DuPont Sabine River Works - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: 
 
DuPont Sabine River Works Plant adheres to corporate policies, which can be summarized as follows: 
 
- All Safety and Environmental incidents are preventable. 
- The Goal is Zero.  Zero injuries and zero incidents. 
 
Corporate policies are embodied in the numerous Safety, Health and Environmental and Engineering Standards, which apply globally.  At Sabine River Works, the policies are implemented through the site Safety, Health and Environmental Manual and Process Safety Management Manual. 
 
FACILITY DESCRIPTION 
 
DuPont Sabine River Works plant is located approximately 2 miles south of the city of Orange, in a rural setting on FM 1006.  The site is located on 1500 acres evenly divided between manufacturing processes, the employee recreation area, and bio-oxidation ponds.  The facility is secured by a chain-link fence, video cameras, controlled entry, and a 24 hour security force. 
 
The site manufactures Nylon Intermediates (hex 
amethylenediamine, and adipic acid) and Ethylene/Ethylene Copolymers. 
 
In the production of these products, the following regulated substances are used as raw materials, intermediates, or byproducts: 
 
- Anhydrous Ammonia 
- Aqueous Ammonia 
- Hydrocyanic Acid (HCN) 
- Vinyl Acetate monomer (VA) 
- 1,3 Butadiene 
- Butane 
- 1-Butene 
- 2-Butene-cis 
- 2-Butene-trans 
- Ethane 
- Ethylene 
- Propane 
- Propylene 
 
WORST-CASE TOXIC RELEASE SCENARIO: 
 
The worst-case release scenario for a toxic chemical is failure of a vinyl acetate barge, with no mitigation assumed.  This release has an off-site impact, as determined by the use of the "RMP*COMP" program.  This release is unlikely due to the double-wall construction and high-integrity design of the barge and associated unloading equipment. 
 
WORST-CASE FLAMMABLE RELEASE SCENARIO: 
 
The worst-case release scenario for a flammable chemical is failure of a mixed butene storage tank, with no mitigation.  This release, if ignited, would have an off-site impa 
ct, as determined by the use of the "RMP*COMP" program.  The ignition of this release is unlikely because the tank is located in a remote location versus normal ignition sources.  A tank failure is unlikely due to the high-integrity design, 100% X-raying of all welds during construction, and mechanical integrity program. 
 
ALTERNATIVE TOXIC RELEASE SCENARIOS: 
 
Anhydrous ammonia - A pipe leak in the Anhydrous Ammonia transfer piping was assumed, with a 60-minute duration.  No mitigation was assumed.  This release has an off-site residential, recreational, and industrial impact, as determined by the use of the "RMP*COMP" program 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 recreational but no impact on r 
esidential populations, as determined by the use of the "RMP*COMP" program and the "Landview" program census data. 
 
Hydrocyanic Acid (HCN) - A pipe leak in the HCN transfer 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 as determined by the use of the "RMP*COMP" program and the "Landview" program census data. 
 
Vinyl acetate monomer (VA) - A vessel leak in the Vinyl Acetate Barge was assumed.  A release duration of 60 minutes was assumed because of the flammable nature of the chemical.  This release has an off-site recreational but no impact on residential populations as determined by the use of the "RMP*COMP" program and the "Landview" program census data. 
 
ALTERNATIVE FLAMMABLE RELEASE SCENARIO: 
 
Mixed Butenes - A pipe leak in the mixed Butenes transfer piping was assumed.  Because of the possibly remote location, a release duration of 60 minutes was assumed.  No mi 
tigation was assumed.  This release has an off-site recreational impact but no impact on residential populations as determined by the use of the "RMP*COMP" program and the "Landview" program census data. 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS: 
 
The DuPont Sabine River Works processes 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 Safely... 
- 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 relase of any of the regulated chemicals (Anhydrous Ammonia, Aqueous Ammonia, Hydrocyanic Acid, Vinyl Acetate monomer, Butadiene, Butane, 1-Butene, 2-Butene-cis, 2-Butene-trans, Ethane, 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 Orange County 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. 
- The Community Alert system is sounded. 
- Community emergency responders are notified as appropriate. 
 
PLANNED CHANGES TO IMPROVE SAFETY: 
 
7 Installing state-of-the-art flammable gas detectors in Ethylene Copolymers. 
7 Continued focus on the "The Goal is Zero" for injuries and incidents. 
7 Training in "Operational Discipline" for all process-related employees.
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