Respondent owns and operates a facility in Houston, Texas. The Facility processes, handles, and/or stores regulated substances and other extremely hazardous substances, including ethylene and ethylene oxide. The Facility has a number of laboratory and pilot plant processes, including a Reversible Acid Pretreatment Pilot Plant (RAPT PP) and an Ethylene Oxide Pilot Plant (EOPP). On February 15, 2016, Respondent attached the RAPT PP to the emergency flare gas (EFG) header, a waste gas collection system. Respondent previously conducted a purge activity of vessels in the RAPT PP in preparation for commissioning and had left two bleeder valves open on that pilot process. These valves were not closed prior to connecting the RAPT PP to the EFG.
NOTE: this is another situation where a “car-seal” program may have prevented an accident.