Ansell Protective Products - Troy Plant - Executive Summary

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EXECUTIVE SUMMARY 
 
1. Ansell Protective Products' Troy plant has an accidental release prevention and emergency response policy which involves a unified approach integrating technologies, procedures and management practices.  All applicable procedures of the U.S. Environmental Protection Agency (EPA) prevention program are followed.  In addition, the emergency response policy involves the preparation of response plans that are tailored to meet the response capability available in the community and is in compliance with the EPA requirements. 
 
2. The chlorine system was installed for use in the manufacture of nitrile products.  The chlorine installation includes a chlorine storage and use shed that contains a maximum of ten (10) one ton containers of chlorine.  Three (3) containers are in use and seven (7) are in storage.  Scales are used to continually monitor the weight of the chlorine containers in use.   A ton container lifting bar and hoist are used to move the containers from stor 
age (chocked on rails) to the use site.  Elevated "saddles" are used to hold the containers in use, and gas detectors are used to monitor the area for chlorine leaks.  A sprinkler system has also been installed in the chlorine shed, as well as a fire extinguisher.  The Troy facility is manned 24 hours per day, seven days per week, with the exception of scheduled shutdown periods (usually two per year at a maximum of one week each).  Occasionally, during shutdown periods, mechanics are on site to perform necessary maintenance on equipment.  Also, during these shutdown periods, at least one guard is on site at all times. 
 
3. The Offsite Consequences Analysis (OCA) was performed for two chlorine release scenarios - one identified as "worst case" and the other as "alternative".  The worst-case release scenario describes the release of the entire quantity of a one ton container (2,000 pounds) in ten (10) minutes.  The alternative release scenario describes the release from a leaking valve  
of 15 pounds in ten (10) minutes. 
 
Atmospheric dispersion modeling is performed to determine the distance traveled by the chlorine released for both the "worst case" and "alternative" scenarios before its concentration decreases to the toxic end point of 3 ppm (0.0087 g/m3) based on the Emergency Response Planning Guideline 2 (ERPG-2) developed by the American Industrial Hygiene Association (AIHA).  The residential population within a circle, with a radius corresponding to the toxic end point distance, is defined to estimate the population potentially affected.  The distance for the "worst case" scenario is 1.3 miles, and the "alternative" scenario is 0.1 miles. 
 
Meteorological conditions for the "worst case" scenario were Stability - F, wind speed 1.5 m/s, average air temperature of 25 0C(77 0F) and 50 % average humidity.   For the "alternative" scenario - Stability D, wind speed 3 m/s, average air temperature 25 0C(77 0F) and 50 % average humidity. 
 
Active mitigation is achieved with 
the use of three chlorine gas detectors.  The chlorine system is also vacuum operated so that the chlorine is under vacuum on removal from the ton  
 
containers as it is fed into the process. A loss of vacuum signal, such as a line break, would shut the system down at the ton container valve. 
 
4. The general accidental release prevention program at the Troy facility is accomplished through the use of the following steps: 
 
Training - combined classroom instruction and on-the-job training. 
Preventive maintenance programs on critical equipment. 
Standard operating procedures. 
Process Safety Management to include hazard assessments and process safety analysis. 
Audits/inspections, conducted internally and by outside sources. 
Effective backup systems/procedures in the event of critical equipment failure. 
Utilization of technology for alarms and monitoring of equipment (PLC's). 
 
5. The Ansell Troy plant has used chlorine since the commencement of nitrile glove production in late 1995.  The pla 
nt was previously out of operation (shut down in May of 1994).  We have had one accidental release of chlorine since 1995.  This release was not reportable (less than 10 pounds).  One employee required medical attention due to lung irritation and missed one day of work due to medication that was dispensed. 
 
6. The Ansell Troy plant has an Emergency Response Program which has been coordinated with and reviewed by Ed Brown of the Troy Fire Department which has the responsibility under current Alabama regulations and is a member of the LEPC.  The program includes an emergency response decision tree and notification plan.  Emergency response drills are conducted at least once per calendar year, and procedures are reviewed at that time. 
 
7. There are currently four planned changes to improve the safety of our chlorine facilities and handling.  The most recent change to our chlorine system was accomplished in early 1999, with the relocation and upgrade of our equipment.  As and when any fut 
ure changes are made, all appropriate parties will be notified/involved when this occurs.
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