Arch Chemicals Inc. - Executive Summary |
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1.0 Accidental Release Prevention and Emergency Response Policies At the Arch Chemicals Brandenburg facility, we are committed to operating and maintaining all of our processes in a safe and responsible manner. A combination of accidental release prevention programs and emergency response planning programs are used to help ensure the safety of our employees and the public as well as protect the environment. As a company, we are committed to excellence in health, safety, and the environment. Arch Chemicals operates under the philosophy that all accidents are preventable all of the time. We recently revitalized this commitment with an ambitious new initiative - "The Goal Is Zero". This initiative is all about striving to achieve zero recordable injuries, zero environmental incidents, zero manufacturing process incidents, and zero distribution incidents. The same dedication to excellence marks our Product Stewardship initiative, under which we address health, safety, and the enviro nment throughout each products' life cycle. The following sections provide a brief overview of the comprehensive risk management activities in practice at the Brandenburg facility. Also attached are the data elements from our risk management program that are required by EPA's RMP rule. 2.0 Stationary Source and Regulated Substances The Arch Chemicals Brandenburg facility is a 220-acre site located east of Brandenburg, Kentucky. The facility is divided into twelve distinct units: Ethylene Oxide, Polysolvs., Light Hydro Carbons (LHC), Polychemicals, Polymer Polyol, Urethane Systems, TDI Terminal, Microelectronics, Pilot Plant, Utilities, and Waste Water Treatment. Primary products of the facility include ethylene oxide, ethylene, propylene glycols, polyether polyols, glycol ethers, and microelectronic chemicals. In our processes, we use the following toxic chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substant ial accidental release: 7 Ethylene Oxide - manufactured at the facility and used in the production of Polysolvs, surfactants and polyol products; maximum quantity handled/stored at the facility is 750,000 pounds. 7 Propylene Oxide - used in the production of Polysolvs, surfactants, and polyol products; maximum quantity handled/stored at the facility is 6,500,000 pounds. 7 Formaldehyde - used in the Microelectronics process for the production of Novolak solutions; maximum quantity handled/stored at the facility is 41,000 pounds. 7 Hydrochloric Acid (>37%) - used in the Microelectronics process for the production of photoactive sensitizers; maximum quantity handled/stored at the facility is 17,200 pounds. 7 Acrylonitrile - used in the Polymer Polyol unit to produce a styrene acrylonitrile polymer dispersion in a polyether polyol; maximum quantity handled/stored at the facility is 165,000 pounds. 7 Ammonia (>20%) - used in Waste Water Treatment unit as a nutrient for activated sludge; maximum quantity handled/stored at the facility is 110,000 pounds. 7 Toluene Diisocyanate - received at the facility in railcars and repackaged into drums, cylinders, and tank trucks for customers; maximum quantity handled/stored at the facility is 800,000 pounds. 7 Ethylenediamine - reacted with ethylene oxide and propylene oxide in Polychemicals unit to produce various polyols; maximum quantity handled/stored at the facility is 40,000 pounds. At the Arch-Brandenburg facility we handle/store three flammable chemicals that are regulated under the EPA Risk Management Program in quantities above the threshold amount. They are: 7 Ethylene - manufactured at the facility and used in the production of ethylene oxide; maximum quantity handled/stored at the facility is 265,000 pounds. 7 Propylene - manufactured at the facility by cracking propane in furnaces; maximum quantity handled/stored at the facility is 420,000 pounds. 7 Propane - used to produce ethylene, propylene, and aromatic dist illate; maximum quantity handled/stored at the facility is 4,000,000 pounds. 3.0 Key Offsite Consequence Analysis Scenarios EPA's RMP rule requires that we provide information about the worst case release scenario and alternate release scenarios for our facility. The following are brief summaries of these scenarios and our assessment of the potential off site consequences from accidental chemical releases, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Toxics: Worst Case Release Scenario Ethylene Oxide: The selected worst case release scenario assumes the failure of a storage tank containing 127,000 pounds of ethylene oxide. The required assumption is that the entire contents of the tank are released in 10 minutes. Upon release the liquid forms a pool which evaporates at a rate of 406 lb/min. Using the EPA OCA tables, urban topography and stipulated meteorology (wind speed of 1.5 m/sec and F st ability class), and passive mitigation measures, the ethylene oxide could travel up to 8.8 miles before dispersing enough to no longer pose a significant hazard to the public. A release of this magnitude could potentially impact area residences and both the Meade County and Harrison County schools. There are no EPA listed receptors within the impact distance. Although unrealistic, this scenario meets the requirements of a release of the largest quantity from a from a vessel that has the potential for the farthest off site impact. Although passive mitigation in the form of dikes were considered for this release scenario, the facility also has sprinkler and deluge systems that would be utilized in a release of this type but were not considered in the consequence analysis. Toxics: Alternate Release Scenario In accordance with the EPA RMP rule, a more credible "alternate" release scenario was considered for each toxic chemical. This scenario is often called the planning scenario beca use we use the information to develop our detailed emergency response plan. While a number of scenarios are considered for each of the chemicals covered by the RMP, only one for each toxic chemical is presented. All scenarios were evaluated using the EPA OCA tables and the stipulated alternate weather conditions of 3.0 m/sec windspeed and D stability class. The alternate release scenarios included in the RMP for the Arch-Brandenburg facility are: Ammonia: The more credible alternate release scenario for ammonia considers the failure of an ammonia process line due to external erosion. Liquid ammonia is spilled to the gravel surface and 116 pounds is released to the air. The release lasts for approximately 20 minutes and travels approximately 0.31 miles before dispersing enough to no longer pose a significant hazard to the public. Potentially impacted public receptors would include the Ohio River. Ethylene Oxide: The more credible alternate release scenario for ethylene oxide consi ders a release from a process safety valve in the polychemical area. Approximately 370 pounds is released to the air in five 30-second lifts. The resulting plume could travel approximately 1.5 miles before dispersing enough to no longer pose a significant hazard to the public. Potentially impacted public receptors would include area residences and the Ohio River. Propylene Oxide: The more credible alternate release scenario for propylene oxide considers a release from a process safety valve in the polychemical area. Approximately 2270 pounds is released to the air at a height of almost fifty feet in five 30-second lifts. The resulting plume could travel approximately 0.8 miles before dispersing enough to no longer pose a significant hazard to the public. Potentially impacted public receptors would include area residences and the Ohio River. Formaldehyde: The more credible alternate release scenario for formaldehyde considers a leak in a 1.5-inch line. The line has isolation va lves at each end which will be manually shut by operators required to oversee all material transfers. Approximately 38 pounds of formaldehyde would be released over a ten minute period. The formaldehyde could travel 0.31 miles before dispersing enough to no longer pose a significant hazard to the public. Potentially impacted public receptors would include the Ohio River. 37% Hydrochloric Acid: An evaluation of credible releases of 37% HCl from the facility produced no scenarios that could potentially result in an offsite impact. The most credible alternate release scenario for 37% HCl considers the puncture of a 55-gallon drum. Approximately 550 pounds of HCl would spill to the ground. The resulting plume could travel 0.04 miles before dispersing enough to no longer pose a significant hazard. Toluene Diisocyanate: The more credible alternate release scenario for toluene diisocyanate (TDI) considers the failure of a pressure relief valve on an incoming railcar. Approximately 100 pounds would be released from the vapor space of the railcar. The resulting plume could travel approximately 0.31 miles before dispersing enough to no longer pose a significant hazard to the public. Potentially impacted public receptors would include Doe Run Creek. Acrylonitrile: The more credible alternate release scenario for acrylonitrile is the rupture of an unloading hose from a tank truck. An operator is always present during truck unloading and would stop the unloading pump in approximately one minute. Approximately 833 pounds of liquid acrylonitrile would be spilled, resulting in a plume that could travel approximately 0.6 miles before dispersing enough to no longer pose a significant hazard to the public. Potentially impacted public receptors would include the Ohio River. Ethylenediamine: An evaluation of credible releases of ethylenediamine (EDA) from the facility produced no scenarios that could potentially result in an offsite impact. The most credible alternate release scenario for EDA considers a transfer hose rupture. Because of shutoff valves at the tank truck and the reactor, only 12 pounds of EDA (the contents of the hose) would be spilled. The resulting plume would travel less than 0.06 miles from the area and would remain onsite. Flammables: Worst Case Release Scenario Propane: The selected worst case scenario for the group of flammable chemicals at the facility considers the release of a series of eight interconnected storage tanks with a total inventory of approximately 2,880,000 pounds of propane. This release would result in a vapor cloud explosion that could sustain a 1 psi overpressure (capable of breaking windows, etc.) at distances up to 1.10 miles. Potentially impacted public receptors would include area residences and the Ohio River. Flammables: Alternate Release Scenario Ethylene: The selected alternate release scenarios for the group of flammable chemicals at the facility considers the release of approximately 20,000 pounds of ethylene from a storage tank within the Ethylene Oxide manufacturing unit. This could result in a vapor cloud fire that could impact distance of 0.06 miles before dispersing to a level below its lower flammability limit. 4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps A systematic, proactive approach is taken to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs, including: 7 Employee involvement 7 Process safety information 7 Process hazard analysis 7 Mechanical integrity 7 Operating procedures 7 Training 7 Management of change 7 Pre-startup reviews 7 Emergency preparedness 7 Incident investigation 7 Hot work permits 7 Contractor safety performance 7 Compliance audits As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: 1. Administratively limit the maximum allowable inventory for toxic chemicals handled at the facility including, ethylene oxide, propylene oxide, hydrochloric acid, and acrylonitrile. 2. Conduct extensive in-process and effluent wastewater monitoring in excess of NPDES permit requirements for derivatives of ethylene oxide and propylene oxide. 3. Designed a closed loop cooling tower for installation in the Polychemicals process area to prevent the accidental release of ethylene oxide or propylene oxide to the Ohio River. The individual elements of our prevention program, along with the chemical specific prevention steps, 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. 5.0 Five Year Accident History Records are maintained for all significant accidental chemical releases that occur at our fac ility. During the past five years, Arch Chemicals - Brandenburg Facility has not experienced any RMP chemical releases to the atmosphere which have caused an off-site impact. Three chemical releases to the Ohio River have occurred which required notification of local emergency responders and state and federal agencies. They are: DATE CHEMICAL AMOUNT 5/15/98 Propylene Oxide 600 pounds 8/20/97 Ethylene Oxide 2,389 pounds 5/20/97 Ethylene 20,000 pounds 1/15/97 Propylene Oxide 16,000 pounds We have made significant efforts through incident investigations and corrective actions to prevent these types of incidents in the future. 6.0 Emergency Response Program Arch Chemicals operates under the philosophy that "all accidents are preventableall of the time." Arch is committed to providing a safe environment for all employees, visitors, and the surrounding community. An Emergency Response Plan has been developed for the Brandenburg facility in or der to provide an effective and efficient response to any type of incident. The Emergency Response Plan addresses all federal, state, and local regulatory requirements for emergency planning. To assist us in the event of an emergency, local area emergency responders have been provided with our Emergency Response Plan. Drills and training for the Arch-Brandenburg Emergency Response Team (ERT) are conducted independently and in conjunction with the Brandenburg Fire Department. Emergency Response Team members are on site 24 hours a day, 365 days a year. The Meade County Fire Department is responsible for notifying the public of any release which has potential off site impacts. 7.0 Planned Changes To Improve Safety The Brandenburg facility has planned facility improvements that will help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment. A USEPA Chemical Safety Audit was recently conducted at the Arch Chemicals -Brandenburg facility in March 1999. A variety of recommendations are being implemented as a result of our participation in this program, including: 1. Increased operator training for emergency response activities. 2. Expanded drills to include the local medical community and LEPC. 3. Continued capital equipment upgrades for existing facilities to prevent chemical releases. 8.0 Certification For all Program 3 covered processes at the Arch Chemicals Brandenburg facility, the undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted in this Risk Management Plan is true, accurate, and complete. Signature: Name/Title: C. Kirk Johnson, Plant Manager Date: June 18, 1999 |