Du Pont Victoria Plant - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The DuPont Victoria Plant adheres to Corporate policies, which could be summarized as follows: - All Safety and Environmental incidents are preventable. - The Goal is Zero - Zero Incidents, Period. - All employees and contractors are responsible for their safety. The Corporate policies are embodied in the numerous SHE and Engineering Standards, which apply globally. At the Victoria Plant, the policies are implemented through the Victoria Plant Safety, Health and Environmental (SHE) Manual. This manual is available to all employees through hard copies or the plantwide "Active Learner" computer system. The 800 series of procedures in particular deals with the Process Safety Management Requirements. In addition, the Victoria Plant Emergency Manual lays out the complete Emergency Response program for the site. FACILITY DESCRIPTION The DuPont Victoria Plant consists of 4500 acres, located approximately 9 mi les south of the city of Victoria, in a rural setting south of SH 185. About 1000 acres of the property are used for manufacturing areas, 100 acres for bio-treatment and wetlands, and the remainder is set aside for wildlife habitat and future manufacturing needs. The site consists of 2 manufacturing processes: * Nylon Intermediates (hexamethylenediamine, adipic acid, and dodecanedioic acid). * Ethylene Copolymers (low-density Polyethylene resins). In the production of these products, the following regulated substances are used as raw materials or intermediates (except for minor transfer of ethylene waste streams to another on-site company): - Anhydrous Ammonia - Aqueous Ammonia - Hydrocyanic Acid (HCN) - Vinyl Acetate monomer (VA) - 1,3 Butadiene - Ethylene - Propane - Propylene WORST-CASE TOXIC RELEASE SCENARIO The worst-case release scenario for a toxic chemical is failure of an anhydrous ammonia storage tank, with no mitigation assumed. This release has an off-site impact, as determined by the use of the OCA Guidance. This release is unlikely due to the double-wall construction and high-integrity design of the tank and associated equipment. WORST-CASE FLAMMABLE RELEASE SCENARIO The worst-case release scenario for a flammable chemical is failure of a butadiene storage sphere, with no mitigation assumed. This release, if ignited, would have an off-site impact, as determined by the use of the OCA Guidance. The ignition of this release is unlikely because the contents would be retained within a diked area and because the spheres are located in a remote location versus normal ignition sources. A sphere failure is unlikely due to the high-integrity design and 100% X-raying of all welds during construction. ALTERNATIVE TOXIC RELEASE SCENARIOS * Anhydrous ammonia - A pipe leak in the Anhydrous Ammonia transfer piping was assumed, with a 60 minute duration because of the possibly remote location. These areas are generally not diked , so no mitigation was assumed. This release has an off-site industrial impact, but no impact on residential populations, as determined by the use of the OCA Guidance and the "Landview" program census data. * Aqueous ammonia (20% concentration) - A pipe leak in the Aqueous Ammonia transfer piping was assumed. Per the OCA Guidance for water solutions, a 10 minute release duration was assumed (since the bulk of the toxic will leave the water solution within that time). This release has an off-site industrial impact, but no impact on residential populations, as determined by the use of the OCA Guidance and the "Landview" program census data. * Hydrocyanic Acid (HCN) - A pipe leak in the piping associated with the distillation system was assumed. Because of the highly toxic nature of the material, a release duration of 60 minutes was assumed. This release has an off-site industrial impact, but no impact on residential populations, as determined by the use of the OCA Guidance and t he "Landview" program census data. * Vinyl acetate monomer (VA) - A pipe leak in either the Vinyl Acetate railcar unloading or transfer piping was assumed. A release duration of 60 minutes was assumed because of the flammable nature of the chemical. This release has an off-site industrial impact, but no impact on residential populations, as determined by the use of the OCA Guidance and the "Landview" program census data. ALTERNATIVE FLAMMABLE RELEASE SCENARIO * Butadiene - A pipe leak in the Butadiene transfer piping was assumed. Because of the possibly remote location, a release duration of 60 minutes was assumed. These areas are generally not diked, so no mitigation was assumed. This release has an off-site industrial impact, but no impact on residential populations, as determined by the use of the OCA Guidance and the "Landview" program census data. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The DuPont Victoria Plant process es follow the requirements of DuPont Corporate SHE Standard S21A, "Process Safety Management." This Standard includes and embraces the requirements of 29 CFR 1910.119 and 40 CFR Part 68. Our Safety Programs include: Designing for Safety ... - A documented process technology system covers hazards of materials, equipment design basis, and process design basis. - Extensive accident prevention and mitigation systems are strategically located. - Applicable codes and standards are met or exceeded. - Materials of construction are chosen to provide mechanical integrity. - Quality Assurance ensures fabrication in accordance with design specifications and proper assembly. Maintaining our Plant ... - Maintenance personnel are trained and experienced. - Contractors are trained and qualified. - A work permit system controls hazards. Operating Safety ... - Operators are trained and job qualified. - Technical resources are available and utilized as required. - Operators follow approved procedures. Auditing our Operations ... - Routine safety inspections are conducted. - Corporate, independent and governmental audits and reviews are conducted. - Process Hazards Analyses are conducted. - Safety critical equipment is set up on a periodic inspection frequency to ensure ongoing mechanical integrity. - Pre-startup safety reviews are conducted prior to starting up any new or modified equipment. - Quality assurance of critical equipment ensures fabrication in accordance with design specifications. - All incidents are investigated and actions taken to prevent recurrence. SAFETY IS A JOB REQUIREMENT FOR ALL EMPLOYEES AND CONTRACTORS! THE FIVE-YEAR ACCIDENT HISTORY No deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage has resulted from a release of any of the regulated chemicals (Anhydrous Ammo nia, Aqueous Ammonia, Hydrocyanic Acid, Vinyl Acetate monomer, Butadiene, Ethylene, Propane, Propylene) in the past five years. EMERGENCY RESPONSE PROGRAM Plant personnel are trained and equipped to respond to any releases of the regulated chemicals. The program can be summarized as follows: * Training and Preparation ... - Plant personnel receive emergency response training. - Plant emergency responders are trained. - Emergency response plans are current. - Plant participates in emergency drills. - Critiques are held on drills and actual events. - Plant is a member of the Victoria Local Emergency Planning Committee. * If a Major Release Occurs ... - Emergency alarm is sounded. - Plant Emergency Operating Center is activated. - Plant Incident Commander and emergency squad respond. - Community emergency responders are notified as appropriate. PLANNED CHANGES TO IMPROVE SAFETY * Strengthening several occupied buildings to better withstand pote ntial explosion overpressures. * Installing state-of-the-art flammable gas detectors in Ethylene Copolymers. * Increasing the number of plant emergency drills involving off-site emergency responders. * Continued focus on the "The Goal is Zero" for injuries and incidents. * Training in "Operational Discipline" for all process-related employees. |