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Covestro- Baytown

Parent Companies:
Covestro LLC
EPA Facility ID:
100000059287
Other ID:
77520MBYCR8500W
Facility DUNS:
112118117
Parent Company DUNS:
64960248

Location:

Address:
8500 West Bay Rd
Baytown, TX 77523
County:
CHAMBERS
Lat / Long:
29.760, -94.907 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Covestro LLC
Phone:
(281) 383-6000
Address:
8500 West Bay Rd
Baytown, TX 77523 -9730
Foreign Address:

Person responsible for RMP implementation:

Name:
Neil Maxson
Title:
Process Safety Manager

Emergency contact:

Name:
Ken Hall
Title:
Emergency Response Specialist
Phone:
(281) 383-6667
24-hour phone:
(281) 383-6380
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Baytown (Texas) LEPC/EMO
Full-Time Equivalent Employees:
1,012
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
CI-0016-S
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 14, 2015
Inspecting Agency:
OSHA
Using Predictive Filing:
No

Processes:

Manufacturing
RMP ID:
1000045546
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
47,000
No
Phosgene [Carbonic dichloride]
75-44-5
120,000
No
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
21,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Manufacturing
RMP ID:
1000045547
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
19,000
No
Phosgene [Carbonic dichloride]
75-44-5
6,300
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Manufacturing
RMP ID:
1000045548
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
30,000
No
Phosgene [Carbonic dichloride]
75-44-5
10,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Manufacturing
RMP ID:
1000045549
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-]
26471-62-5
25,000,000
No
Public OCA Chemical
0
No
Manufacturing
RMP ID:
1000045550
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
130,000
No
Phosgene [Carbonic dichloride]
75-44-5
150,000
No
Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-]
26471-62-5
4,000,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Manufacturing
RMP ID:
1000045551
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Formaldehyde (solution)
50-00-0
590,000
No
Public OCA Chemical
0
No
Manufacturing
RMP ID:
1000045552
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
17,000,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
May 8, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000037199

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Manufacturing)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Manufacturing)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Manufacturing)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Scrubbers
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
Public OCA Chemical (in Manufacturing)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Concrete Pad with Curb
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Manufacturing)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
  • Neutralization
  • Scrubbers
  • Emergency shutdown
not considered:
  • Water curtain
  • Excess flow valve
  • Flares
Public OCA Chemical (in Manufacturing)
CBI claimed:
No
Percent weight:
37.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
  • Emergency shutdown
not considered:
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Manufacturing)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
  • Neutralization
  • Scrubbers
  • Emergency shutdown
not considered:
  • Water curtain
  • Excess flow valve
  • Flares

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

Sept. 26, 2006 at 11:21
ID:
1000030756
NAICS:
Plastics Material and Resin Manufacturing (325211)
Duration:
2 hours and 26 minutes
Chemicals involved:
  • Ammonia (anhydrous)
Release events:
Uncontrolled/runaway reaction
Weather conditions at time of event
Wind speed:
5.0999999 miles/h ENE
Temperature:
78.00 ℉
Atmospheric stability:
B
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
39
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$25000000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Overpressurization
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised training
  • Revised operating procedures
  • New process controls
  • New mitigation systems
  • Changed process

7. Prevention: Program level 3

Manufacturing, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000039722
Safety Review Date
Dec. 9, 2013
PHA Update Date
Dec. 9, 2013
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Aug. 26, 2013
Training Review Date
May 9, 2012
Maintenance Review Date
Feb. 25, 2013
Maintenance Inspection Date
Aug. 6, 2013
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 30, 2013
Management of Change Review Date
July 3, 2013
Pre-startup Review Date
Dec. 19, 2013
Compliance Audit Date
Nov. 20, 2012
Compliance Audit Change Completion Date
Dec. 26, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Dec. 30, 2013
Hot Work Review Date
May 6, 2013
Contractor Safety Review Date
May 4, 2011
Contractor Safety Eval. Date
May 2, 2013
Manufacturing, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000039718
Safety Review Date
Dec. 19, 2011
PHA Update Date
Dec. 19, 2011
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
Procedure Review Date
April 29, 2014
Training Review Date
Aug. 26, 2011
Maintenance Review Date
Jan. 29, 2013
Maintenance Inspection Date
Sept. 26, 2013
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 10, 2013
Management of Change Review Date
July 3, 2013
Pre-startup Review Date
Aug. 14, 2013
Compliance Audit Date
Nov. 20, 2012
Compliance Audit Change Completion Date
Dec. 26, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Dec. 30, 2013
Hot Work Review Date
May 6, 2013
Contractor Safety Review Date
May 4, 2011
Contractor Safety Eval. Date
May 2, 2013
Manufacturing, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000039719
Safety Review Date
Jan. 7, 2013
PHA Update Date
Jan. 7, 2013
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
Competency Testing
  • Written Test
  • Oral Test
Procedure Review Date
March 31, 2014
Training Review Date
March 18, 2013
Maintenance Review Date
Jan. 22, 2013
Maintenance Inspection Date
Feb. 9, 2012
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 12, 2013
Management of Change Review Date
July 3, 2013
Pre-startup Review Date
Sept. 26, 2013
Compliance Audit Date
Nov. 20, 2012
Compliance Audit Change Completion Date
Dec. 26, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Dec. 30, 2013
Hot Work Review Date
May 6, 2013
Contractor Safety Review Date
May 4, 2011
Contractor Safety Eval. Date
May 2, 2013
Manufacturing, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000039720
Safety Review Date
March 26, 2012
PHA Update Date
March 26, 2012
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Oral Test
Procedure Review Date
Nov. 19, 2013
Training Review Date
March 6, 2013
Maintenance Review Date
Feb. 25, 2013
Maintenance Inspection Date
Dec. 10, 2011
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 3, 2013
Management of Change Review Date
July 3, 2013
Pre-startup Review Date
Oct. 9, 2013
Compliance Audit Date
Nov. 20, 2012
Compliance Audit Change Completion Date
Dec. 26, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Dec. 30, 2013
Hot Work Review Date
May 6, 2013
Contractor Safety Review Date
May 4, 2011
Contractor Safety Eval. Date
May 2, 2013
Manufacturing, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000039721
Safety Review Date
Dec. 30, 2010
PHA Update Date
Dec. 30, 2010
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • None
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Neutralization
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Controls
  • Process Detection
Training Type
  • Classrom
Competency Testing
  • Written Test
Procedure Review Date
Dec. 10, 2013
Training Review Date
July 30, 2012
Maintenance Review Date
Feb. 25, 2013
Maintenance Inspection Date
March 13, 2013
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 4, 2013
Management of Change Review Date
July 3, 2013
Pre-startup Review Date
Nov. 5, 2013
Compliance Audit Date
Nov. 20, 2012
Compliance Audit Change Completion Date
Dec. 26, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Dec. 30, 2013
Hot Work Review Date
May 6, 2013
Contractor Safety Review Date
May 4, 2011
Contractor Safety Eval. Date
May 2, 2013
Manufacturing, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000039723
Safety Review Date
May 6, 2013
PHA Update Date
May 6, 2013
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • None
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Nov. 5, 2013
Training Review Date
March 6, 2013
Maintenance Review Date
Feb. 25, 2013
Maintenance Inspection Date
Sept. 8, 2012
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 18, 2013
Management of Change Review Date
July 3, 2013
Pre-startup Review Date
Dec. 18, 2013
Compliance Audit Date
Nov. 20, 2012
Compliance Audit Change Completion Date
Dec. 26, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Dec. 30, 2013
Hot Work Review Date
May 6, 2013
Contractor Safety Review Date
May 4, 2011
Contractor Safety Eval. Date
May 2, 2013
Manufacturing, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000043206
Safety Review Date
May 12, 2010
PHA Update Date
May 12, 2010
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Overpressurization
  • Corrosion
  • Overfilling
Process Controls
  • Relief Valves
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
Mitigation Systems
  • Sprinkler System
  • Dikes
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
Procedure Review Date
May 29, 2013
Training Review Date
May 16, 2013
Maintenance Review Date
July 23, 2013
Maintenance Inspection Date
Nov. 18, 2013
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 27, 2013
Management of Change Review Date
July 3, 2013
Pre-startup Review Date
Dec. 30, 2013
Compliance Audit Date
Nov. 20, 2013
Compliance Audit Change Completion Date
Dec. 26, 2014
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Dec. 30, 2013
Hot Work Review Date
May 6, 2013
Contractor Safety Review Date
May 4, 2011
Contractor Safety Eval. Date
May 2, 2013

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Dec. 20, 2013
Local Response Agency:
Local Response Agency Phone:
(281) 420-6558
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Covestro- Baytown Executive Summary



Accident Release Prevention

Covestro Baytown site has the responsibility to protect the environment as well as the health and safety of its employees, facility, customers and surrounding communities. Our employees strive for safety, health, and environmental excellence in all aspects of Covestro's activities while meeting our business objectives.

Without exception, every Covestro employee is responsible for working safely. Safety is the top responsibility at all levels of management and supervision. Managers and supervisors are expected to set an example with their own behavior. The design, operation, maintenance, and regular inspections of Covestro facilities safeguard employees and the public. Covestro works to make its operations safer by continually improving safety and health measures.



The Corporate Policy on Health, Safety, Environment and Quality states:

"At Covestro, it is our core belief that safety, environmental protection, product and process quality and commercial efficiency are factors of equal importance in achieving our corporate objectives. Consequently, we respect and support the objectives of Responsible Care and Sustainable Development as a commitment for management and as a responsibility shared by each employee."

Employees and management have confirmed this dedication through the adoption and implementation of a Code of Conduct which states, among other safety objectives, "Code of Conduct is my agreement and commitment to keep myself and my coworkers safe and to protect the environment."

"Responsible Care" is a public commitment to which the Covestro Baytown Industrial Park actively supports as a member of the American Chemical Council. Responsible Care focuses on continuous improvement of health, safety and environmental performance.

Patrick Thomas, Covestro CEO, stated in a recent talk in Baytown, "Nothing you do is worth getting hurt for." The talk was broadcast globally to all Covestro
facilities.



Description of the Facility

Located in West Chambers County on 1,700 acres along Cedar Bayou, Covestro's first operating units came on line in 1971 with steady growth continuing over the next 40+ years. The site doubled its manufacturing capacity between 1997 and 2001 with Covestro's largest-ever capital expansion ($1.4 billion). Known today as an industrial park, approximately 35% of the Covestro acreage is developed. Covestro hosts three guest facilities (Momentive, El Dorado Nitrogen and Texas Brine) to provide raw materials for the facility and one energy center (Calpine Corporation) to produce steam and electricity for the entire complex.

The site is serviced by barge, rail, and truck as well as pipeline service to and from industry along the Houston Ship Channel region.

Primarily supporting the automotive and construction industries, products manufactured by Covestro Baytown include:

? polycarbonate thermoplastic (used in CD/DVDs, auto and optical lenses, medical supplies and sports equipment)

? raw materials for polyurethane foams (used in home and appliance insulation, cushions, and auto trim)

? high-performance coatings (used in automotive, wood, flooring and furniture coatings)

? basic inorganic chemical products, such as chlorine, hydrochloric acid, and caustic, to be used as raw materials in our other processes, and for products for industry



Risk Management Program (RMP)

Covestro Baytown has seven processes covered under RMP. The management team at Covestro Baytown has designated the site as a Process Safety Management site. All processes are covered at the full PSM level and are considered to be Program Level III processes under the scope of Risk Management.

There are six chemicals used in quantities greater than the threshold quantities as defined in the RMP regulations:

? Ammonia

? Chlorine

? Formaldehyde solution (37%)

? Phosgene

? Toluene Diisocyanate (mixed isomer form).

? HCl (Anhydrous Hydrogen Chloride c
ompressed gas)

One other RMP-covered chemical (hydrogen) is used at the Baytown site but does not meet the threshold quantity requirements. No other covered flammable compounds are used at the site.

Management of Risk

The site is covered by Process Safety Management (PSM). PSM (29 CFR 1910.119) is intended to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. The PSM elements are:

Employee Participation:

Employees participate on numerous safety steering committees that potentially affect the work life of each area at the Covestro Baytown site. Action items identified from inspections, incidents, process hazards analyses, etc. are provided to employees for review.

Process Safety Information:

All site personnel have access to the company's electronic mail system and Intranet. Chemical-specific information (Material Safety Data Sheets), operating information, and information on the equipment in the process are easily accessible. The information resides in a controlled electronic system that is updated regularly. All Process Safety Information (PSI) is verified at each scheduled process hazards analysis.

Process Hazards Analysis:

Every five years, process hazards analyses (PHA's) are conducted in each process unit. The HazOp method is used to conduct PHA's. Findings are identified, prioritized, and then promptly corrected. The information is shared with personnel who are impacted by the findings. The action items and completion schedules are available through the electronic follow up, tracking, and closure system. Improvements in process control systems and safeguards are outcomes of the PHA process.

Operating Procedures:

Operating procedures addressing normal and abnormal operating situations are in place and implemented. Deviations from established operating limits and the consequences of these deviations are clearly identified and easily referenced. The procedures are reviewe
d annually to assure accuracy.

Training:

Training on these operating procedures is ongoing to assure operators know and understand the safe operation of their unit and they understand the necessary actions for non-normal situations. Employee training is documented and tracked through a network system. The system allows specific training needs to be identified as well as tracking the completion of required modules.

Contractor Safety:

Control of contractor activity in operating areas is well established. A contractor safety steering committee and the site-wide safety council actively monitors the actions of contractors to assure their safety, the safety of the Covestro facility and its employees is maintained. Contract employees are required to participate annually in comprehensive industry safety training.

Pre-Startup Safety Reviews:

Reviews are conducted of any new facility, major modification, or a change (management of change) before the new system can become operational. Findings are addressed prior to startup.

Mechanical Integrity:

Mechanical integrity procedures are in place to ensure maintenance workers understand how to perform their duties safely to maintain the facility. Specific instructions for testing and inspections are included. Testing and inspections are conducted as scheduled and documented. Maintenance and engineering follow established codes, standards and company guidelines.

Hot Work and Control of Abnormal Activities:

Control of hot work and non-normal situations is conducted to ensure work does not contribute to or cause hazardous results. All aspects of hot work and abnormal situations are controlled. Non-routine work is controlled through multi-disciplinary teams who anticipate what may occur during the execution of the work and prepare appropriate plans to prevent/mitigate the situations.

Management of Change:

The management of change process generates appropriate assessment of possible impacts on the level of safety a
nd health in an area. All impacted documents and procedures are revised as required. Affected personnel are informed regarding changes before they operate the new system.

Incident Investigations:

Incidents, injuries and near-miss situations are investigated. Root causes are identified and documented. Changes in the system are made to prevent recurrence. Incident reports are readily available to assist other areas in preventing similar occurrences. Findings from investigations are followed through implementation and completion.

Compliance Audits:

Baytown conducts site-wide compliance audits every three years of the PSM-RMP program. An audit team made up of hourly employees, supervision, and contractors conduct these audits. Deficiencies are documented and corrected in a timely manner. Open action items are tracked through completion.



Chemical Specific Prevention Programs

At Baytown, accident prevention programs are required in each process. Specific prevention programs include:

Detection Systems:

Detectors are in place for various toxic vapors (phosgene, chlorine, etc.) and for hydrocarbons. Personnel wear dosimeters in the plant. A Leak Detection and Repair (LDAR) program is in place. Personnel conduct audio, visual and olfactory walkthroughs to assure no leaks are occurring.

 



Release Control and Containment:

Systems for emergency scrubbing and emergency vacuum application are in place. Remote-operated valves allow control of systems and processes. Outlets for relief devices are directed to neutralization and/or containment systems. Steam-ammonia curtains surround operating areas for mitigation/ neutralization of possible leaks. Firewater systems are in place for deluge and for high pressure application of fire water.

Release Mitigation Systems:

Trained emergency response personnel are in place and supported by external emergency response organizations. Fire/toxic release suppression and fire extinguishing systems are in pl
ace. Specific areas have deluge systems. Appropriate personal protection equipment is readily available.



Five Year Accident History

The Covestro plant experienced no incident meeting the RMP accident reporting criteria in the past five years.



Emergency Response Program

Covestro Baytown maintains a trained emergency response team on site at all times. Each shift has an emergency response team with up-to-date training. There are emergency medical technicians on each shift and an ambulance and fire truck staged for their immediate use. An auxiliary trailer has additional equipment (air bottles, escape equipment, etc.) for immediate access during emergencies.

The emergency team includes members who have completed requirements for hazard materials (HazMat) response. Equipment for emergency HazMat response use has been prepared and staged at this facility.

There is a designated organization which responds during daytime emergencies and off-shift emergencies. The Emergency Operations Center (EOC) has equipment (maps, warning systems, P&ID drawings, MSDS, etc.) and supplies to direct the response. The EOC is equipped with an emergency response modeling system to estimate the potential effects of a release on other areas of the facility or the community. The EOC maintains lists of personnel to notify during an emergency. The list also includes local emergency response personnel and organizations.

The Covestro Baytown facility is active in the Mutual Aid of Mont Belvieu (MAMB) industry mutual aid organization. The Covestro facility is an active participant in the Baytown Local Emergency Planning Committee (and Baytown Emergency Management Office). All emergency plans have been coordinated with the Baytown LEPC. The Covestro facility has also been involved with the Chambers County LEPC. All RMP plans have been reviewed with both LEPC groups. Community outreach efforts are currently underway in all communities in the vicinity of the Covestro facili
ty. Covestro's role in the community emergency action plan is documented in the community procedures.

The Covestro facility has also been an active participant in the Baytown Citizens Advisory Panel to address concerns of the citizens regarding their proximity to manufacturing sites. The City of Baytown is notified of all plant level alarms as an information source to citizens. Through the East Harris County Manufacturers Association, Covestro participates in recording messages on a CAER line for information and emergency notification purposes. The Covestro facility posts updates for the community in the event of an emergency or significant activity at the Covestro facility.

The Baytown Plant Managers Network represents the manufacturing sector of the Baytown area. Through this organization, a siren system was installed to alert the community.