DuPont - Mobile Plant - Executive Summary |
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The E. I. DuPont de Nemours Mobile Manufacturing Center is located on Highway 43 North, two miles north of Axis, Alabama. Shell Chemical Company originally built the plant in 1968. DuPont acquired the plant in October 1986 as part of its Agricultural Products business and we have continued to add to our facilities. We currently have 322 employees and there are approximately 200 contractors working with us every day. Our employees are active in churches, youth sports, schools, and other activities around our plant, in Mobile, Baldwin, and Washington counties. DuPont is committed to improving the quality of life and enhancing the vitality of communities in which the company has a major business presence. The DuPont Mobile Manufacturing Center primarily produces crop protection chemicals for use in agricultural applications. Some of our products include insecticides such as ASANA and specialty chemicals used in the manufacture of fibers and detergents. Our products contribute to an abundant and safe supply of food for the world's people. We adhere to the highest standards for safe operations and for the protection of the environment, our people, customers, and the citizens of the communities in which we do business. Every person on site has the right and responsibility to stop ANY work he or she sees as unsafe. This includes shutting a process unit down. We will not make a product if we can not make it safely. We have worked over 13 years without an injury causing any employee to miss work. At the DuPont Mobile Manufacturing Center, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. 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 mana gement activities that we have designed and implemented, including: a description of our facility and use of substances regulated by EPA's RMP regulation a summary of results from our assessment of the potential offsite consequences from accidental chemical releases an overview of our accidental release prevention programs a five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule an overview of our emergency response program an overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment the certifications that EPA's RMP rule requires us to provide the detailed information (called data elements) about our risk management program Risk Management Planning The Environmental Protection Agency (EPA) has established regulations that require DuPont and other companies who handle certain chemicals to develop a Risk Manage ment Plan. Our plant uses seven listed chemicals that meet the minimum storage quantities for reporting. We have analyzed the effects to our workers and the community if something should happen that caused these chemicals to be released into the air using EPAs guidance for Worst Case Scenarios and Alternative Release Scenarios. This information, along with a well-developed risk management system, our Process Safety Management program, our emergency response programs coordinated with local response agencies, and a 5-year accident history make up our Risk Management Plan. Worst Case Scenarios The EPA established the assumptions for these unlikely scenarios. The worst case toxic release scenario for our site results from the failure of two one-ton cylinders of phosgene connected together inside of a cylinder building. We had to assume that both of these cylinders broke open catastrophically, spilling their entire contents in 10 minutes, and the vapors, which escape outside of the building, are carried away by a slow breeze. This could only happen if all prevention measures and backup systems failed simultaneously. Although this building has a scrubber to reduce the amount of vapors potentially released to the atmosphere, we cannot take credit for it or any of our other active safety systems in this case. EPA provided a standard procedure to calculate the distance where the amount of the chemical in the air would be sufficient to make most people sick if they breathed it for one hour. Under these highly improbable conditions, the vapors would extend offsite and would impact public receptors. The worst case flammable scenario for our site results from the catastrophic failure of an isobutane storage vessel. Using the assumptions established by EPA, the entire contents of this vessel would instantaneously vaporize with no active mitigation and form a cloud that explodes. This explosion may be heard off-site but would not have any other off-site impact. Alternative Release Scenarios... While the worst case scenario focuses on catastrophic potential, the EPA also established assumptions for an alternative release scenario, which looked at a more realistic situation that could potentially impact our neighbors. For these scenarios, we can take credit for all of the things we do to make our plant a safer place through design and operation of our processes. None of our alternative releases would impact residential or environmental receptors. A rupture of the rupture disk on a phosgene cylinder within the cylinder building could result in a release. The cylinder building has a scrubber that is extremely efficient in removing phosgene from the air and thus, significantly reduces the amount released to the atmosphere. Phosgene detectors are installed inside and outside the cylinder building as well as around the perimeter of the process area. These detectors initiate alarms and interlocks to shutdown the flow of phosgene in the event of a release. 5 Year Accident History As an indication of how realistic these Alternative Release Scenarios are, we looked at our releases for the last 5 years. The EPA defined RMP accidents as those involving listed chemicals that resulted in injuries or serious on-site or off-site impact. We have not had any releases that meet EPA's definition. General Accidental Release Prevention Program Several examples of how we design our processes for safety are; automatic fail-safe valving systems are included as part of the design, Process Hazard Analyses are done as part of the design process prior to construction and start-up, Process Hazard Analyses are repeated every three years and improvements made, and leak detection alarms specifically for chlorine and phosgene. We take care of our equipment by the following methods; preventive maintenance programs are in place, all maintenance work is preplanned and safety che cks and reviews are done after the work is completed, periodic inspections and tests are performed on critical devices such as pressure relief devices and rupture discs, alarm and interlock systems are periodically tested, and maintenance technicians are trained and qualified in proper safe work practices. The ways we ensure that we operate our processes safely are; process technicians are trained and qualified in proper safe work practices and handling techniques as well as OSHA Process Safety Management, computerized control systems provide continuous monitoring of the operating process, written operating procedures are reviewed and certified annually, process and maintenance technicians are retrained prior to each campaign of a product. We audit our operations in a number of different ways. Some examples of how we do this important work is; operators patrol the process units throughout each shift, we perform weekly Safety, Health & Environmental audits of the operating areas, Si te and Corporate personnel carry out internal audits and reviews of Process Safety Management systems, pressure relief devices and critical interlocks are routinely inspected, safety reviews precede all startups, our processes are certified under International Organization for Standardization (ISO 9002), all incidents are investigated and recommendations are acted on, and annual audits are conducted by ADEM, FRA, DOT, Aetna Casualty, and other third party agencies to assure regulatory compliance. Emergency Response Program We maintain an emergency response plan, which contains all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. We coordinate our site plan with the community emergency response plan. Some specific aspects of our emergency response program are; our Emergency Response Team (ERT) is on-site 24 hours per day year-round, Transportation Emergency Response Team (TERP) available on-site to respond to transportation related incidents, quarterly training for ERT on-site and at the Avery Oliver Emergency Response Training Center (Fire School on Salco Road), active preventive maintenance and inspection program for on-site fire protection systems, conduct drills and coordinate training with neighboring industry and local fire departments, and coordinate responses to aid other local industries through the Emergency Management Agency (EMA). We have and will continue to reduce the risks associated with handling and using the chemicals we have on our site. We will continue to maintain the active community involvement process we've developed to keep our neighbors abreast of risk management issues related to our site. |