Bayer, Agriculture Division - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Practices We the Agriculture Division, 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 measures to prevent possible releases of regulated substances. If such a release does occur, our highly trained on site emergency response personnel are at hand to control and mitigate the effects of the release. Bayer has maintained a long-standing working relationship with the Kansas City emergency response team HAZMAT 71 to insure their support in the event of an unexpected release. 2. The Stationary Source and the Regulated Substances Handled The pri mary activities at our Hawthorn Road site are the formulation and manufacture of crop protection chemicals. Of the 140 RMP regulated chemicals we have 8 chemicals present at our facility in quantities sufficient to be regulated by this rule. These chemicals are essential raw materials for the production of crop protection intermediate chemicals and include carbon disulfide, chlorine, ethyl mercaptan, formaldehyde (solution), hydrazine hydrate, methyl butene, phosphorus trichloride, and vinyl chloride. Chlorine is also used for the manufacture of sodium hypochlorite, which is the oxidizing agent for one of our herbicides, or is either sold as bleach or used as a vent gas-scrubbing agent on site. 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 and alternate scenarios, we used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance. The scenarios were selected in accordance with the EPA guidance documents. All chemicals are submitted as Program Level 3 for both toxic and flammable scenarios. The worst case was evaluated using the required Class F meteorological conditions with 1.5 meters/second wind speed. The alternate case used neutral weather conditions Class D meteorological conditions wind speed 3.0 meters/second. The worst case toxic release scenario submitted involves a release from a chlorine rail car. The scenario involves the release of 180,000 pounds of liquid chlorine which is evaporated over 10 minutes. The maximum distance of 14.2 miles under worst case weather conditions is obtained corresponding to an endpoint concentration of 0.0087 mg/L (3 PPM). The alternative release scenario for chlorine involves the release of gaseous chlorine near the p oint of use in the production process. The scenario involves the release of 83 pounds of chlorine in a gaseous form over 10 minutes. Passive mitigation controls such as the enclosure are taken into account to calculate the potential for offsite impact reducing the release to the environment to 43 pounds over 10 minutes. The release is assumed to be controlled by active mitigation measures that include emergency shutdown systems. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L (3 PPM) of chlorine is 0.21 miles. The alternative release scenario for carbon disulfide involves failure of a transfer hose resulting in the release of 1770 pounds of carbon disulfide. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 14.51 minutes. Passive mitigation controls such as dikes and sumps are taken into account to calculate the pot ential for offsite impact. The release is also assumed to be controlled by active mitigation measures that include deluge system(s) and emergency shutdown systems. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.16 mg/L of carbon disulfide is 0.27 miles. The alternative release scenario for phosphorus trichloride involves a release from the 170,000 pound storage vessel. The scenario involves the failure of a transfer hose resulting in the release of 253 pounds of phosphorus trichloride. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to evaporate over 37 minutes. Passive mitigation controls such as dikes are taken into account to calculate the potential for offsite impact. The release is also assumed to be controlled by active mitigation measures that include emergency shutdown systems. Under neutral weather conditions, the maximum distance to th e endpoint of 0.028 mg/L of phosphorus trichloride is 0.08 miles. Currently this process is being relocated to another production area. All reviews will be brought up to date prior to startup. The alternative release scenario for formaldehyde (solution) involves a release from raw material storage. The scenario involves the release of 10,415 pounds of formaldehyde (solution). Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. Passive mitigation controls such as dikes and sumps are not taken into account to calculate the potential for offsite impact. Under neutral weather conditions, the maximum distance to the endpoint of 0.012 mg/L of formaldehyde (solution) is 0.19 miles. If the passive mitigation controls in place, i.e. dikes, were accounted for and the active mitigation deluge system was considered, the release would not have an offsite impact. The alternative release scenario for hydrazine hydrate (solution) involves a release from production process storage. The scenario involves the release of 32,000 pounds of hydrazine hydrate (solution). Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. Passive mitigation controls such as dikes and sumps are not taken into account to calculate the potential for offsite impact. Under neutral weather conditions, the maximum distance to the endpoint of 0.011 mg/L of hydrazine hydrate (solution) is 0.19 miles. If the passive mitigation controls in place, i.e. dikes, were accounted for and the active mitigation deluge system was considered, the release would not have an offsite impact. The worst case release scenario submitted for flammable substances, as a class, involves a release from storage of methyl butene in the methyl butene storage process. The scenario involves the release of 132,000 pounds of methyl butene. Passiv e mitigation systems such as dikes have been considered when evaluating this scenario. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. The maximum distance of 0.41 miles is obtained corresponding to an endpoint of 1 psi overpressure. The representative alternative release scenario involves a release from storage of methyl butene. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 82,570 pound of methyl butene in 5 minutes. The release is also controlled by active mitigation measures that include a deluge system. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.23 miles. Alternate release scenarios were also determined for vinyl chloride and ethyl mercaptan with both having an overpressure distance less than methyl butene. 4. The General Acc idental Release Prevention Program and the Chemical-Specific Prevention Steps Bayer 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 manufacturing facility was designed and constructed in accordance with NFPA-58 Standard, in effect at the time of construction. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Bayer 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 c ontrolled efficiently. The methodology used to carry out these analyses is Hazard and Operability (HAZOP). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Bayer maintains written operating procedures. These procedures address various modes of operation including initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a shutdown. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Bayer has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity Bayer carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel obtain specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Bayer to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aw are of and trained 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 at Bayer. 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 Bayer conducts audits on a regular basis to determine whether the requirements of the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Bayer promptly investigates any incident that has resulted in, or could reasonably result in a release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccu rring. All reports are retained for a minimum of 5 years. Employee Participation Bayer truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention 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 in particular. Contractors Bayer utilizes 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. Bayer has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Bayer has 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 with offsite consequences during this period. 6. Emergency Response Plan Bayer maintains a written emergency response plan to deal with accidental releases of hazardous materials. 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. Bayer has an on-site emergency brigade, which is made up of approximately 60 employees and provides coverage 24 hours per day and 365 days per year. The brigade is trained in fire and rescue and has drills on a quarterly basis to keep them current for emergency response. Bayer also has a trained HAZMAT team with approximately 10 employees available for emergenci es when necessary. The HAZMAT team, the brigade and their equipment is dedicated to this site to provide initial response for any emergency that may occur. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Construction of a chlorine unloading containment building and scrubbing system is one of the major steps underway to improve safety at our facility. All changes will be fully implemented by September 30, 1999. Additional developments have been implemented for rail cars stored on remote siding with new berms to mitigate or contain worst case releases. |