur due to the facility's existing release and accident prevention program. If a release should occur, Arkema Inc. has mitigation measures to reduce potential human health and environmental receptor impact. The prevention program elements in place at Crosby are:

-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 that could remove airborne vapor with water sprays;

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

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

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

The Arkema Inc. 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 29CFR1910.119, Process Safety Management and the EPA Risk Management Program pursuant to 40CFR68. The accidental release prevention program includes the following elements and activities:

-In-depth hazard analyses are completed every five years by qualified personnel using techniques approved under the OSHA PSM standard of 29CFR1910.119;

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

-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety;

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

-Critical equipment is i
nspected on a planned, periodic basis to ensure proper operating conditions;

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

-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;

-The risk of over pressure of pressurized storage tanks is addressed by monitoring the tank temperature and pressure controllers or by a system of relief valves;

-The risk of over filling of vessels is addressed by the use of trained operators who monitor tank level indicators and metering devices;

-The risk of unloading releases are addressed by using a vapor recovery system 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 sabbotage;

-A safety permitting system is used to ensure routine and non-routine work is carried out after identification and implementation of safe work practices; and

-Hazardous material delivery drivers are escorted into the plant and for the duration of the unloading by plant logistics personnel and access to all plant unloading lines is controlled via a key and lock system in the QC Laboratory to prevent inadvertant material transfers.

This systematic approach to process safety involves all
the 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 Inc. 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 employees 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 facility also conducts emergency drills on a regular basis.


PLANNED CHANGES FOR HEALTH, ENVIRONMENT, AND SAFETY

Safety has been a part of the culture at the Crosby facility for many years. An example of Crosby's dedication to safety is that in March of 2006, the facility acheived 23 years without a plant employee lost time incident. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. The Crosby facility continues to implement methods to reduce risk, as demonstrated by the installation of remote access controls for these tank systems.


CERTIFICATION

I ceritify to the best of my knowledge, the information, and belief formed after reasonable inquiry, that the information submitted is true, accurate, and complete. The Crosby facility submitted its Title V permit application t
o the EPA on May 18, 2000 and has been assigned an operating permit number O-01554, which is currently being reviewed by TCEQ.
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 Employees80
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 Date19770824
Last Safety Inspection ByOSHA
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 #4 : 20060621)
Owner or Operator Phone2813283561
Facility Phone2813283561
Facility Dun and Bradstreet Number0
RMP ContactDenise L. Hubbard
RMP Contact TitleDirector of Manufacturing
RMP Contact EmailDenise.hubbard@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 Date20060622
Error Report Datenull
Graphics IndicatorNo
Attachment IndicatorNo
Certification Received FlagYes
Submission MethodRMP*Submit
CBI Substantiation FlagNo
Electronic Waiver FlagNo
Postmark Date20060615
Anniversary Date20090616
Confidential Business InformationNo
Unsanitized Version ProvidedNo
Software Version Number3.4

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #4 : 20060621)
Latitude29.943722
Longitude-95.022722
Valid Lat/LongYes
Lat/Long MethodInterpolation - Photo
Lat/Long Location TypeAdministrative Building
Lat/Long Horizontal Accuracy25
Lat/Long Horizontal Reference2
Lat/Long Source Map Scale24000
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 Chemicals2
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 #4 : 20060621, process #1 : CPU and MPU Units)
Process ID66474
Process DescriptionCPU and MPU Units
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)50,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)50,000
Number of Process Chemicals1
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 Record ID88064
Process Chemical IDSulfur dioxide (anhydrous)
CAS number007446095
Chemical TypeToxic
Process Chemical Amount (lbs)50,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #4 : 20060621, process #1 : CPU and MPU Units, process chemical #2)
Process Chemical Record ID588064
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  
Toxic Scenario ID43696
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
Release Duration (minutes)10
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
TopographyUrban
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 #4 : 20060621, process #1 : CPU and MPU Units, process chemical #2, alternate toxic scenario #1)
Toxic Scenario ID51514
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
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 #4 : 20060621, process #1 : CPU and MPU Units, process NAICS code #1 : 325199)
Process NAICS ID68062
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Prevention Program ID38975
Safety Info Review Date20040331
PHA Update Date20020328
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20030410
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
Changes Since PHA - Reduced InventoryYes
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 Date20040331
Training Review Date20031114
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 Date20021120
Maintenance Inspection Date20030612
Equipment TestedRemote actuated valves
Management of Change Most Recent Date20031030
Management of Change Review Date20040429
Pre-startup Review Date20031030
Compliance Audit Date20031117
Compliance Audit Change Completion Date20041231
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20031230
Hot Work Review Date20031230
Contractor Safety Review Date20030815
Contractor Safety Eval. Date20030825
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #4 : 20060621, process #1 : CPU and MPU Units, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
88064

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
This process includes two production units, the Continuous Perester Unit (CPU) and the Multi-Purpose Unit (MPU). All elements of Arkema Inc. Crosby Facility's prevention program, in accordance with 29CFR1910.119 for Process Safety Management and the EPA Risk Management Program pursuant to 40 CFR 68, apply to both units with the following exception: the date of the last PHA for CPU is 03/28/2002 and for MPU is 12/08/2003. The CPU is currently idle.

Processes facility_Processes help link help link  
Process ID66475
Process DescriptionMPU
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)82,000
Number of Process Chemicals1
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 #4 : 20060621, process #2 : MPU, process chemical #1)
Process Chemical Record ID88065
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)82,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical Record ID588065
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  
Flammable Scenario ID11306
Model UsedEPA's OCA Guidance Reference Tables or Equations
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 #4 : 20060621, process #2 : MPU, process chemical #2, alternate flammable scenario #1)
Flammable Scenario ID8727
Model UsedEPA's OCA Guidance Reference Tables or Equations
Passive Mitigation - DikesNo
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  
Process NAICS ID68063
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #4 : 20060621, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1)
Prevention Program ID38976
Safety Info Review Date20031208
PHA Update Date20031208
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistYes
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20041231
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
Mitigation Systems - SprinklersYes
Mitigation Systems - DikesNo
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
Changes Since PHA - Reduced InventoryYes
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 Date20040331
Training Review Date20031114
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 Date20021120
Maintenance Inspection Date20040308
Equipment TestedPumps
Management of Change Most Recent Date20040401
Management of Change Review Date20040429
Pre-startup Review Date20040401
Compliance Audit Date20031117
Compliance Audit Change Completion Date20041231
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20031230
Hot Work Review Date20031230
Contractor Safety Review Date20030815
Contractor Safety Eval. Date20030825
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #4 : 20060621, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
88065

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 ATOFINA Chemicals, 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 Date20030814
Response Training Date20031103
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, CAA

Submission Info facility_Submission_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #5 : 20041025)
RMP ID40974
Submission Typecorrection for prior submission
Receipt Date20041025
Reason For SubmissionNotification of facility ownership change
Deregistration Datenull
Deregistration Effective Datenull
Process Toxic Amount Total (lbs)50,000
Process Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)132,000
Number of Potential Offsite Consequence Processes2
Potential Offsite Consequence Toxic Amount Total (lbs)50,000
Potential Offsite Consequence Flammable Amount Total (lbs)82,000
Potential Offsite Consequence Amount Total (lbs)132,000

Submission - Basic Facility Info facility_Submission_-_Basic_Facility_Info help link help link  
Facility NameArkema Inc. - Crosby Plant
Street Address Line 118000 Crosby Eastgate Road
CityCrosby
StateTX
Zip Code77532
County FIPS Code48201
CountyHarris County
Parent CompanyArkema Delaware Inc.

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

Executive Summary
INTRODUCTION

A Risk Management Program has been implemented at Arkema Inc.'s Crosby, Texas production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan 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:

-Introduction;
-Arkema Inc.'s Policies 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. POLICIES FOR HEALTH, ENVIRONMENT, AND SAFETY

Arkema Inc. 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 Risk Management Plan formalizes and documents these activities.

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

FACILITY IDENTIFICATION AND REGULATED SUBSTANCES IN COVERED PROCESSES

The Arkema Inc. 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 40CFR68, the EPA Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability and for the Crosby plant include Sulfur Dioxide (SO2) and 2-Methyl Propene (Isobutylene).

HAZARD ASSESSMENT
WORST-CASE RELEASE MITIGATION MEASURES

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

In compliance with regulatory criteria associated with RMP evaluations, 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:

-Stationary fire monitors that could remove airborne vapors with water sprays;

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

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

HAZARD ASSESSMENT
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 unlike
ly to occur due to the facility's existing release and accident prevention program. If a release should occur, Arkema Inc. has mitigation measures to reduce potential human health and environmental receptor impact. The prevention program elements in place at Crosby are:

-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 that could remove airborne vapor with water sprays;

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

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

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

The Arkema Inc. 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 29CFR1910.119, Process Safety Management and the EPA Risk Management Program pursuant to 40CFR68. The accidental release prevention program includes the following elements and activities:

-In-depth hazard analyses are completed every five years by qualified personnel using techniques approved under the OSHA PSM standard of 29CFR1910.119;

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

-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety;

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

-Critical equipment is i
nspected on a planned, periodic basis to ensure proper operating conditions;

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

-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;

-The risk of over pressure of pressurized storage tanks is addressed by monitoring the tank temperature and pressure controllers or by a system of relief valves;

-The risk of over filling of vessels is addressed by the use of trained operators who monitor tank level indicators and metering devices;

-The risk of unloading releases are addressed by using a vapor recovery system 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 sabbotage;

-A safety permitting system is used to ensure routine and non-routine work is carried out after identification and implementation of safe work practices; and

-Hazardous material delivery drivers are escorted into the plant and for the duration of the unloading by plant logistics personnel and access to all plant unloading lines is controlled via a key and lock system in the QC Laboratory to prevent inadvertant material transfers.

This systematic approach to process safety involves all
the 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 Inc. 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 employees 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 facility also conducts emergency drills on a regular basis.


PLANNED CHANGES FOR HEALTH, ENVIRONMENT, AND SAFETY

Safety has been a part of the culture at the Crosby facility for many years. An example of Crosby's dedication to safety is that in March of 2004, the facility acheived 21 years without a plant employee lost time incident. Recently in May of 2004, the facility celebrated the completion of one year without an employee OSHA Recordable injury. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. The Crosby facility continues to implement methods to reduce risk, as demonstrated by the installation of remote access controls for these tank systems.


CERTIFICATION

I ceritify to the best of my knowledge, the information, and belief formed after reasonable inquiry, that
the information submitted is true, accurate, and complete. The Crosby facility submitted its Title V permit application to the EPA on May 18, 2000 and has been assigned an operating permit number O-01554, which is currently being reviewed by TCEQ.
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 Employees81
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 Date19770824
Last Safety Inspection ByOSHA
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 #5 : 20041025)
Owner or Operator Phone2813283561
Facility Phone2813283561
Facility Dun and Bradstreet Number0
RMP ContactRandy Nycz
RMP Contact TitlePlant Manager
RMP Contact Emailrandy.nycz@arkemagroup.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 Date20041029
Error Report Datenull
Graphics IndicatorNo
Attachment IndicatorNo
Certification Received FlagYes
Submission MethodRMP*Submit
CBI Substantiation FlagNo
Electronic Waiver FlagNo
Postmark Date20041022
Anniversary Date20090616
Confidential Business InformationNo
Unsanitized Version ProvidedNo
Software Version Number3.3

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #5 : 20041025)
Latitude29.943722
Longitude-95.022722
Valid Lat/LongYes
Lat/Long MethodInterpolation - Photo
Lat/Long Location TypeAdministrative Building
Lat/Long Horizontal Accuracy25
Lat/Long Horizontal Reference2
Lat/Long Source Map Scale24000
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 Chemicals2
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 #5 : 20041025, process #1 : CPU and MPU Units)
Process ID58884
Process DescriptionCPU and MPU Units
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)50,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)50,000
Number of Process Chemicals1
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 Record ID77793
Process Chemical IDSulfur dioxide (anhydrous)
CAS number007446095
Chemical TypeToxic
Process Chemical Amount (lbs)50,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #5 : 20041025, process #1 : CPU and MPU Units, process chemical #2)
Process Chemical Record ID577793
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  
Toxic Scenario ID38912
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
Release Duration (minutes)10
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
TopographyUrban
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 #5 : 20041025, process #1 : CPU and MPU Units, process chemical #2, alternate toxic scenario #1)
Toxic Scenario ID45876
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
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 #5 : 20041025, process #1 : CPU and MPU Units, process NAICS code #1 : 325199)
Process NAICS ID60241
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Prevention Program ID34066
Safety Info Review Date20040331
PHA Update Date20020328
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20030410
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
Changes Since PHA - Reduced InventoryYes
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 Date20040331
Training Review Date20031114
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 Date20021120
Maintenance Inspection Date20030612
Equipment TestedRemote actuated valves
Management of Change Most Recent Date20031030
Management of Change Review Date20040429
Pre-startup Review Date20031030
Compliance Audit Date20031117
Compliance Audit Change Completion Date20041231
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20031230
Hot Work Review Date20031230
Contractor Safety Review Date20030815
Contractor Safety Eval. Date20030825
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #5 : 20041025, process #1 : CPU and MPU Units, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
77793

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
This process includes two production units, the Continuous Perester Unit (CPU) and the Multi-Purpose Unit (MPU). All elements of ATOFINA Chemicals, Inc. Crosby Facility's prevention program, in accordance with 29CFR1910.119 for Process Safety Management and the EPA Risk Management Program pursuant to 40 CFR 68, apply to both units with the following exception: the date of the last PHA for CPU is 03/28/2002 and for MPU is 12/08/2003. The CPU is currently idle.

Processes facility_Processes help link help link  
Process ID58885
Process DescriptionMPU
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)82,000
Number of Process Chemicals1
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 #5 : 20041025, process #2 : MPU, process chemical #1)
Process Chemical Record ID77794
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)82,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical Record ID577794
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  
Flammable Scenario ID10015
Model UsedEPA's OCA Guidance Reference Tables or Equations
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 #5 : 20041025, process #2 : MPU, process chemical #2, alternate flammable scenario #1)
Flammable Scenario ID7806
Model UsedEPA's OCA Guidance Reference Tables or Equations
Passive Mitigation - DikesNo
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  
Process NAICS ID60242
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #5 : 20041025, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1)
Prevention Program ID34067
Safety Info Review Date20031208
PHA Update Date20031208
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistYes
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20041231
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
Mitigation Systems - SprinklersYes
Mitigation Systems - DikesNo
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
Changes Since PHA - Reduced InventoryYes
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 Date20040331
Training Review Date20031114
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 Date20021120
Maintenance Inspection Date20040308
Equipment TestedPumps
Management of Change Most Recent Date20040401
Management of Change Review Date20040429
Pre-startup Review Date20040401
Compliance Audit Date20031117
Compliance Audit Change Completion Date20041231
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20031230
Hot Work Review Date20031230
Contractor Safety Review Date20030815
Contractor Safety Eval. Date20030825
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #5 : 20041025, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
77794

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 ATOFINA Chemicals, 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 Date20030814
Response Training Date20031103
Local Response AgencyCrosby Volunteer Fire Department
Local Response Agency Phone2813281000
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, CAA

Submission Info facility_Submission_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #6 : 20040618)
RMP ID32795
Submission Typerevised submission for facility
Receipt Date20040618
Reason For Submission5-year update (40 CFR 68.190(b)(1))
Deregistration Datenull
Deregistration Effective Datenull
Process Toxic Amount Total (lbs)50,000
Process Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)132,000
Number of Potential Offsite Consequence Processes2
Potential Offsite Consequence Toxic Amount Total (lbs)50,000
Potential Offsite Consequence Flammable Amount Total (lbs)82,000
Potential Offsite Consequence Amount Total (lbs)132,000

Submission - Basic Facility Info facility_Submission_-_Basic_Facility_Info help link help link  
Facility NameATOFINA Chemicals, Inc. - Crosby Plant
Street Address Line 118000 Crosby Eastgate Road
CityCrosby
StateTX
Zip Code77532
County FIPS Code48201
CountyHarris County
Parent CompanyATOFINA Delaware, Inc.

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

Executive Summary
INTRODUCTION

A Risk Management Program has been implemented at ATOFINA Chemicals, Inc.'s Crosby, Texas production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan 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:

-Introduction;
-ATOFINA Chemicals, Inc.'s Policies 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.

ATOFINA CHEMICALS, INC. POLICIES FOR HEALTH, ENVIRONMENT, AND SAFETY

ATOFINA Chemicals, Inc. 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 Risk Management Plan formalizes and documents these activities.

This commitment to health, environment, and safety (HES) 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 ATOFINA Chemicals, Inc.'s HES programs is also reflected by a strong commitment to safety by employees and contractors.

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

FACILITY IDENTIFICATION AND REGULATED SUBSTANCES IN COVERED PROCESSES

The ATOFINA Chemicals, Inc. 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 40CFR68, the EPA Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability and for the Crosby plant include Sulfur Dioxide (SO2) and 2-Methyl Propene (Isobutylene).

HAZARD ASSESSMENT
WORST-CASE RELEASE MITIGATION MEASURES

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

In compliance with regulatory criteria associated with RMP evaluations, active mitigation systems cannot be considered in modeling worst-case scenario impacts; however, the significant planning and subsequent implementation that ATOFINA Chemicals, Inc. has made in active mitigation measures could effectively reduce the risk associated with an RMP worst-case related incident. Mitigation measures include:

-Stationary fire monitors that could remove airborne vapors with water sprays;

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

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

HAZARD ASSESSMENT
ALTERNATIVE RELEASE SCENARIOS MITIGATION MEASURES

While the Alterna
tive 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, ATOFINA Chemicals, Inc. has mitigation measures to reduce potential human health and environmental receptor impact. The prevention program elements in place at Crosby are:

-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 that could remove airborne vapor with water sprays;

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

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

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

The ATOFINA Chemicals, Inc. 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 29CFR1910.119, Process Safety Management and the EPA Risk Management Program pursuant to 40CFR68. The accidental release prevention program includes the following elements and activities:

-In-depth hazard analyses are completed every five years by qualified personnel using techniques approved under the OSHA PSM standard of 29CFR1910.119;

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

-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting
safety;

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

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

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

-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;

-The risk of over pressure of pressurized storage tanks is addressed by monitoring the tank temperature and pressure controllers or by a system of relief valves;

-The risk of over filling of vessels is addressed by the use of trained operators who monitor tank level indicators and metering devices;

-The risk of unloading releases are addressed by using a vapor recovery system 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 sabbotage;

-A safety permitting system is used to ensure routine and non-routine work is carried out after identification and implementation of safe work practices; and

-Hazardous material delivery drivers are escorted into the plant and for the duration of the unloading by plant logistics personnel and access to all plant unloading lines is controlled vi
a a key and lock system in the QC Laboratory to prevent inadvertant material transfers.

This systematic approach to process safety involves all the 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 ATOFINA Chemicals, Inc. 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 employees 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 facility also conducts emergency drills on a regular basis.


PLANNED CHANGES FOR HEALTH, ENVIRONMENT, AND SAFETY

Safety has been a part of the culture at the Crosby facility for many years. An example of Crosby's dedication to safety is that in March of 2004, the facility acheived 21 years without a plant employee lost time incident. Recently in May of 2004, the facility celebrated the completion of one year without an employee OSHA Recordable injury. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. The Crosby facility continues to implement methods to reduce risk, as demonstrated by the installation of remote access
controls for these tank systems.


CERTIFICATION

I ceritify to the best of my knowledge, the information, and belief formed after reasonable inquiry, that the information submitted is true, accurate, and complete. The Crosby facility submitted its Title V permit application to the EPA on May 18, 2000 and has been assigned an operating permit number O-01554, which is currently being reviewed by TCEQ.
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees53
Owner or Operator NameATOFINA Chemicals, 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 Employees90
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 Date19770824
Last Safety Inspection ByOSHA
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 #6 : 20040618)
Owner or Operator Phone2813283561
Facility Phone2813283561
Facility Dun and Bradstreet Number0
RMP ContactRandy Nycz
RMP Contact TitlePlant Manager
RMP Contact Emailrandy.nycz@atofina.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 Date20040715
Error Report Datenull
Graphics IndicatorNo
Attachment IndicatorYes
Certification Received FlagYes
Submission MethodRMP*Submit
CBI Substantiation FlagNo
Electronic Waiver FlagNo
Postmark Date20040616
Anniversary Date20090616
Confidential Business InformationNo
Unsanitized Version ProvidedNo
Software Version Number3.1

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #6 : 20040618)
Latitude29.943722
Longitude-95.022722
Valid Lat/LongYes
Lat/Long MethodInterpolation - Photo
Lat/Long Location TypeAdministrative Building
Lat/Long Horizontal Accuracy25
Lat/Long Horizontal Reference2
Lat/Long Source Map Scale24000
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 Chemicals2
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 #6 : 20040618, process #1 : CPU and MPU Units)
Process ID47373
Process DescriptionCPU and MPU Units
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)50,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)50,000
Number of Process Chemicals1
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 Record ID62426
Process Chemical IDSulfur dioxide (anhydrous)
CAS number007446095
Chemical TypeToxic
Process Chemical Amount (lbs)50,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #6 : 20040618, process #1 : CPU and MPU Units, process chemical #2)
Process Chemical Record ID562426
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  
Toxic Scenario ID30891
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
Release Duration (minutes)10
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
TopographyUrban
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 #6 : 20040618, process #1 : CPU and MPU Units, process chemical #2, alternate toxic scenario #1)
Toxic Scenario ID36459
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
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 #6 : 20040618, process #1 : CPU and MPU Units, process NAICS code #1 : 325199)
Process NAICS ID48424
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Prevention Program ID27115
Safety Info Review Date20040331
PHA Update Date20020328
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20030410
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
Changes Since PHA - Reduced InventoryYes
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 Date20040331
Training Review Date20031114
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 Date20021120
Maintenance Inspection Date20030612
Equipment TestedRemote actuated valves
Management of Change Most Recent Date20031030
Management of Change Review Date20040429
Pre-startup Review Date20031030
Compliance Audit Date20031117
Compliance Audit Change Completion Date20041231
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20031230
Hot Work Review Date20031230
Contractor Safety Review Date20030815
Contractor Safety Eval. Date20030825
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #6 : 20040618, process #1 : CPU and MPU Units, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
62426

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
This process includes two production units, the Continuous Perester Unit (CPU) and the Multi-Purpose Unit (MPU). All elements of ATOFINA Chemicals, Inc. Crosby Facility's prevention program, in accordance with 29CFR1910.119 for Process Safety Management and the EPA Risk Management Program pursuant to 40 CFR 68, apply to both units with the following exception: the date of the last PHA for CPU is 03/28/2002 and for MPU is 12/08/2003. The CPU is currently idle.

Processes facility_Processes help link help link  
Process ID47374
Process DescriptionMPU
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)82,000
Number of Process Chemicals1
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 #6 : 20040618, process #2 : MPU, process chemical #1)
Process Chemical Record ID62427
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)82,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical Record ID562427
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  
Flammable Scenario ID8460
Model UsedEPA's OCA Guidance Reference Tables or Equations
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 #6 : 20040618, process #2 : MPU, process chemical #2, alternate flammable scenario #1)
Flammable Scenario ID6695
Model UsedEPA's OCA Guidance Reference Tables or Equations
Passive Mitigation - DikesNo
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  
Process NAICS ID48425
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #6 : 20040618, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1)
Prevention Program ID27116
Safety Info Review Date20031208
PHA Update Date20031208
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistYes
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20041231
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
Mitigation Systems - SprinklersYes
Mitigation Systems - DikesNo
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
Changes Since PHA - Reduced InventoryYes
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 Date20040331
Training Review Date20031114
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 Date20021120
Maintenance Inspection Date20040308
Equipment TestedPumps
Management of Change Most Recent Date20040401
Management of Change Review Date20040429
Pre-startup Review Date20040401
Compliance Audit Date20031117
Compliance Audit Change Completion Date20041231
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20031230
Hot Work Review Date20031230
Contractor Safety Review Date20030815
Contractor Safety Eval. Date20030825
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #6 : 20040618, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
62427

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 ATOFINA Chemicals, 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 Date20030814
Response Training Date20031103
Local Response AgencyCrosby Volunteer Fire Department
Local Response Agency Phone2813281000
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, CAA

Submission Info facility_Submission_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711)
RMP ID21617
Submission Typerevised submission for facility
Receipt Date20000711
Deregistration Datenull
Deregistration Effective Datenull
Process Toxic Amount Total (lbs)56,000
Process Flammable Amount Total (lbs)168,000
Process Amount Total (lbs)224,000
Number of Potential Offsite Consequence Processes3
Potential Offsite Consequence Toxic Amount Total (lbs)56,000
Potential Offsite Consequence Flammable Amount Total (lbs)168,000
Potential Offsite Consequence Amount Total (lbs)224,000

Submission - Basic Facility Info facility_Submission_-_Basic_Facility_Info help link help link  
Facility NameATOFINA Chemicals, Inc. - Crosby Plant
Street Address Line 118000 Crosby Eastgate Road
CityCrosby
StateTX
Zip Code77532
County FIPS Code48201
CountyHarris County
Parent CompanyATOFINA Delaware, Inc.

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

Executive Summary
INTRODUCTION

A Risk Management Program has been implemented at ATOFINA Chemicals, Inc.'s Crosby, Texas production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan 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:

-Introduction;
-ATOFINA Chemicals, Inc.'s Policies 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.

ATOFINA CHEMICALS, INC. POLICIES FOR HEALTH, ENVIRONMENT, AND SAFETY

ATOFINA Chemicals, Inc. 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 Risk Management Plan formalizes and documents these activities.

This commitment to health, environment, and safety (HES) 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 ATOFINA Chemicals, Inc.'s HES programs is also reflected by a strong commitment to safety by employees and contractors.

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

FACILITY IDENTIFICATION AND REGULATED SUBSTANCES IN COVERED PROCESSES

The ATOFINA Chemicals, Inc. 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 40CFR68, the EPA Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability and for the Crosby plant include Sulfur Dioxide (SO2) and 2-Methyl Propene (Isobutylene).

HAZARD ASSESSMENT
TOXIC WORST-CASE SCENARIO

The worst-case accidental release scenario submitted for Program 3 toxic substances involves a catastophic failure of the Sulfur Dioxide (SO2) storage tank. Sulfur Dioxide is purchased and transported to the Crosby facility via pressurized tank trucks. SO2 is stored as a gas in a pressure controlled storage tank. Administrative controls limit the quantity of SO2 stored on-site to 90% of the storage tank's capacity. This quantity is assumed to be released over a 10 minute period and that the entire quantity is released as a vapor. Based on dispersion modeling, using the EPA Off-Site Consequence Analysis (OCA), and EPA assumptions, the resulting concentrations of SO2 from the worst-case scenario release caused off-site impacts.

It should be noted that the worst-case scenario is recognized by regulatory agencies and ATOFINA Chemicals, Inc. as an extremely unlikely event. Mitigation and prevention procedures and measures are implemented by ATOFINA Chemicals, Inc. to reduce the risk of the worst-case event occurring.

FLAMMABLE WORST-CASE SCENARIO

The worst-case accidental release scenario submitted for Program
3 flammable substances involves a catastrophic failure of a 2-Methyl Propene (isobutylene) storage tank. Isobutylene is purchased and transported to the Crosby facility via pressurized tank trucks. It is stored as a gas in a pressure controlled storage tank. Administrative controls limit the quantity of isobutylene stored on-site to 90% of the storage tank's capacity. This quantity is assumed to be released over a 10 minute period. It is further assumed that the entire quantity is released as a vapor, which comes in contact with an ignition source, with 10% of the total released quantity participating in a vapor cloud explosion. Based on dispersion modeling, using the EPA OCA look-up tables, and EPA assumptions, the 1 psi overpressurization resulting from the isobutylene vapor cloud explosion caused off-site impacts.

Again, it should be noted that the worst-case scenario is recognized by regulatory agencies and ATOFINA Chemicals, Inc. as an extremely unlikely event. Mitigation and prevention procedures and measures are implemented by ATOFINA Chemicals, Inc. to reduce the risk of the worst-case event occurring.

WORST-CASE RELEASE MITIGATION MEASURES

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

In compliance with regulatory criteria associated with RMP evaluations, active mitigation systems cannot be considered in modeling worst-case scenario impacts; however, the significant planning and subsequent implementation that ATOFINA Chemicals, Inc. has made in active mitigation measures could effectively reduce the risk associated with an RMP worst-case related incident. Mitigation measures include:

-Stationary fire monitors that could remove airborne vapors with water sprays;

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

-A Community Alert Network (CAN) enabling the facility to immediately notify the surrounding neighbors.

HAZARD ASSESSMENT
TOXIC ALTERNATIVE RELEASE SCENARIO

The alternative release scenario submitted for Program 3 toxic substances involves the failure of a 1"" pipe from the SO2 storage tank to the Continuous Perester Unit's (CPU) process building. Mitigation measures to reduce this release are an excess flow valve on the line and a remote activated tank shut-off system. Evaluation of the alternative release scenario per EPA assumptions shows off-site impacts.

FLAMMABLE ALTERNATIVE RELEASE SCENARIO

The alternative release scenario submitted for Program 3 flammable substances involves the failure of a 4"" line from the isobutylene storage tank to the tank's pressure relief device system. Mitigation measures to reduce this release is the remote activated tank shut-off system. Evaluation of the alternative release scenario per EPA assumptions shows off-site impacts.

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, ATOFINA Chemicals, Inc. has mitigation measures to reduce potential human health and environmental receptor impact. The prevention program elements in place at Crosby are:

-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 that could remove airborne vapor with water sprays;

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

-A Community Alert Network (CAN) enabling the facility to immediately notify the surrounding neighbors.

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

The ATOFINA Chemicals, Inc. 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 29CFR1910.119, Process Safety Management and the EPA Risk Management Program pursuant to 40CFR68. The accidental release prevention program includes the following elements and activities:

-In-depth hazard analyses are completed every five years by qualified personnel using techniques approved under the OSHA PSM standard of 29CFR1910.119;

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

-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety;

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

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

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

-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 Pet
roleum 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;

-The risk of over pressure of pressurized storage tanks is addressed by monitoring the tank temperature and pressure controllers or by a system of relief valves;

-The risk of over filling of vessels is addressed by the use of trained operators who monitor tank level indicators and metering devices;

-The risk of unloading releases are addressed by using a vapor recovery system 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 sabbotage; and,

-A safety permitting system is used to ensure routine and non-routine work is carried out after identification and implementation of safe work practices.

This systematic approach to process safety involves all the 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

Sulfur Dioxide:
There have been no accidental off-site releases of Sulfur Dioxide from our facility for the past five years.

2-Methyl Propene
There have been no accidental releases of 2-Methyl Propene from our facility for the past five years that have had an adverse impact on the community. There has been one incident at the facility which meets the EPA Risk Management Program accident criteria with respect to causing significant property damage on-site.

On November 6, 1998, an explosion occurred in one of the facility's production units. Due to mechanical pump problems, the preparation and transfer of the sulfated isobutylene intermediate
with the organic peroxide intermediate was delayed. During this delay period, the temperature of the organic peroxide intermediate mixture rose. Upon completion of maintenance activities, the production process was continued by combining the two intermediate mixtures. Due to the elevated temperature of the organic peroxide intermediate mixture, the resultant mixture underwent a rapid decomposition. From this decomposition, approximately 180 pounds of isobutylene was released. No off-site injuries or property damage resulted from this incident. No on-site injuries occurred. Property damage occurred on-site and was localized to the facility's production unit.


EMERGENCY RESPONSE STATEMENT

The ATOFINA Chemicals, Inc. 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 employees 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 facility also conducts emergency drills on a regular basis.


PLANNED CHANGES FOR HEALTH, ENVIRONMENT, AND SAFETY

Safety has been a part of the culture at the Crosby facility for many years. An example of Crosby's dedication to safety is that in March of 2000, the facility acheived 17 years without a plant employee lost time incident. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. The Crosby facility continues to implement methods to reduce risk, as demonstrated by the installation of remote access controls for these tank systems.


CERTIFICATION


I ceritify to the best of my knowledge, the information, and belief formed after reasonable inquiry, that the information submitted is true, accurate, and complete. The Crosby facility submitted its Title V permit application to the EPA on May 18, 2000 and is operating under permit number O-01554.
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees53
Owner or Operator NameATOFINA Chemicals, 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 Employees114
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 Date19770824
Last Safety Inspection ByOSHA
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 #7 : 20000711)
Owner or Operator Phone2813283561
Facility Phone2813283561
Facility Dun and Bradstreet Number43750152
RMP ContactRandy Nycz
RMP Contact TitlePlant Manager

Submission - Additional Info facility_Submission_-_Additional_Info help link help link  
RMP Complete FlagYes
Predictive FilingNo
No RMP Accidents Last 5 YearsNo
Complete Check Date20000712
Error Report Date20000712
Graphics IndicatorNo
Attachment IndicatorNo
Certification Received FlagYes
Submission MethodRMP*Submit
CBI Substantiation FlagNo
Electronic Waiver FlagNo
Postmark Date20000710
Anniversary Date20050710
Confidential Business InformationNo
Unsanitized Version ProvidedNo
Software Version Number1.2.5

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711)
Latitude29.965556
Longitude-95.021944
Valid Lat/LongYes
Lat/Long MethodOther
Lat/Long Location TypeAdministrative Building
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 Accidents1
Number of Processes3
Number of Process Chemicals3
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)180
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)180
Total RMP Accident Deaths0
Total RMP Accident Injuries0
Total RMP Accident Evacuated/Sheltering In Place257
Total RMP Accident Property Damage$3,500,000

Processes facility_Processes help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711, process #1 : BPU, CPU, MPU Units)
Process ID30558
Process DescriptionBPU, CPU, MPU Units
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)56,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)56,000
Number of Process Chemicals1
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 Record ID39849
Process Chemical IDSulfur dioxide (anhydrous)
CAS number007446095
Chemical TypeToxic
Process Chemical Amount (lbs)56,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711, process #1 : BPU, CPU, MPU Units, process chemical #2)
Process Chemical Record ID539849
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  
Toxic Scenario ID20055
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
Release Duration (minutes)10
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
TopographyUrban
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 #7 : 20000711, process #1 : BPU, CPU, MPU Units, process chemical #2, alternate toxic scenario #1)
Toxic Scenario ID23488
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
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 #7 : 20000711, process #1 : BPU, CPU, MPU Units, process NAICS code #1 : 325199)
Process NAICS ID31332
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Prevention Program ID16881
Safety Info Review Date20000516
PHA Update Date20000516
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20011231
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 - OverfillingNo
Hazard Identified - ContaminationYes
Hazard Identified - Equipment FailureYes
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeNo
Hazard Identified - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
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 Date20000516
Training Review Date20000327
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - OtherCBT
Competency Testing - Written TestsYes
Competency Testing - Oral TestsYes
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date20000627
Maintenance Inspection Date20000613
Equipment TestedPressure Relief Valves
Management of Change Most Recent Date20000626
Management of Change Review Date19990830
Pre-startup Review Date19990921
Compliance Audit Date19971205
Compliance Audit Change Completion Date20000321
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20000419
Hot Work Review Date19990715
Contractor Safety Review Date19981016
Contractor Safety Eval. Date20000627
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711, process #1 : BPU, CPU, MPU Units, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
39849

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
This process includes three interconnected production units, the Batch Processing Unit (BPU), the Continuous Perester Unit (CPU), and the Multi-Purpose Unit (MPU). All elements of ATOFINA Chemicals, Inc. Crosby Facility's prevention program, in accordance with 29CFR1910.119 for Process Safety Management and the EPA Risk Management Program pursuant to 40 CFR 68, apply to all three units with the following exception: the date of the last PHA for CPU is 03/26/97.

Processes facility_Processes help link help link  
Process ID30559
Process DescriptionMPU
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)82,000
Number of Process Chemicals1
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 #7 : 20000711, process #2 : MPU, process chemical #1)
Process Chemical Record ID39850
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)82,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical Record ID539850
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  
Flammable Scenario ID5318
Model UsedEPA's OCA Guidance Reference Tables or Equations
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 #7 : 20000711, process #2 : MPU, process chemical #2, alternate flammable scenario #1)
Flammable Scenario ID4153
Model UsedEPA's OCA Guidance Reference Tables or Equations
Passive Mitigation - DikesNo
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  
Process NAICS ID31333
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1)
Prevention Program ID16882
Safety Info Review Date20000416
PHA Update Date20000416
PHA Technique - What IfYes
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20011231
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
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 Date20000307
Training Review Date20000327
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - OtherCBT
Competency Testing - Written TestsYes
Competency Testing - Oral TestsYes
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date20000627
Maintenance Inspection Date19981111
Equipment TestedStorage Tank
Management of Change Most Recent Date20000626
Management of Change Review Date19990830
Pre-startup Review Date19990921
Compliance Audit Date19971205
Compliance Audit Change Completion Date20000321
Incident Investigation Date19981106
Incident Invest. Change Completion Date19991015
Participation Plan Review Date20000419
Hot Work Review Date19990715
Contractor Safety Review Date19981016
Contractor Safety Eval. Date20000627
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
39850

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 ATOFINA Chemicals, 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.

Processes facility_Processes help link help link  
Process ID30560
Process DescriptionBPU
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)86,000
Process Amount Total (lbs)86,000
Number of Process Chemicals1
Number of Toxic Worst-Case Scenarios0
Number of Toxic Alternate Scenarios0
Number of Flammable Worst-Case Scenarios0
Number of Flammable Alternate Scenarios0

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711, process #3 : BPU, process chemical #1)
Process Chemical Record ID39851
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)86,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical Record ID539851
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link  
Process NAICS ID31334
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711, process #3 : BPU, process NAICS code #1 : 325199, prev. program 3 #1)
Prevention Program ID16883
Safety Info Review Date20000412
PHA Update Date20000412
PHA Technique - What IfNo
PHA Technique - ChecklistYes
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Technique - OtherUpdate of July 1995 PHA.
PHA Change Completion Date20011231
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 - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
Mitigation Systems - SprinklersNo
Mitigation Systems - DikesNo
Mitigation Systems - Fire WallsNo
Mitigation Systems - Blast WallsNo
Mitigation Systems - Deluge SystemsNo
Mitigation Systems - Water CurtainsNo
Mitigation Systems - EnclosureNo
Mitigation Systems - NeutralizationNo
Mitigation Systems - NoneNo
Mitigation Systems - OtherFire Monitors
Monitoring Systems - Process AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
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 Date20000412
Training Review Date20000327
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - OtherCBT
Competency Testing - Written TestsYes
Competency Testing - Oral TestsYes
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date20000627
Maintenance Inspection Date20000316
Equipment TestedStorage Tank
Management of Change Most Recent Date20000626
Management of Change Review Date19990830
Pre-startup Review Date19990416
Compliance Audit Date19971205
Compliance Audit Change Completion Date20000321
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20000419
Hot Work Review Date19990715
Contractor Safety Review Date19981016
Contractor Safety Eval. Date20000627
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711, process #3 : BPU, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
39851

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
This process covers the BPU production unit only. All of ATOFINA Chemicals, 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.

Accidents facility_Accidents help link help link  
Accident ID3093
Accident Date19981106
Accident Time1535
Number of Chemicals1
Flammable Amount Total (lbs)180
Toxic Amount Total (lbs)0
Released Amount Total (lbs)180
Number of Deaths0
Number of Injuries0
Number Evacuated / Sheltered257
Total Property Damage$3,500,000
Environmental DamageNo
NAICS of Process Involved325199: All Other Basic Organic Chemical Manufacturing
Release Duration (HHHMM)1
Release Event - Gas ReleaseNo
Release Event - SpillNo
Release Event - FireNo
Release Event - ExplosionYes
Release Event - ReactionNo
Release Source - Storage VesselNo
Release Source - PipingNo
Release Source - Process VesselYes
Release Source - Transfer HoseNo
Release Source - ValveNo
Release Source - PumpNo
Release Source - JointNo
Wind Speed10
Wind Speed Unitsmiles/h
Wind DirectionE
Temperature50
PrecipitationNo
Unknown WeatherNo
Workers Killed0
Responders Killed0
Public Killed (on-site)0
Workers Injured0
Responders Injured0
Public Injured (on-site)0
Property Damage (on-site)$3,500,000
Off-site Deaths0
Hospitalizations0
Number Requiring Medical Treatment0
Number Evacuated0
Number Sheltered In Place257
Property damage (off-site)$0
Environmental Damage - Fish/Animal KillsNo
Environmental Damage - DefoliationNo
Environmental Damage - Water ContaminationNo
Environmental Damage - Soil ContaminationNo
Initiating EventEquipment Failure
Contributing Factor - Equipment FailureYes
Contributing Factor - Human ErrorNo
Contributing Factor - Improper ProcedureNo
Contributing Factor - OverpressurizationNo
Contributing Factor - Upset ConditionNo
Contributing Factor - By-pass ConditionNo
Contributing Factor - MaintenanceYes
Contributing Factor - Process DesignNo
Contributing Factor - Unsuitable EquipmentNo
Contributing Factor - Unusual WeatherNo
Contributing Factor - Management ErrorNo
Off-site Responders NotifiedNotified Only
Changes Introduced - Improved EquipmentYes
Changes Introduced - Revised MaintenanceYes
Changes Introduced - Revised TrainingYes
Changes Introduced - Operating ProceduresYes
Changes Introduced - Process ControlYes
Changes Introduced - Mitigation SystemsYes
Changes Introduced - Response PlanYes
Changes Introduced - Changed ProcessNo
Changes Introduced - Reduced InventoryNo
Changes Introduced - NoneNo
Confidential Business InformationNo
Total RMP Accident Deaths0
Total RMP Accident Injuries0
Total RMP Accident Evacuated/Sheltering In Place0
Total RMP Accident Property Damage$0

Accident Chemicals facility_Accident_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #7 : 20000711, accident #1, accident chemical #1)
Accident Chemical Record ID3391
Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Amount Released (lbs)180
Number of Flammable Components0

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 Date19990503
Response Training Date20000615
Local Response AgencyCrosby Volunteer Fire Department
Local Response Agency Phone2813281000
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

Submission Info facility_Submission_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622)
RMP ID11802
Submission Typefirst submission for facility
Receipt Date19990622
Deregistration Datenull
Deregistration Effective Datenull
Process Toxic Amount Total (lbs)56,000
Process Flammable Amount Total (lbs)168,000
Process Amount Total (lbs)224,000
Number of Potential Offsite Consequence Processes3
Potential Offsite Consequence Toxic Amount Total (lbs)56,000
Potential Offsite Consequence Flammable Amount Total (lbs)168,000
Potential Offsite Consequence Amount Total (lbs)224,000

Submission - Basic Facility Info facility_Submission_-_Basic_Facility_Info help link help link  
Facility NameElf Atochem North America, Inc. Crosby Plant
Street Address Line 118000 Crosby Eastgate Road
CityCrosby
StateTX
Zip Code77532
County FIPS Code48201
CountyHarris County
Parent CompanyElf Atochem North America Delaware, Inc.

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

Executive Summary
INTRODUCTION

A Risk Management Program has been implemented at Elf Atochem North America, Inc.'s Crosby, Texas production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan 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:

-Introduction;
-Elf Atochem's Policies 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.


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

This commitment to health, environment, and safety (HES) 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 Elf Atochem's HES programs is also reflected by a strong commitment to safety by employees and contractors.

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


FACILITY IDENTIFICATION AND REGULATED SUBSTANCES IN COVERED PROCESSES

The Elf Atochem Crosby faility 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 Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability and for the Crosby plant include Sulfur Dioxide (SO2) and 2-Methyl Propene (Isobutylene).


HAZARD ASSESSMENT
TOXIC WORST CASE SCENARIO

The worst-case accidental release scenario submitted for Program 3 toxic substances involves a catastrophic failure of the Sulfur Dioxide (SO2) storage tank. Sulfur Dioxide is purchased and transported to the Crosby facility via pressurized tank trucks. SO2 is stored as a gas in a pressure controlled storage tank. Administrative controls limit the quantity of SO2 stored on-site to 90% of the storage tanks capacity. This quantity is assumed to be released over a 10 minute period and that the entire quantity is released as a vapor. Based on dispersion modeling, using the EPA Off-Site Consequence Analysis (OCA), and EPA assumptions, the resulting concentrations of SO2 from the worst-case scenario release caused off-site impacts.

It should be noted that the worst case scenario is recognized by regulatory agencies and Elf Atochem as an extremely unlikely event. Mitigation and prevention procedures and measures are implemented by Elf Atochem to reduce the risk of the worst case event occurring.

FLAMMABLE WORST CASE SCENARIO

The worst-case accidental release scenario submitted for Program 3 flammable substances involves a catastrophic failure of a 2-Methyl Propene (isobutylene) storage t
ank. Isobutylene is purchased and transported to the Crosby facility via pressurized tank trucks. It is stored as a gas in a pressure controlled storage tank. Administrative controls limit the quantity of isobutylene stored on-site to 90% of the storage tanks capacity. This quantity is assumed to be released over a 10-minute period. It is further assumed that the entire quantity is released as a vapor, which comes in contact with an ignition source, with 10% of the total released quantity participating in a vapor cloud explosion. Based on dispersion modeling, using the EPA OCA look-up tables, and EPA assumptions, the 1 psi overpressurization resulting from the isobutylene vapor cloud explosion caused off-site impacts.

Again, it should be noted that the worst-case scenario is recognized by regulatory agencies and Elf Atochem as an extremely unlikely event. Mitigation and prevention procedures and measures are implemented by Elf Atochem to reduce the risk of the worst-case event occurring.

WORST CASE RELEASE MITIGATION MEASURES

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

In compliance with regulatory criteria associated with RMP evaluations, active mitigation systems cannot be considered in modeling worst-case scenario impacts; however, the significant planning and subsequent implementation that Elf Atochem has made in active mitigation measures could effectively reduce the risk associated with an RMP worst-case related incident. Mitigation measures include:

-Stationary fire monitors that could remove airborne vapors with water sprays;

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

-A Community Alert Network (CAN) enabling the
facility to immediately notify the surrounding neighbors.


HAZARD ASSESSMENT
TOXIC ALTERNATIVE RELEASE SCENARIO

The alternative release scenario submitted for Program 3 toxic substances involves the failure of a 1"" pipe from the SO2 storage tank to the Continuous Perester Unit's (CPU) process building. Mitigation measures to reduce this release are an excess flow valve on the line and a remote activated tank shut-off system. Evaluation of the alternative release scenario per EPA assumptions shows off-site impacts.

The alternative release scenario submitted for Program 3 flammable substances involves the failure of a 4"" line from the isobutylene storage tank to the tank's pressure relief device system. Mitigation measure to reduce this release is the remote activated tank shut-off system. Evaluation of the alternative release scenario per EPA assumptions shows off-site impacts.

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 to reduce potential human health and environmental receptor impact. The prevention program elements in place at Crosby are:

-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 that could remove airborne vapor with water sprays;

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

-A Community Alert Network (CAN) enabling the facility to immediately notify the surrounding nei
ghbors.


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

The Elf Atochem 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 29 CFR 1910.119, Process Safety Management and the EPA Risk Management Program persuant to 40 CFR 68. The accidental release prevention program includes the following elements and activities:

-In-depth hazard analyses are completed every five years by qualified personnel using techniques approved under the OSHA PSM standard of 29 CFR 1910.119;

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

-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety;

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

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

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

-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;


-The risk of over pressure of pressurized storage tanks is addressed by monitoring the tank temperature and pressure controllers or by a system of relief valves;

-The risk of over filling of vessels is addressed by the use of trained operators who monitor tank level indicators and metering devices;

-The risk of unloading releases are addressed by using a vapor recovery system 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 sabbotage; and

-A safety permitting system is used to ensure routine and non-routine work is carried out after identification and implementation of safe work practices.

This systematic approach to process safety involves all the 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

Sulfur Dioxide:
There have been no accidental off-site releases of Sulfur Dioxide from our facility for the past five years.

2-Methyl Propene
There have been no accidental releases of 2-Methyl Propene from our facility for the past five years that have had an adverse impact on the community. There has been one incident at the facility which meets the EPA Risk Management Program accident criteria with respect to causing significant property damage on-site.

On November 6, 1998, an explosion occurred in one of the facility's production units. Due to mechanical pump problems, the preparation and transfer of the sulfated isobutylene intermediate with the organic peroxide intermediate was delayed. During this delay period, the temperature of the organic peroxide intermediate mixture rose. Upon completion of maintenance activites, the production p
rocess was continued by combining the two intermediate mixtures. Due to the elevated temperature of the organic peroxide intermediate mixture, the resultant mixture underwent a rapid decomposition. From this decomposition, approximately 180 pounds of isobutylene was released. No off-site injuries or property damage resulted from this incident. Property damage occurred on-site and was localized to the facility's production unit.


EMERGENCY RESPONSE STATEMENT

The Elf Atochem 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 employees 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.


PLANNED CHANGES FOR HEALTH, ENVIRONMENT AND SAFETY

Safety has been a part of the culture at the Crosby facility for many years. An example of Crosby's dedication to safety is that in March of 1999, the facility achieved 16 years without a plant employee lost time incident. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. The Crosby facility is also continuing with its efforts to upgrade the tank systems of the regulated substances to provide remote access controls for these tank systems.


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. Furthermore, the Crosby facility is in the process of preparing it's Title V permit application to be submitted to the EPA
in April of 2000.
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees53
Owner or Operator NameElf Atochem North America, 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 Employees107
Number of FTE CBI FlagNo
Covered by OSHA PSM StandardYes
Covered by EPCRA Section 302Yes
Covered by CAA Title VYes
Last Safety Inspection Date19770824
Last Safety Inspection ByOSHA
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 #8 : 19990622)
Owner or Operator Phone2813283561
Facility Phone2813283561
Facility Dun and Bradstreet Number43750152
RMP ContactRandy Nycz
RMP Contact TitlePlant Manager

Submission - Additional Info facility_Submission_-_Additional_Info help link help link  
RMP Complete FlagYes
Predictive FilingNo
No RMP Accidents Last 5 YearsNo
Complete Check Date19990713
Error Report Datenull
Graphics IndicatorNo
Attachment IndicatorNo
Certification Received FlagYes
Submission MethodRMP*Submit
CBI Substantiation FlagNo
Electronic Waiver FlagNo
Postmark Date19990621
Anniversary Date20040621
Confidential Business InformationNo
Unsanitized Version ProvidedNo
Software Version Number1.1.7

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622)
Latitude29.965556
Longitude-95.021944
Valid Lat/LongYes
Lat/Long MethodOther
Lat/Long Location TypeAdministrative Building
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 Accidents1
Number of Processes3
Number of Process Chemicals3
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)180
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)180
Total RMP Accident Deaths0
Total RMP Accident Injuries0
Total RMP Accident Evacuated/Sheltering In Place257
Total RMP Accident Property Damage$3,500,000

Processes facility_Processes help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622, process #1 : BPU, CPU, MPU Units)
Process ID15785
Process DescriptionBPU, CPU, MPU Units
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)56,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)56,000
Number of Process Chemicals1
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 Record ID19653
Process Chemical IDSulfur dioxide (anhydrous)
CAS number007446095
Chemical TypeToxic
Process Chemical Amount (lbs)56,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622, process #1 : BPU, CPU, MPU Units, process chemical #2)
Process Chemical Record ID519653
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  
Toxic Scenario ID10840
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
Release Duration (minutes)10
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
TopographyUrban
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 #8 : 19990622, process #1 : BPU, CPU, MPU Units, process chemical #2, alternate toxic scenario #1)
Toxic Scenario ID12417
Physical StateGas liquified by pressure
Model UsedEPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
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 #8 : 19990622, process #1 : BPU, CPU, MPU Units, process NAICS code #1 : 325199)
Process NAICS ID16179
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Prevention Program ID8164
Safety Info Review Date19990426
PHA Update Date19990416
PHA Technique - What IfYes
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20001231
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 - OverfillingNo
Hazard Identified - ContaminationYes
Hazard Identified - Equipment FailureYes
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeNo
Hazard Identified - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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 - InterlocksNo
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
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
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 Date19990205
Training Review Date19990421
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - OtherCBT
Competency Testing - Written TestsYes
Competency Testing - Oral TestsYes
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date19990506
Maintenance Inspection Date19981111
Equipment TestedExternal visual inspection of sulfur dioxide piping.
Management of Change Most Recent Date19990426
Management of Change Review Date19981116
Pre-startup Review Date19990209
Compliance Audit Date19971205
Compliance Audit Change Completion Date19990930
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date19990302
Hot Work Review Date19990512
Contractor Safety Review Date19981016
Contractor Safety Eval. Date19990210
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622, process #1 : BPU, CPU, MPU Units, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
19653

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
This process includes three interconnected production units, the Batch Processing Unit (BPU), the Continuous Perester Unit (CPU), and the Multi-Purpose Unit (MPU). All elements of Elf Atochem Crosby Facility's prevention program, in accordance with 29 CFR 1910.119 for Process Safety Management and the EPA Risk Management Program pursuant to 40 CFR 68, apply to all three units with the following exception: the dates of the last PHA for each respective unit are 12/13/95, 3/26/97 and 4/16/99.

Processes facility_Processes help link help link  
Process ID15786
Process DescriptionMPU
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)82,000
Process Amount Total (lbs)82,000
Number of Process Chemicals1
Number of Toxic Worst-Case Scenarios0
Number of Toxic Alternate Scenarios0
Number of Flammable Worst-Case Scenarios0
Number of Flammable Alternate Scenarios0

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622, process #2 : MPU, process chemical #1)
Process Chemical Record ID19654
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)82,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical Record ID519654
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link  
Process NAICS ID16180
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1)
Prevention Program ID8165
Safety Info Review Date19990426
PHA Update Date19990416
PHA Technique - What IfYes
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20001231
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 - OverfillingNo
Hazard Identified - ContaminationYes
Hazard Identified - Equipment FailureYes
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeNo
Hazard Identified - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
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
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 AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
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 Date19990204
Training Review Date19990421
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - OtherCBT
Competency Testing - Written TestsYes
Competency Testing - Oral TestsYes
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date19990506
Maintenance Inspection Date19990416
Equipment TestedExternal visual inspection of 2-methyl propene pump.
Management of Change Most Recent Date19990426
Management of Change Review Date19981116
Pre-startup Review Date19990209
Compliance Audit Date19971205
Compliance Audit Change Completion Date19990930
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date19990302
Hot Work Review Date19990512
Contractor Safety Review Date19981016
Contractor Safety Eval. Date19990210
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622, process #2 : MPU, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
19654

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 Elf Atochem's prevention program elements, in accordance with 29 CFR 1910.119 for Process Safety Management and the EPA Risk Management Program pursuant to 40 CFR 68, apply to this production unit.

Processes facility_Processes help link help link  
Process ID15787
Process DescriptionBPU
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)86,000
Process Amount Total (lbs)86,000
Number of Process Chemicals1
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 #8 : 19990622, process #3 : BPU, process chemical #1)
Process Chemical Record ID19655
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)86,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical Record ID519655
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  
Flammable Scenario ID2664
Model UsedEPA's OCA Guidance Reference Tables or Equations
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 #8 : 19990622, process #3 : BPU, process chemical #2, alternate flammable scenario #1)
Flammable Scenario ID2134
Model UsedEPA's OCA Guidance Reference Tables or Equations
Passive Mitigation - DikesNo
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  
Process NAICS ID16181
NAICS Code325199: All Other Basic Organic Chemical Manufacturing
Number of Prevention Program 2 Records0
Number of Prevention Program 3 Records1

Prevention Program 3 facility_Prevention_Program_3 help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622, process #3 : BPU, process NAICS code #1 : 325199, prev. program 3 #1)
Prevention Program ID8166
Safety Info Review Date19990409
PHA Update Date19960813
PHA Technique - What IfYes
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistYes
PHA Technique - HAZOPNo
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date19990630
Hazard Identified - Toxic ReleaseNo
Hazard Identified - FireYes
Hazard Identified - ExplosionYes
Hazard Identified - Runaway ReactionNo
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureNo
Hazard Identified - CorrosionYes
Hazard Identified - OverfillingYes
Hazard Identified - ContaminationNo
Hazard Identified - Equipment FailureNo
Hazard Identified - Cooling LossNo
Hazard Identified - EarthquakeNo
Hazard Identified - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
Process Controls - VentsNo
Process Controls - Relief ValvesYes
Process Controls - Check ValvesNo
Process Controls - ScrubbersNo
Process Controls - FlaresNo
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksYes
Process Controls - AlarmsYes
Process Controls - Keyed BypassNo
Process Controls - Emergency AirNo
Process Controls - Emergency PowerNo
Process Controls - Backup PumpNo
Process Controls - GroundingNo
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksNo
Process Controls - Excess Flow DevicesYes
Process Controls - Quench SystemNo
Process Controls - Purge SystemNo
Process Controls - NoneNo
Mitigation Systems - SprinklersNo
Mitigation Systems - DikesNo
Mitigation Systems - Fire WallsNo
Mitigation Systems - Blast WallsNo
Mitigation Systems - Deluge SystemsNo
Mitigation Systems - Water CurtainsNo
Mitigation Systems - EnclosureNo
Mitigation Systems - NeutralizationNo
Mitigation Systems - NoneNo
Mitigation Systems - OtherFire monitors
Monitoring Systems - Process AreaNo
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneYes
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryNo
Changes Since PHA - Process ParametersNo
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 Date19990428
Training Review Date19990421
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - OtherCBT
Competency Testing - Written TestsYes
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date19990506
Maintenance Inspection Date19990322
Equipment TestedInternal visual inspection of 2-methyl propene tank.
Management of Change Most Recent Date19990409
Management of Change Review Date19981116
Pre-startup Review Date19990416
Compliance Audit Date19971205
Compliance Audit Change Completion Date19990930
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date19990302
Hot Work Review Date19990512
Contractor Safety Review Date19981016
Contractor Safety Eval. Date19990210
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622, process #3 : BPU, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
19655

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
This process covers the BPU production unit only. All of Elf Atochem's prevention program elements, in accordance with 29 CFR 1910.119 for Process Safety Management and the EPA Risk Management Program pursuant to 40 CFR 68, apply to this production unit.

Accidents facility_Accidents help link help link  
Accident ID1428
Accident Date19981106
Accident Time1535
Number of Chemicals1
Flammable Amount Total (lbs)180
Toxic Amount Total (lbs)0
Released Amount Total (lbs)180
Number of Deaths0
Number of Injuries0
Number Evacuated / Sheltered257
Total Property Damage$3,500,000
Environmental DamageNo
NAICS of Process Involved325199: All Other Basic Organic Chemical Manufacturing
Release Duration (HHHMM)1
Release Event - Gas ReleaseNo
Release Event - SpillNo
Release Event - FireNo
Release Event - ExplosionYes
Release Event - ReactionNo
Release Source - Storage VesselNo
Release Source - PipingNo
Release Source - Process VesselYes
Release Source - Transfer HoseNo
Release Source - ValveNo
Release Source - PumpNo
Release Source - JointNo
Wind Speed10
Wind Speed Unitsmiles/h
Wind DirectionE
Temperature50
PrecipitationNo
Unknown WeatherNo
Workers Killed0
Responders Killed0
Public Killed (on-site)0
Workers Injured0
Responders Injured0
Public Injured (on-site)0
Property Damage (on-site)$3,500,000
Off-site Deaths0
Hospitalizations0
Number Requiring Medical Treatment0
Number Evacuated0
Number Sheltered In Place257
Property damage (off-site)$0
Environmental Damage - Fish/Animal KillsNo
Environmental Damage - DefoliationNo
Environmental Damage - Water ContaminationNo
Environmental Damage - Soil ContaminationNo
Initiating EventEquipment Failure
Contributing Factor - Equipment FailureYes
Contributing Factor - Human ErrorNo
Contributing Factor - Improper ProcedureNo
Contributing Factor - OverpressurizationNo
Contributing Factor - Upset ConditionNo
Contributing Factor - By-pass ConditionNo
Contributing Factor - MaintenanceYes
Contributing Factor - Process DesignNo
Contributing Factor - Unsuitable EquipmentNo
Contributing Factor - Unusual WeatherNo
Contributing Factor - Management ErrorNo
Off-site Responders NotifiedNotified Only
Changes Introduced - Improved EquipmentYes
Changes Introduced - Revised MaintenanceYes
Changes Introduced - Revised TrainingYes
Changes Introduced - Operating ProceduresYes
Changes Introduced - Process ControlYes
Changes Introduced - Mitigation SystemsYes
Changes Introduced - Response PlanYes
Changes Introduced - Changed ProcessNo
Changes Introduced - Reduced InventoryNo
Changes Introduced - NoneNo
Confidential Business InformationNo
Total RMP Accident Deaths0
Total RMP Accident Injuries0
Total RMP Accident Evacuated/Sheltering In Place0
Total RMP Accident Property Damage$0

Accident Chemicals facility_Accident_Chemicals help link help link (Facility #1 : Arkema Inc. - Crosby Plant, RMP submission #8 : 19990622, accident #1, accident chemical #1)
Accident Chemical Record ID1520
Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Amount Released (lbs)180
Number of Flammable Components0

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 Date19990503
Response Training Date19990427
Local Response AgencyCrosby Volunteer Fire Department
Local Response Agency Phone2813281000
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


Search Criteria Used
Facility NameARKEMA
Facility CityCROSBY
Facility StateTexas
Sort OrderBy facility name

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