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Rohm and Haas Texas Incorporated

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Facility #1 : Rohm And Haas Texas Incorporat


Basic Facility Info facility_Basic_Facility_Info help link help link  
Facility ID100000084954
Deregistered (Yes/No)No
Facility NameRohm and Haas Texas Incorporated
Street Address Line 11900 Tidal Road
CityDeer Park
StateTX
Zip Code77536
CountyHarris County
113th Congressional DistrictTX36: Texas 36
Owner or Operator NameHarry L. Engelhardt
Parent CompanyRohm and Haas Company
Latitude29.726389
Longitude-095.102778
Number of RMP Submissions4

Most Recent Submission Info facility_Most_Recent_Submission_Info help link help link  
RMP ID1000012621
Submission Typerevised submission for facility
Submission Date03/01/2010
Reason For SubmissionProcess no longer covered (source has other processes that remain covered) (40 CFR 68.190(b)(7))
Process Toxic Amount Total (lbs)110,000
Process Flammable Amount Total (lbs)36,000
Process Amount Total (lbs)146,000
Number of Potential Offsite Consequence Processes3
Potential Offsite Consequence Toxic Amount Total (lbs)110,000
Potential Offsite Consequence Flammable Amount Total (lbs)36,000
Potential Offsite Consequence Amount Total (lbs)146,000
All Process NAICS32511
Exec Summary Submission Date03/01/2010

Executive Summary facility_Executive_Summary help link help link (Facility #1 : Rohm and Haas Texas Incorporat, executive summary: all)

Executive Summary
Executive Summary for Rohm and Haas Texas Incorporated, a wholly owned subsidiary of The Dow Chemical Company

Accidental Release Prevention and Emergency Response

At Rohm and Haas Texas Incorporated, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. The company/corporate policies are embodied in the numerous EHS and Engineering standards which apply globally. At Rohm and Haas Texas, these policies are implemented through the site Safety and Health Manual and site Environmental Manual.

This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:

- A description of our facility and use of substances regulated by EPA's RMP regulation
- Notes relating to our assessment of the potential offsite consequences from accidental chemical releases
- An overview of our accidental release prevention programs
- A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
- An overview of our emergency response program
- An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment
- The certifications that EPA's RMP rule requires us to provide
- The detailed information (called data elements) about our risk management program


Stationary Source and Regulated Substances

Our facility produces acrylic and methacrylic acids and esters using a variety of chemicals and processing operations. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substan
tial accidental release:

Toxic Chemicals:

Ammonia
Ammonia is received by pipeline and stored as a pressurized liquid in a horizontal tank. The quantity is limited by automatic and manual systems to half of the tank's capacity; this is the inventory reported in the Section 1.17. Ammonia is reacted with natural gas and air in the presence of a platinum gauze to produce HCN. It is also used in various neutralization processes around the plant.

Hydrogen Cyanide
HCN is produced by the catalytic reaction of ammonia, natural gas and air over a platinum gauze. It is stored as a refrigerated liquid in two separate, non-connected, widely-separated stainless steel tanks. Normal inventory is limited by policy to 35% of each tank's capacity. For major unit maintenance, the inventory in one tank is increased to 60% of capacity; this was the inventory reported in the Section 1.17. This inventory is quickly used; the tank will be back to the normal level in 2-3 days. The HCN is used as an intermediate in the production of methacrylic acid and its esters, methyl methacrylate and butyl methacrylate.

Chlorine
Chlorine is used in our Battleground Water facility to sanitize process water. The chlorine is stored and used in one ton cylinders.

Flammable Chemicals:

Propylene
Liquid propylene is received into the plant via pipeline, and there is no storage tank. There are two long, interconnected pipelines from the metering station to the process units. The total quantity reported in Section 1.17 is the volume contained in both pipelines and in the vaporizers. Propylene is used to produce acrylic acid via partial oxidation in the presence of a catalyst.


Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.

Key Offsite Consequence Analysis Scenarios

EPA's RMP rule requires that we provide information about
the worst-case release
scenario(s) and alternative release scenario(s) for our facility. The following notes about these scenarios include information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:

Worst-case Release Scenario(s) - Regulated Toxic Chemicals:

Ammonia
The inventory of the tank is limited to 50% of capacity by automatic level controls and the operating procedures. The worst case for ammonia is the release of the entire tank inventory in 10 minutes. This will result in a liquid spill and vaporization and will produce a cloud that does have offsite residential impact. This scenario is unlikely because the tank has 1.5" thick steel walls, is made of stress relieved carbon steel, and is inspected periodically.

Alternative Release Scenario(s) - Regulated Toxic Chemicals:

Ammonia
The Alternative case for ammonia is a 1.5" line leak. This will produce a cloud that will not impact public receptors other than neighboring industrial plants and Tidal road. For the alternative scenario, the Rohm and Haas emergency response system will allow mitigation to begin within 10 minutes. There are remote manual valves available to isolate the release. The pipelines downstream of the ammonia storage tank are equipped with excess flow valves. Fire monitors are available for water curtain in most areas of the plant.

Hydrogen Cyanide
The Alternative case for HCN is a 0.5" line leak into a diked area. This will produce a cloud that will not impact public receptors other than neighboring industrial plants and Tidal road. For the alternative scenario, the Rohm and Haas emergency response system will allow mitigation to begin within 20 minutes. There are HCN detectors in strategic locations throughout the plant and remote manual valves available to isolate the release. Fire monitors are available for water curtain in most areas of the plant.

Chlorine
The Alternative case for chlorine is a 5/8" line
leak. This will produce a cloud that will not impact public receptors other than a neighboring industrial plant. There are automatic shut-off valves which will isolate the cylinders from the feed piping to isolate the release. There are also chlorine detectors in strategic locations.

Worst-case Release Scenario(s) - Regulated Flammable Chemicals:

Propylene
The Worst case release scenario for propylene is a rupture of the pipeline that would release the entire inventory of propylene in 10 minutes, which then ignites. A vapor cloud explosion would result in an overpressure that would affect Tidal road. Depending on the location of the pipeline rupture, off-site effects could occur and affect industrial neighbors. Because the area along most of the pipeline is unconfined, a vapor cloud fire is a more likely scenario.

Alternative Release Scenario(s) - Regulated Flammable Chemicals

Propylene
The alternative case scenario for propylene is a 1" leak in the pipeline. The pipeline is equipped with remotely-operated isolation valves which will shut on low pipeline pressure which will occur upon line rupture or significant leaks. The quantity reported in the alternative scenario assumes the valves will shut and the volume contained in the longest section of the pipeline between the isolation valves will be released. Depending on the location of the leak along the pipeline, this scenario results in overpressure that could affect a portion of Tidal road and could affect one industrial neighbor. Because this area is unconfined, a vapor cloud fire was chosen for the scenario.


We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. All of this information including all details has been shared with the general public in the area and with the Deer Park LEPC. The LEPC uses the information for detailed reviews of the city's emergency response plans.

General Ac
cidental Release Prevention Program and Chemical-Specific Prevention Steps

We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including:

- Process safety information - All of our processes have comprehensive information that is used to guide the choice of process and control technologies, operating parameters, and inspection intervals for equipment such as pipes, vessels, and protective systems.

- Process hazard analysis - All processes have been subjected to a PHA that was at least as rigorous as a HAZOP. These HAZOPs were used to define the scenarios used in this report. The accident scenarios found in HAZOPs form the basis of additional analyses which allow us to ensure that the integrity levels of all protective systems are high enough to protect both our employees and our neighbors. They also help us target the most important equipment for more frequent inspection.

- Operating procedures - Operating procedures include windows for safe operations and guides for trouble shooting which allow operators to keep the processes out of unsafe areas. Operators are involved in writing, reviewing, and updating operating procedures.

- Training - Training is based on the operating instructions. Operators help determine the frequency of refresher training.

- Mechanical integrity - We have a comprehensive inspection and preventive maintenance system that ensures that equipment maintains its capability to contain the process chemicals. This system is being continuously improved.

- Management of change - As an industry pioneer in the management of change, we have a comprehensive, well-institutionalized MOC system. Employees at all levels are involved in the operation of the MOC system.

- Pre-startup review - The Pre-Startup Safety Review (PSSR) is integral to ensuring that any new or modified process is built as intended. It
is the completion of hazard analysis to ensure that the analyses conducted are, indeed applicable to the process as built. PSSRs are part of the institutionalized MOC and PHA systems.

- Compliance audits - Several types of compliance and management system audits are performed. RMP/PSM self-audits are performed every three years. Annual VPP evaluations are conducted. Company/corporate EHS audits are completed every 2 years. Actions needed are entered into a computer-based action tracking system that automatically tells those responsible if completion of action items is taking longer than anticipated, so that remedial steps may be taken.

- Incident investigation - We also pioneered process safety incident investigations using multiple-cause, system-oriented techniques. Many technical papers and presentations came from this work. We continue to investigate process incidents using this technique and other root cause analysis tools so that we can gain all the information from each incident that we can to determine the root cause(s), in order to prevent future incidents and to add to the body of information about each process.

- Employee participation - Employees participate in all aspects of the prevention program. Since 1978, we would not perform a HAZOP unless hourly employees were present. Operators help write operating instructions and perform much of the training for new employees. Operators and mechanics are expected to attend MOC reviews.

- Hot work permit - We have had a very effective Hot Work permit, and safe work permit, system.

- Contractors - Contractors are picked according to stringent standards of management, competence, and safety. Contractors are expected to adhere to the same standards of safety that our own employees do. A monthly management meeting is held to review all contractors' EHS performance.

As part of our prevention efforts, we have implemented the following chemical-specific prevention steps:

Ammonia: Most of the amm
onia piping is all-welded stainless steel from the metering station to the unit. (Carbon steel is considered adequate for ammonia service, but we opted for the more costly choice to eliminate future concerns about external corrosion.) There are two tanks capable of storing ammonia, but only one is in service at any time. This allows maintenance to be performed at leisure on the tank that is out of service. The tanks are made from carbon steel and both are stress-relieved. There are excess-flow check valves in the tank outlets and in the line from the tank to the north end of the plant. These valves will slam shut on major flow increases which would occur upon line rupture or significant leaks.

Hydrogen Cyanide: Where possible, HCN lines are all-welded construction, and all welds are 100% X-rayed. Where flanges are required, we use 300# flanges and spiral-wound gaskets for maximum integrity. Pumps for 100% HCN are magnetic drive pumps which have no seals, and leaks are highly unlikely. HCN detectors are mounted at strategic locations throughout the unit, and provide an excellent warning system. There are evacuation procedures at each HCN unit which are tested and drilled.

Chlorine: The chlorine system feed piping uses a vacuum delivery system. Leaks in the vacuum section of the delivery piping will automatically isolate the feed cylinders. Chlorine detectors are installed in the area surrounding the chlorine system.

Propylene: The propylene lines are welded carbon steel; one is buried, the other is above ground. The buried pipe is coated and wrapped and is cathodically protected. The propylene piping is designed for high pressure and normally operates at less than 20% of the design pressure. The extra capability gives us an inherently safer means of being prepared for pressure surges, but there are also relief valves in the system to prevent damage to the pipelines. There are remotely-operated isolation valves in the line to allow isolation o
f a segment in the event of a leak. These valves will shut automatically if a line rupture or significant leaks occurs. There are vehicle barricades to protect above-ground parts of the line. There is no tank, so the only inventory is in the lines themselves. The metering area and the vaporizer system are equipped with propylene detectors.

Note: All lines and vessels have inspection programs tailored to the hazards.

These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.


Five-Year Accident History

We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years:
Ammonia - There has been one (1) release of ammonia that met the criteria for the Five-Year Accident History.
Hydrocyanic Acid - There have been no releases of HCN that met the criteria for the Five-Year Accident History.
Chlorine - There have been no releases of chlorine that met the criteria for the Five-Year Accident History.
Propylene - There have been no releases of propylene that met the criteria for the Five-Year Accident History.

Emergency Response Program
We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Our responders are trained in fire fighting at Texas A&M University fire school, and also in Hazardous Material response techniques. Furthermore, we coordi
nate our plan with the community emergency response plan.

Planned Changes to Improve Safety
The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases:

At the present time there are no significant safety improvements planned for the Rohm and Haas Texas site.

Certifications
Within the past five years, the processes which have had no accidental release that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the processes, entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMPlan. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true accurate, and complete.

For all other covered processes, the undersigned also certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RMPlan is true, accurate, and complete.

Printed Name: Tamara Coppens
Title: Responsible Care Leader
Date: February 26, 2010

RMP Data Elements
The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows:

- Registration
- Offsite consequence analysis
- Five-year accident history
- Program 2 prevention program
- Program 3 prevention program
- Emergency response program
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees740
Owner or Operator NameHarry L. Engelhardt
Owner or Operator Address Line 11900 Tidal Road
Owner or Operator CityDeer Park
Owner or Operator StateTX
Owner or Operator Zip77536
Parent Dun and Bradstreet Number2292043
Second Parent Dun and Bradstreet Number0
Number of Full Time Employees740
Number of FTE CBI FlagNo
Other Facility IDTXD065096273
Covered by OSHA PSM StandardYes
Covered by EPCRA Section 302Yes
Covered by CAA Title VYes
CAA Title V Air Operating Permit IDO-02232,33,36
Last Safety Inspection Date11/26/2007
Last Safety Inspection ByOSHA
OSHA Star or Merit RankingYes
LEPC NameHarris County-Deer Park Area L

Submission - Contact Info facility_Submission_-_Contact_Info help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01)
Owner or Operator Phone2812288204
Facility URLwww.dow.com
Facility Phone2812288217
Facility Emaildarrelldavis@dow.com
Facility Dun and Bradstreet Number65096273
RMP ContactThomas J. Stang
RMP Contact TitleEHS Specialist
RMP Contact Emailtstang@dow.com

Submission - Additional Info facility_Submission_-_Additional_Info help link help link  
RMP Complete FlagYes
Predictive FilingNo
No RMP Accidents Last 5 YearsNo
Complete Check Date03/01/2010
Postmark Date03/01/2010
Anniversary Date03/01/2015
Confidential Business InformationNo

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01)
Latitude29.726389
Longitude-095.102778
Valid Lat/LongYes
Lat/Long MethodClassical Surveying Techniques
Lat/Long Location TypeCenter of Facility
FRS Latitude29.72
FRS Longitude-95.1
FRS Lat/Long DescriptionCENTER OF FACILITY
FRS Lat/Long MethodCLASSICAL SURVEYING TECHNIQUES

Submission - Counts and Totals facility_Submission_-_Counts_and_Totals help link help link  
Number of RMP Accidents1
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)133
RMP Accident Amount Total (lbs)133
Number of RMP Accidents1
Number of Processes3
Number of Process Chemicals0
Number of Toxic Worst-case Scenarios1
Number of Toxic Alternate Case Scenarios3
Number of Flammable Worst-case Scenarios1
Number of Flammable Alternate Case Scenarios1
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)133
RMP Accident Amount Total (lbs)133
Total RMP Accident Deaths0
Total RMP Accident Injuries1
Total RMP Accident Evacuated/Sheltering In Place0
Total RMP Accident Property Damage$0

Processes facility_Processes help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #1 : Acetone Cyanohydrin Produ)
Process DescriptionAcetone Cyanohydrin Produ
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)101,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)101,000
Number of Process Chemicals0
Number of Toxic Worst-Case Scenarios1
Number of Toxic Alternate Scenarios2
Number of Flammable Worst-Case Scenarios0
Number of Flammable Alternate Scenarios0

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDAmmonia (anhydrous)
CAS number007664417
Chemical TypeToxic
Process Chemical Amount (lbs)90,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #1 : Acetone Cyanohydrin Produ, process chemical #2)
Process Chemical IDHydrocyanic acid
CAS number000074908
Chemical TypeToxic
Process Chemical Amount (lbs)11,000
Confidential Business InformationNo

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

Worst-Case Toxic Scenarios facility_Worst-Case_Toxic_Scenarios help link help link  
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
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 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #1 : Acetone Cyanohydrin Produ, process chemical #3, alternate toxic scenario #1)
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
Wind Speed3
Atmospheric Stability ClassD
TopographyUrban
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 ShutdownNo
Active Mitigation - OtherRemote shutoff valves
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #1 : Acetone Cyanohydrin Produ, process chemical #4)
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link  
Physical StateGas liquified by refrigeration
Model UsedEPA's RMP*Comp(TM)
Wind Speed3
Atmospheric Stability ClassD
TopographyUrban
Passive Mitigation - DikesYes
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 ValvesNo
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownYes
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #1 : Acetone Cyanohydrin Produ, process NAICS code #1 : 32511)
NAICS Code32511: Petrochemical Manufacturing

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date02/06/2007
PHA Update Date02/06/2007
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date08/19/2008
Hazard Identified - Toxic ReleaseYes
Hazard Identified - FireYes
Hazard Identified - ExplosionNo
Hazard Identified - Runaway ReactionNo
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
Process Controls - VentsYes
Process Controls - Relief ValvesYes
Process Controls - Check ValvesYes
Process Controls - ScrubbersNo
Process Controls - FlaresYes
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksYes
Process Controls - AlarmsYes
Process Controls - Keyed BypassYes
Process Controls - Emergency AirYes
Process Controls - Emergency PowerYes
Process Controls - Backup PumpYes
Process Controls - GroundingYes
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 water spray available
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 DetectionNo
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Changes Since PHA - Otherinstrument upgrades, procedure review, heat exchanger replacement, re-coating pipeline
Procedure Review Date01/21/2010
Training Review Date03/20/2009
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - OtherComputer Based Training (CBT) for chemical hazards and interlocks
Competency Testing - Written TestsYes
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Competency Testing - OtherCBT exams
Maintenance Review Date11/03/2008
Maintenance Inspection Date11/25/2009
Equipment TestedAmonnia Vaporizer (external)
Management of Change Most Recent Date10/05/2009
Management of Change Review Date09/01/2008
Pre-startup Review Date03/31/2008
Compliance Audit Date11/26/2007
Compliance Audit Change Completion Date05/26/2008
Incident Investigation Date01/12/2010
Incident Invest. Change Completion Date07/12/2010
Participation Plan Review Date02/15/2010
Hot Work Review Date09/01/2009
Contractor Safety Review Date12/01/2009
Contractor Safety Eval. Date02/01/2010
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #1 : Acetone Cyanohydrin Produ, process NAICS code #1 : 32511, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
1000018475

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  

Prevention Program Description
Acetone Cyanohydrin Production
Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date12/10/2008
PHA Update Date12/10/2008
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date12/10/2010
Hazard Identified - Toxic ReleaseYes
Hazard Identified - FireYes
Hazard Identified - ExplosionYes
Hazard Identified - Runaway ReactionYes
Hazard Identified - PolymerizationYes
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 - HurricaneYes
Process Controls - VentsYes
Process Controls - Relief ValvesNo
Process Controls - Check ValvesYes
Process Controls - ScrubbersNo
Process Controls - FlaresYes
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksYes
Process Controls - AlarmsYes
Process Controls - Keyed BypassYes
Process Controls - Emergency AirYes
Process Controls - Emergency PowerYes
Process Controls - Backup PumpYes
Process Controls - GroundingYes
Process Controls - Inhibitor AdditionYes
Process Controls - Rupture DisksYes
Process Controls - Excess Flow DevicesNo
Process Controls - Quench SystemNo
Process Controls - Purge SystemYes
Process Controls - NoneNo
Mitigation Systems - SprinklersNo
Mitigation Systems - DikesYes
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 water spray available for both tanks, one tank has deluge
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Monitoring Systems - OtherPersonal HCN detectors
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryNo
Changes Since PHA - Process ParametersYes
Changes Since PHA - Process ControlsNo
Changes Since PHA - Process DetectionNo
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Changes Since PHA - Otherother operability and procedure changes, valve upgrades
Procedure Review Date03/26/2009
Training Review Date03/20/2009
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - OtherCBT for chemical hazards, interlocks, and emergency response
Competency Testing - Written TestsYes
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Competency Testing - OtherCBT exams
Maintenance Review Date11/03/2008
Maintenance Inspection Date10/06/2009
Equipment TestedHCN Distillation Condenser (internal)
Management of Change Most Recent Date09/26/2008
Management of Change Review Date09/01/2008
Pre-startup Review Date08/01/2006
Compliance Audit Date11/26/2007
Compliance Audit Change Completion Date05/26/2008
Incident Investigation Date05/07/2009
Incident Invest. Change Completion Date09/03/2009
Participation Plan Review Date02/15/2010
Hot Work Review Date09/01/2009
Contractor Safety Review Date12/01/2009
Contractor Safety Eval. Date02/01/2010
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #1 : Acetone Cyanohydrin Produ, process NAICS code #1 : 32511, prev. program 3 #2, prev. program 3 chemical: all)
Process Chemical Record ID
1000018476

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
Acetone Cyanohydrin Production

Processes facility_Processes help link help link  
Process DescriptionAcrylic Acid Production
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)36,000
Process Amount Total (lbs)36,000
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 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #2 : Acrylic Acid Production, process chemical #1)
Process Chemical IDPropylene [1-Propene]
CAS number000115071
Chemical TypeFlammable
Process Chemical Amount (lbs)36,000
Confidential Business InformationNo

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

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

Alternate Case Flammable Scenarios facility_Alternate_Case_Flammable_Scenarios help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #2 : Acrylic Acid Production, process chemical #2, alternate flammable scenario #1)
Model UsedEPA's RMP*Comp(TM)
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 ValvesNo
Active Mitigation - OtherAutomatic shutoff valves which close on low pipeline pressure
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link  
NAICS Code32511: Petrochemical Manufacturing

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date11/12/2008
PHA Update Date11/12/2008
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date11/12/2010
Hazard Identified - Toxic ReleaseNo
Hazard Identified - FireYes
Hazard Identified - ExplosionYes
Hazard Identified - Runaway ReactionNo
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureYes
Hazard Identified - CorrosionYes
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 - HurricaneYes
Process Controls - VentsYes
Process Controls - Relief ValvesYes
Process Controls - Check ValvesYes
Process Controls - ScrubbersNo
Process Controls - FlaresYes
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksYes
Process Controls - AlarmsYes
Process Controls - Keyed BypassYes
Process Controls - Emergency AirNo
Process Controls - Emergency PowerYes
Process Controls - Backup PumpNo
Process Controls - GroundingYes
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksNo
Process Controls - Excess Flow DevicesNo
Process Controls - Quench SystemNo
Process Controls - Purge SystemNo
Process Controls - NoneNo
Process Controls - OtherRelief valves (dual to allow testing)
Mitigation Systems - SprinklersYes
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 - OtherSprinkler system in vaporizer area only; fire monitors available in some pipeline areas
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Monitoring Systems - OtherCameras monitoring vaporizer and metering station areas
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryNo
Changes Since PHA - Process ParametersNo
Changes Since PHA - Process ControlsNo
Changes Since PHA - Process DetectionNo
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Changes Since PHA - Otherincrease monitoring of some double-wall pipe, procedure updates, valve upgrades
Procedure Review Date10/09/2009
Training Review Date05/15/2009
Type of Training - ClassroomYes
Type of Training - On the JobYes
Type of Training - OtherCBT for chemical hazards and emergency response
Competency Testing - Written TestsYes
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Competency Testing - OtherCBT exam
Maintenance Review Date11/03/2008
Maintenance Inspection Date02/15/2010
Equipment TestedPropylene vaporizer
Management of Change Most Recent Date02/05/2010
Management of Change Review Date09/01/2008
Pre-startup Review Date02/05/2010
Compliance Audit Date11/27/2007
Compliance Audit Change Completion Date05/26/2008
Incident Investigation Date03/25/2009
Incident Invest. Change Completion Date11/30/2009
Participation Plan Review Date02/15/2010
Hot Work Review Date09/01/2009
Contractor Safety Review Date12/01/2009
Contractor Safety Eval. Date02/01/2010
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #2 : Acrylic Acid Production, process NAICS code #1 : 32511, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
1000018478

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
Acrylic Acid Production

Processes facility_Processes help link help link  
Process DescriptionBattleground Water
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)9,000
Flammable Amount Total (lbs)0
Process Amount Total (lbs)9,000
Number of Process Chemicals0
Number of Toxic Worst-Case Scenarios0
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 (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #3 : Battleground Water, process chemical #1)
Process Chemical IDChlorine
CAS number007782505
Chemical TypeToxic
Process Chemical Amount (lbs)9,000
Confidential Business InformationNo

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

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link  
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
Wind Speed3
Atmospheric Stability ClassD
TopographyUrban
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 ValvesNo
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownNo
Active Mitigation - OtherAutomatic shutoff valves which close on high pipe pressure (vacuum delivery)
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #3 : Battleground Water, process NAICS code #1 : 32511)
NAICS Code32511: Petrochemical Manufacturing

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date08/24/2007
PHA Update Date08/24/2007
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date06/30/2008
Hazard Identified - Toxic ReleaseYes
Hazard Identified - FireNo
Hazard Identified - ExplosionNo
Hazard Identified - Runaway ReactionNo
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureNo
Hazard Identified - CorrosionYes
Hazard Identified - OverfillingNo
Hazard Identified - ContaminationYes
Hazard Identified - Equipment FailureNo
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeNo
Hazard Identified - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneYes
Process Controls - VentsNo
Process Controls - Relief ValvesNo
Process Controls - Check ValvesYes
Process Controls - ScrubbersNo
Process Controls - FlaresNo
Process Controls - Manual ShutoffsNo
Process Controls - Auto ShutoffsYes
Process Controls - InterlocksYes
Process Controls - AlarmsYes
Process Controls - Keyed BypassNo
Process Controls - Emergency AirYes
Process Controls - Emergency PowerNo
Process Controls - Backup PumpNo
Process Controls - GroundingNo
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksNo
Process Controls - Excess Flow DevicesNo
Process Controls - Quench SystemNo
Process Controls - Purge SystemNo
Process Controls - NoneNo
Process Controls - Othervacuum delivery
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 - Otherarea chlorine detectors high alarm and high pressure in delivery system shut supply RCVs
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryNo
Changes Since PHA - Process ParametersNo
Changes Since PHA - Process ControlsNo
Changes Since PHA - Process DetectionNo
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Changes Since PHA - Otherprocedure updates
Procedure Review Date11/13/2009
Training Review Date11/07/2008
Type of Training - ClassroomYes
Type of Training - On the JobYes
Competency Testing - Written TestsYes
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationYes
Competency Testing - ObservationYes
Maintenance Review Date11/03/2008
Maintenance Inspection Date05/22/2009
Equipment Testedchlorine bottle rack, system PM in 4th qtr 2009
Management of Change Most Recent Date07/17/2007
Management of Change Review Date09/01/2008
Compliance Audit Date11/26/2007
Compliance Audit Change Completion Date05/26/2008
Participation Plan Review Date02/15/2010
Hot Work Review Date09/01/2009
Contractor Safety Review Date12/01/2009
Contractor Safety Eval. Date02/01/2010
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, process #3 : Battleground Water, process NAICS code #1 : 32511, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
1000018479

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description
Battleground Water

Accidents facility_Accidents help link help link  
Accident Date01/15/2010
Accident Time1615
Number of Chemicals1
Flammable Amount Total (lbs)0
Toxic Amount Total (lbs)133
Released Amount Total (lbs)133
Number of Deaths0
Number of Injuries1
Number Evacuated / Sheltered0
Total Property Damage$0
Environmental DamageNo
NAICS of Process Involved32511: Petrochemical Manufacturing
Release Duration (HHHMM)00423
Release Event - Gas ReleaseYes
Release Event - SpillNo
Release Event - FireNo
Release Event - ExplosionNo
Release Event - ReactionNo
Release Source - Storage VesselNo
Release Source - PipingNo
Release Source - Process VesselNo
Release Source - Transfer HoseNo
Release Source - ValveNo
Release Source - PumpNo
Release Source - JointNo
Release Source - OtherFlare
Wind Speed12
Wind Speed Unitsmiles/h
Wind DirectionESE
Temperature50
Atmospheric Stability ClassD
PrecipitationNo
Unknown WeatherNo
Workers Killed0
Responders Killed0
Public Killed (on-site)0
Workers Injured1
Responders Injured0
Public Injured (on-site)0
Property Damage (on-site)$0
Off-site Deaths0
Hospitalizations0
Number Requiring Medical Treatment0
Number Evacuated0
Number Sheltered In Place0
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 - MaintenanceNo
Contributing Factor - Process DesignNo
Contributing Factor - Unsuitable EquipmentNo
Contributing Factor - Unusual WeatherNo
Contributing Factor - Management ErrorNo
Contributing Factor - OtherLoss of power to control system, process failed to safe state
Off-site Responders NotifiedNo, not notified
Changes Introduced - Improved EquipmentNo
Changes Introduced - Revised MaintenanceNo
Changes Introduced - Revised TrainingNo
Changes Introduced - Operating ProceduresYes
Changes Introduced - Process ControlNo
Changes Introduced - Mitigation SystemsNo
Changes Introduced - Response PlanNo
Changes Introduced - Changed ProcessNo
Changes Introduced - Reduced InventoryNo
Changes Introduced - NoneNo
Changes Introduced - OtherUpgraded power supply alarm and inspection/maintenance systems. Initiated LOPA for flare system failures
Total RMP Accident Deaths0
Total RMP Accident Injuries1
Total RMP Accident Evacuated/Sheltering In Place0
Total RMP Accident Property Damage$0

Accident Chemicals facility_Accident_Chemicals help link help link (Facility #1 : Rohm and Haas Texas Incorporat, RMP submission #1 : 2010-03-01, accident #1, accident chemical #1)
Chemical IDAmmonia (anhydrous)
CAS number007664417
Chemical TypeToxic
Amount Released (lbs)133
Percent Weight (Within Mixture)100

Emergency Response Plan Info facility_Emergency_Response_Plan_Info help link help link  
Facility In Community PlanYes
Facility Own Response PlanYes
Specific Facility Response PlanYes
Inform. Procedures in Response PlanYes
Emergency Care in Response PlanYes
Plan Review Date09/19/2009
Response Training Date11/30/2009
Local Response AgencyDeer Park LEPC
Local Response Agency Phone2814791511
Subject To - OSHA EAPYes
Subject To - OSHA HAZWOPERYes
Subject To - CWAYes
Subject To - RCRAYes
Subject To - OPANo
Subject To - State EPCRAYes
Subject To - OtherClean Air Act


Search Criteria Used
RMP Facility ID100000084954

*END OF REPORT*