GNI Chemicals Corporation, Inc. - Executive Summary |
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Introduction GNI Chemicals Corporation, Inc. is a fully integrated specialty chemical manufacturing company serving major chemical, petrochemical, industrial and consumer product manufacturers nationwide. The facility is located in the heart of the Gulf Coast petrochemical complex in East Harris County Texas. The nearest residential neighborhood is over two miles away. The company has an excellent record for regulatory compliance and well should, since protection of the health and safety of our employees and residents of our community is of the highest priority. While we cannot eliminate risk completely, we can and do make a concerted effort to safeguard people and protect the environment. We work closely with other members of our industry, the public, and local officials to maintain strong safety and environmental programs and to minimize risks. As part of our commitment to comply with laws and regulations of local, state, and federal agencies, we are submitting the risk managem ent plan under guidelines established by the federal Environmental Protection Agency (EPA). Prevention Program GNI Chemicals Corporation, Inc. has developed wide-ranging procedures and systems to reduce the likelihood of accidents, including: 7 Prevention programs, which include ongoing review of safety measures. 7 Written operating procedures that address safety issues. 7 Training programs for employees and contractors. 7 Existing procedures to investigate incidents and to identify their causes for improvement. 7 Restricted access to processes and hazardous materials. 7 Equipment that meets or surpasses industry standards. 7 Safety inspections and audits covering employee and contractor activities. 7 Environmental audits and inspections. 7 Various prevention systems, such as fire and chemical extinguishing systems and dikes around tanks. In addition to these measures, GNI Chemicals Corporation, Inc. has systems designed to address the safe handling of all chemicals that are stored or processed. We review our projects to assess the hazards posed by the chemicals we handle so that we can manage these risks. Under RMP we must consider the impact of specific hypothetical release scenarios on the facility and the surrounding community. Hazard Assessment The hazard assessment component of the RMP requires us to provide information on the following for certain quantities of regulated chemicals: 7 A hypothetical worst-case accidental release scenario in which we approximate what might happen under certain conditions if all of a chemical in a process were released and every single safety system were to fail, even though the possibility of this kind of scenario is remote. This worst-case scenario suggests the potential effect that such a release might have on the community. 7 Alternative release scenarios in which we approximate the effects of hypothetical accidental releases in which the safety systems work. 7 A five-year accident history for the facility, desc ribing any accidents involving regulated chemicals that may have occurred at the site. GNI Chemicals Corporation, Inc. has conducted the assessment of these hypothetical scenarios, using the EPA's Offsite Consequence Analysis Guidance (OCA) software called RMP Comp as well as the (Automated Resource for Chemical Hazard Incident Evaluation) model (ARCHIE). These two models are deemed by EPA as appropriate methods for chemical emergency planning. The OCA and ARCHIE models approximates the distance chemicals might travel in the event of an accidental release and the concentration of chemicals at various distances from the facility. GNI Chemicals Corporation, Inc. stores the following substances onsite in quantities that are greater than the RMP threshold quantities: Toxics 7 Ammonia 40,000 pounds 7 Phosphorous trichloride 60,000 pounds 7 Formaldehyde 40,836 pounds 7 Ethylenediamine 40,000 pounds Flammables 7 Isobutylene 45,000 pounds The results from the offsite consequen ce analysis for these compounds are as follows: Worst-Case Scenario (Toxics): Ammonia Cas#: 7664-41-7 Concentration: 0.014 mg/l Toxic endpoint: 2.3 miles Worst-Case Scenario (Flammables): Isobutylene Cas#: 115-11-7 Distance to 1-psi overpressure: 0.3 miles Alternative Release Scenarios (Toxics) Ammonia Cas#: 7664-41-7 Concentration: 0.014 mg/l Toxic endpoint: 0.1 miles Phosphorous trichloride Cas#: 7719-12-2 Concentration: 0.028 mg/l Toxic endpoint: 0.2 miles Formaldehyde Cas#: 50-00-0 Concentration: 0.012 mg/l Toxic endpoint: 0.8 miles Ethylenediamine Cas#: 107-15-3 Concentration: 0.49 mg/l Toxic endpoint: 0.1 miles Alternative Release Scenario (Flammables) Isobutylene Cas#: 115-11-7 Distance to Heat Radiation of 5 Kilowatts/sq meter: 0.1 miles Emergency Response At GNI Chemicals Corporation, Inc. there are plans in place for handling emergencies such as fires and natural disasters as well as chemical accidents. Our goal in any chemical release or similar emergency is to contain the release as quickly as possible thereby minimizing the impact on the facility and its neighbors. We have various resources ranging from warning systems to communications equipment to well-rehearsed plans and procedures to ensure that all personnel know their roles in an emergency. Our plans are coordinated with those of local government emergency services and other services such as Channel Industries Mutual Aid (CIMA). We maintain and update our equipment and systems as needed and review our emergency plans on a regular basis. Five-Year Accident History There have been no releases of RMP substances at GNI Chemicals that meet EPA Risk Management Program reporting requirements. There was one incident that occurred on 05/27/98. Approximately 19 lbs. of phosphorous trichloride was accidentally released. The incident was quickly mitigated and there were no injuries. Conclusion While the documentation and some of the analyses required by RMP are new, the overall thrust of the program is not. The chemical industry has worked extensively with federal regulators for many years to develop ways to safeguard employees, the public and the environment. Clearly, no manufacturing process is completely risk-free. For that matter, no aspect of ordinary life is without some risk. But with continuing attention to safety, regular monitoring of processes, and adherence to rigorous guidelines, we can reduce the likelihood of accidents. The RMP builds upon existing safety and environmental protections and will result in more information being made to the public. |