Rhone Poulenc Surfactants & Specialties, LP - Executive Summary

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Executive Summary for Rhodia - Winder, GA 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Rhone Poulenc Surfactants & Specialties, LP -- operating as Rhodia Inc. are strongly committed to employee, public and environmental safety.  This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances; and ensure the safety of employees and neighbors. 
2.    The Stationary Source and the Regulated Substances Handled 
Our Winder, Georgia facility's primary activity is the manufacture of surfactants and specialty chemicals.  These products are used in the manufacture a variety of consumer goods, including personal care products such as soaps, shampoos, detergents, and textile processing aids.  W 
e also make polyester based polymers which are used for soil release in detergent applications and in textile processing..  We presently have 3 substances at our facility, which are regulated under the EPA RMP regulations.  These are Epichlorohydrin  [Oxirane, (chloromethyl)-], Methylamine  [Methanamine] and Dimethylamine  [Methanamine, N-methyl-].  Epichlorohydrin  [Oxirane, (chloromethyl)-] is used for production of Episulfonate Solution - an intermediate used to produce surfactants for Industrial and Personal Care Products.  Methylamine  [Methanamine] is used for Methyl Taurine - a surfactant for commercial cleaning applications.  Dimethylamine  [Methanamine, N-methyl-] is used for production of ASC Intermediate, which is used to produce an end product used in various Industrial and Personal Care Products. 
The maximum inventory of Epichlorohydrin  [Oxirane, (chloromethyl)-] at our facility is 285,000 lb. Methylamine  [Methanamine] and Dimethylamine  [Methanamine, N-methyl-] are pre 
sent on-site at our facility in maximum quantities of 54,500 lb. and 18000 lb. respectively. The Methylamine and Dimethylamine are present in aqueous solutions. 
3.    The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
To evaluate the worst case scenarios, we have used the EPA's OCA Guidance Reference Tables.  For alternative release scenario analyses we have employed Phast ver 5.2 modeling program.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from Episulfonate Solution process.  In this scenario 98000 lb. of Epichlorohydrin  [Oxirane, (chloromethyl)-] is released from a railcar.  The toxic liquid released is assumed to form a pool from which evaporation takes place.  The entire pool is estimated to evaporate over 5665 mi 
nutes. Passive mitigation systems such as a berm are also taken into account to calculate the scenario. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.4 miles is obtained corresponding to a toxic endpoint of 0.076 mg/L. 
The alternative release scenario for Epichlorohydrin  [Oxirane, (chloromethyl)-] involves a release from a gasket leak in the Epichlorohydrin transfer line from the storage tank to the Episulfonate Solution manufacturing vessel.  The scenario involves the release of 5480 lb. of Epichlorohydrin liquid, that is assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The leak is estimated to last for 20 minutes.  The release is also assumed to be controlled or limited by an excess flow valve and our emergency safety shutdown system.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.076 mg/L of Epichlorohydrin  [Oxirane, (chloromethyl)-] is 0.07 miles. 
The worst case release s 
cenario submitted for Program 3 flammable substances as a class involves a catastrophic release from our MonoMethylAmine storage tank.  In this scenario 33000 lb. of Methylamine  [Methanamine] in a flammable 40% aqueous solution is released.  It is assumed that the entire quantity is released, vaporized, and then finds an ignition source causing a vapor cloud explosion.  Under worst case weather conditions, the calculated distance of 0.23 miles is obtained corresponding to an endpoint of 1 psi overpressure. 
One alternative release scenario submitted for Program 3 flammable substances involves a release from a hose break while unloading 40% Dimethylamine from a tank truck.  The release is assumed to result in a Jet flame.  The scenario involves the release of 1220 lb. Dimethylamine  [Methanamine, N-methyl-] in a flammable 40% aqueous solution released in two minutes.  Passive mitigation controls taken into account to calculate the scenario for this system is that the unloading is a ful 
ly attended operation - We estimate that the operator will stop unloading within two minutes.  Under neutral weather conditions, the maximum distance to the high heat radiation (5 kw/m2) endpoint is 0.04 miles. 
Another alternative release scenario submitted for Program 3 flammable substances involves a release from a hose break while unloading 40% Methylamine from a tank truck.  The release is assumed to result in a Jet flame.  The scenario involves the release of 886 lb. Methylamine  [Methanamine] in a flammable 40% aqueous solution released in two minutes.  Passive mitigation controls taken into account to calculate the scenario for this system is that the unlading is a fully attended operation - We estimate that the operator will stop unloading within two minutes.  Under neutral weather conditions, the maximum distance to the high heat radiation (5 kw/m2) endpoint is 0.03 miles.   
4.    The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.  This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition, and other nationally recognized safe design standards.    The following sections briefly describe the elements of the release prevention program that is in place at our facility. 
Process Safety Information 
Rhone Poulenc Surfactants & Specialties, LP -- operating as Rhodia Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses includes What If, HAZOP, and Quantitative Risk Assessment.  The studies are undertaken by a team of qual 
ified personnel with expertise in engineering and process operations plus experienced operations personnel. The safety studies are revalidated at least every five years.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update for Methyl Taurine and use of MonoMethylAmine was performed on 3/31/1998. The initial PHA for ASC Intermediate and the use of Dimethylamine was performed on 5/08/1997.  The initial PHA for Episulfonate Solution and use of Epichlorohydrin, was held on 4/28/1997. 
Operating Procedures 
We maintain written Equipment Operating Procedures addressing safety and quality specific to the operating equipment and system.  In addition we have written Manufacturing Procedures for each of our products.  These procedures are controlled to ensure that the current version is readily available to operators involved in the processes. The combined sets of  procedures address various modes of operation such as startup, normal operation 
s, shutdown and  emergency shutdown.  The procedures are reviewed at least every three years and are readily accessible to operators involved in the processes.  The procedures are certified as current on an annual basis. 
We have a comprehensive training program in place to ensure that employees operating processes are competent in the Operating and Manufacturing Procedures associated processes, and equipment for which the employees are responsible.  Refresher training is provided periodically.  Training on handling, use, and hazards of raw materials and products is conducted regularly. 
Mechanical Integrity 
We have a formal documented Mechanical Integrity / Preventive Maintenance Program. Regularly scheduled maintenance checks on process equipment ensure proper operation.  Process equipment covered by the system includes; pressure vessels, storage tanks, piping systems, relief systems, emergency shutdown systems, process controls and pumps.  Qualified contractors complete som 
e periodic inspections and tests, other inspections and tests are carried out by our own qualified personnel with previous training in maintenance practices.  Plant personnel are provided specialized training as needed.  Any equipment deficiencies identified by inspections and tests are corrected in a timely manner. 
Management of Change 
Written procedures are in place at our facility to manage changes in process chemicals, technology, equipment and procedures. The most recent revision of our management of change procedure was issued on 6/1/1998.  The most recent revision of maintenance procedures was issued on 3/31/1997.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and provided training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice a 
t our Winder plant.  The most recent reviews for RMP covered processes was performed for Epichlorohydrin / Episulfonate Solution on 4/22/97; for Dimethylamine / ASC Intermediate on 6/3/1997; and for Methylamine / Methyl Taurine on 5/30/1995.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
Rhone Poulenc and Rhodia conduct audits on a regular basis to determine whether the provisions set out under the PSM and RMP rules are properly implemented, at the Winder facility.  The most recent compliance audit was conducted on 6/24/1998.  These audits are carried out yearly and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
We investigate any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance.  These investigation 
s are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
Employee Participation 
At our Winder facility, Process Safety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning all aspects of Personnel Safety; Process Safety; Accident Prevention; and quality issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  We have a strict policy of informing the contractors of known potential h 
azards related the contractor's work and the processes.  Contractors are also informed of all  procedures for emergency response should an accidental release of a regulated substance occur. 
5.    Five-year Accident History 
Rhone Poulenc Surfactants & Specialties, LP and Rhodia have had an excellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, there has been no accidental release of RMP covered chemicals during this period. 
6.    Emergency Response Plan 
The Winder plant has a formal written emergency response plan to deal with accidental releases of hazardous materials, and other incidents.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
To ensure proper functioning, our emergency response equipment is regularly inspected and s 
erviced.  Suitable training is conducted regularly, for the different levels of responders. Drills are held regularly to ensure readiness for response. In addition, the emergency response plan is promptly updated to reflect any pertinent changes taking place within our equipment or processes that would require a modified emergency response. 
Barrow County, GA LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.  We also coordinate our emergency response  with the Barrow County (GA) Emergency Management Agency. In addition we meet regularly (approx. eight times per year) with a Community Advisory Panel, which includes representatives of the community, media and others.  
7.    Planned Changes to Improve Safety 
Under the Chemical Manufacturers' Association (CMA) Responsible Care program, Rhodia as a CMA member is pledged to continually improve all aspects of health, safety and environmental performance.  This includes reducin 
g risk potential.  As part of the Responsible Care Process Safety Code, we have an on-going process safety program that includes measurement of performance, audits, and implementation of corrective actions.  Any corrective actions identified have been, and will continue to be, implemented in a responsible and timely manner.
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