Albright & Wilson Americas - Charleston, SC Plant - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

ALBRIGHT & WILSON AMERICAS, INC. 
CHARLESTON SC FACILITY 
RISK MANAGEMENT PLAN PROGRAM 
EXECUTIVE SUMMARY 
 
INTRODUCTION 
 
The Executive Summary is intended to provide a condensed description of the following, to provide a better understanding of the chemicals handled at the Charleston Plant, and the accident prevention and emergency response programs, which are designed to protect our employees, the public and the environment from an accidental releases. 
 
o Accidental release prevention and emergency response policies 
o A description of our facility and use of substances regulated by EPA's Risk Management Program (RMP) regulation 
o A summary of results from our assessment of the potential off site consequences from accidental chemical releases 
o An overview of our accidental release prevention program 
o A five-year accident history of accidental releases of chemicals regulated by EPA's RMP rule 
o An overview of our emergency response program 
o An overview of planned improvements at the fac 
ility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment 
 
1.O ACCIDENTAL RELEASE PREVENTION AND EMERGENCY 
RESPONSE POLICIES 
 
At Albright & Wilson Americas' Charleston, SC plant site, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner.   The operations of the Charleston Plant are subject to strict internal company policy requirements regarding the management of health, safety and environmental issues.  The Charleston Plant is also subject to a number of local, state and federal regulatory requirements to which Albright & Wilson adheres.    We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment.  This document provides a brief overview of the comprehensive risk managemen 
t programs we have developed and implemented. 
 
2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES 
 
The Charleston, SC Plant produces inorganic and specialty organic chemicals using a variety of chemical raw materials and processing operations.  These chemical products are produced in several separate production units using batch and continuous manufacturing processes.  In these processes, we use or produce the following chemicals that EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release: 
 
CHEMICAL NAME                                            USE 
 
TOXICS 
 
Chlorine                                                          Reactant 
Phosphorus Trichloride                                  Reactant/Sales 
Phosphorus Oxychloride                               Reactant/Sales 
Ammonia (Anhydrous)                                   Reactant/Neutralizer 
Formaldehyde (50 % Solution)                       Reactant 
Hydrogen  
Chloride (Anhydrous)                    Reactant 
Ethylene Oxide                                               Reactant 
Propylene Oxide                                             Reactant 
 
FLAMMABLES 
 
Pentane                                                         Non Reactive Diluent 
 
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 
 
3.0 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS 
 
EPA's RMP regulation requires that Albright & Wilson provide information about worst-case accidental release scenarios and alternative accidental release scenarios at our facility for the chemicals listed in Section 2.  In compliance with the regulation, Albright & Wilson has assessed the impact of worst case scenarios for each of the listed chemicals in Section 2. This document includes a worst case scenario for the toxic chemical with the grea 
test potential impact in terms of distance, and a worst case scenario for the one flammable chemical on the list.  Albright & Wilson has also conducted a hazards assessment to identify potentially more likely or alternate accidental release scenarios for each of the listed chemicals, and in compliance with the RMP regulation, has included in this document a single alternate accidental release scenario for each of the listed chemicals. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: 
 
WORST-CASE RELEASE SCENARIO - Regulated Toxic Chemicals  
 
EVENT - PHOSPHORUS TRICHLORIDE (PCl3) 
 
Phosphorus trichloride railcar rupture releasing entire contents (180,000 pounds) to the ground in a ten-minute period. Scenario release mandated by EPA. 
 
Estimated Exposure Distance - 16 miles. 
 
Potentially Impacted Receptors - Industrial, residential and recreational area 
s; schools, prison/correction facilities and hospitals; as well as, national and state parks and monuments. 
 
Administrative Controls and Mitigation Measures to Minimize Exposure Distance - None 
 
ALTERATIVE RELEASE SCENARIO(S) - Regulated Toxic Chemicals 
(MORE LIKELY ACCIDENTAL RELEASE CASE(S) 
 
EVENT - HYDROGEN CHLORIDE, ANHYDROUS (AHCl) 
 
Partial failure of railcar unloading hose resulting in a release of 129 pounds of anhydrous hydrogen chloride (AHCl) in a 0.5 minute time period. 
 
Estimated Exposure Distance - 0.1 mile. 
 
Potentially Impacted Receptors - Not off site. 
 
Administrative Controls and Mitigation Measures to Minimize Exposure Distance - Area AHCl sensors/interlocks; isolation of leaking piping by automatic shutoff valves; operation of railcar excess flow valves and scheduled periodic inspection and pressure test of the transfer hose. 
 
EVENT - PHOSPHORUS TRICHLORIDE (PCl3) 
 
Partial failure of railcar loading hose resulting in a release of 905 pounds of phosphorus trichloride  
in a 2.5 minute time period. 
 
Estimated Exposure Distance - 0.2 mile. 
 
Potentially Impacted Receptors - Recreational area. 
 
Administrative Controls and Mitigation Measures to Minimize Exposure Distance - Operator detection and isolation of line by remote operated automatic shutoff valves.  Scheduled periodic inspection and pressure test of the loading hose. 
 
EVENT - CHLORINE (Cl2) 
 
Release of 100 pounds over one minute period due to partial failure of transfer hose at rail car unloading station. 
 
Estimated Exposure Distance - 0.2 miles 
 
Potentially Impacted Receptors - Recreational areas. 
 
Administrative Controls and Mitigation Measures To Minimize Exposure Distance - Isolation of leaking piping by automatic shutoff valves, operation of railcar excess flow valves; area chlorine sensors/interlocks; and scheduled periodic inspection and pressure test of the transfer hose. 
 
EVENT - ANHYDROUS AMMONIA (NH3) 
 
Anhydrous ammonia feed line partial failure releasing 335 pounds of product over a  
two minute period. 
 
Estimated Exposure Distance - 0.1 mile 
 
Potentially Impacted Receptors - Not off site. 
 
Administrative Controls and Mitigation Measures To Minimize Exposure Distance - Operator detection and isolation of line by remote operated automatic shutoff valves.  
 
EVENT - ETHYLENE OXIDE (EO) 
 
Partial failure of transfer hose supplying Ethylene Oxide (EO) from railcar to OSU 1. Release of 2,990 pounds of EO over an eight-minute period. 
 
Estimated Exposure Distance - 0.5 mile 
 
Potentially Impacted Receptors - Industrial, residential and recreational areas; as well as, a hospital and school. 
 
Administrative Controls and Mitigation Measures To Minimize Exposure Distance - Isolation of leaking piping by automatic shutoff valves; area EO sensors/interlocks; operation of railcar excess flow valves and scheduled periodic inspection and pressure test of the transfer hose. 
 
EVENT - FORMALDEHYDE, 50% SOLUTION (HCHO) 
 
Partial failure of pipe gasket near reactor allowing release of 350 p 
ounds of product over a 5 minute period.  Released to a secondary containment (curbed) area. 
 
Estimated Exposure Distance - 0.06 mile  
 
Potentially Impacted Receptors - Not off site. 
 
Administrative Controls and Mitigation Measures To Minimize Exposure Distance - Operator detection and isolation of piping by remote operated automatic shutoff valves and secondary containment - curbed area.  
 
EVENT - PHOSPHORUS OXYCHLORIDE (POCl3) 
 
Partial failure of transfer hose while loading tank truck, releasing 595 pounds of Phosphorus oxychloride over a 2.5 minute period into the truck loading containment area. 
 
Estimated Exposure Distance - 0.3 mile 
 
Potentially Impacted Receptors - Industrial, residential and recreational areas. 
 
Administrative Controls and Mitigation Measures To Minimize Exposure Distance - Operator detection and isolation of loading line by remote operated automatic shutoff valves; scheduled periodic inspection and pressure test of the loading hose and secondary containment (cu 
rbed truck loading area). 
 
EVENT - PROPYLENE OXIDE (PO) 
 
Partial failure of transfer hose while supplying Propylene oxide from railcar to OSU 3, releasing 3,600 pounds of product to ground over a 10 minute period. 
 
Estimated Exposure Distance - 0.2 mile 
 
Potentially Impacted Receptors - Recreational areas. 
 
Administrative Controls and Mitigation Measures To Minimize Exposure Distance - Operator detection and isolation of line by remote operated automatic shutoff valves.  Scheduled periodic inspection and pressure test of the transfer hose. 
 
WORST-CASE RELEASE SCENARIO - Regulated Flammable Chemicals 
 
EVENT - PENTANE (C5H12) 
 
Full 16,000-gallon (80,000 pounds) Pentane Storage Tank ruptures releasing contents with a resulting immediate vapor cloud explosion.  Scenario mandated by EPA. 
 
Estimated Exposure Distance - 0.3 mile (VCE end point: 1-psi overpressure) 
 
Potentially Impacted Receptors - Industrial, residential and recreational areas. 
 
Administrative Controls and Mitigation Measures 
To Minimize Exposure Distance - Diked area. 
 
ALTERATIVE RELEASE, SCENARIO - Regulated Flammable Chemical 
(MORE LIKELY ACCIDENTAL RELEASE CASE) 
 
EVENT - PENTANE (C5H12) 
 
Partial failure of Tank Truck unloading hose releasing 263 pounds of pentane which results in a pool fire. 
 
Estimated Exposure Distance - 0.02 mile. 
 
Potentially Impacted Receptors - Not off site. 
 
Administrative Controls and Mitigation to Minimize Exposure Distance - Operator detection and isolation of leaking hose line; scheduled periodic inspection and pressure test of the unloading hose; tank truck unloading located in a curbed area; and area electrical classification to minimize the chance of ignition of spilled pentane. 
 
Please note that instructions from the US Environmental Protection Agency on the submission of data in Section 3 of this Risk Management Plan require the rounding off of some values shown above for the alternate scenarios; therefore, some values in the Executive Summary may appear different from  
those in Section 3.    
 
4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND 
CHEMICAL-SPECIFIC PREVENTION STEPS 
 
The Charleston Plant has a number of processes covered under the requirements of the OSHA Process Safety Management regulation, 29 CFR 1910.119. The Charleston Plant also has a well-established process safety management program which meets, and in some cases exceeds, the requirements of this OSHA regulation. Many of these same processes are also covered under the requirements of the EPA Risk Management Program rule. In complying with the above regulations, the Charleston Plant takes a systematic, integrated approach to preventing accidental releases of hazardous chemicals and planning for emergencies.  The new requirements under the EPA's RMP regulation have been integrated into the existing process safety management programs at the Charleston Plant, and are described in a Process Safety and Risk Management Plan for the Charleston Plant. The key elements of the accident pre 
vention program are listed below:   
 
o Process safety information 
o Process hazard analysis 
o Operating procedures 
o Training 
o Mechanical integrity 
o Management of change 
o Pre-Startup Safety Review 
o Compliance audits 
o Incident investigation 
o Employee participation 
o Hotwork permit 
o Contractors 
 
Our company and our employees are committed to the standard that these management systems establish 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 
 
During the five-year period ending in June 1999, the Charleston Plant has had two (2) accidental chemical releases involving chemicals covered under EPA's RMP rule.  
 
In 1995, during a maintenance activity, a drop of liquid phosphorus oxychloride fell on an employee performing maintenance in the Organic Specialties Unit. This person was treated by a physician and released to resume normal activities; this inc 
ident resulted in no lost time for the employee, but was recorded as a recordable injury under OSHA injury and illness record keeping requirements. There were no other on site consequences.  There were no off site consequences from this incident. 
 
In 1998, during a railcar transfer hose disconnect activity, there was a small chlorine release from a scrubber assembly in the Phosphorus Trichloride production unit. One contract plant security employee was examined by a physician for possible health effects.  There  were no other on-site consequences.  There were no off-site consequences from this incident.   
 
We have conducted investigations to identify and correct the root causes of each of these incidents. 
 
6.0  EMERGENCY RESPONSE PROGRAM 
 
The Charleston Plant has a comprehensive Emergency Response Plan that covers all types of emergencies, including naturally occurring emergencies such a hurricanes. This plan is subject to a number of regulatory requirements but primarily those under t 
he US Occupational Safety and Health Administration (OSHA). Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Our plan includes procedures in communications, evacuation, emergency organization, emergency response, decontamination and operation and maintenance of emergency equipment. 
 
Furthermore, we coordinate our plan with the community emergency response plan and conduct joint training with the local fire department and Local Emergency Planning Committee (LEPC). 
 
7.0 PLANNED CHANGES TO IMPR0VE SAFETY 
 
We currently have one scheduled improvement that we are planing to implement at our facility to help prevent and/or better respond to accidental chemical releases. This improvement is to upgrade our facility for the drumming of phosphorus trichloride and phosphorus oxychloride.
Click to return to beginning