DSM Chemicals North America, Inc. - Executive Summary

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Risk management Plan 
Executive Summary 
WHO IS DSM? 
DSM is a highly integrated international group of companies that is active worldwide in the field of chemicals, biotechnological products and plastic materials. The group is headquartered in Heerlen, The Netherlands, with annual sales in excess of $7 billion and employs about  23,000 people at more than 200 sites in Europe, North and South America, Asia, Africa and Australia. 
DSM's Corporate SHE Policy 
Responsible Care is a worldwide action program set up by the chemical industry to ensure ongoing improvement of the chemical industry's performance in the field of Safety, Health and Environment (SHE) and to promote communication on SHE matters. DSM considers proper SHE management to be a fundamental part of its operations. We have incorporated the main SHE elements in a management system that is closely linked to the Responsible Care program and is at the same time based on the ISO 9000 and ISO 14000 standards. DSM's SHE policy clearly  
states what the company understands by safe, healthy and environmentally conscious working. Our policy objectives are: 
7 an accident-free working environment. DSM is convinced that all accidents can be prevented. 
7 no occupational diseases or health problems attributable to DSM's activities. 
7 ongoing evaluation and improvement of working methods, processes, products and services to ensure that these are safe and acceptable from the point of view of employees, customers, the community and the environment. 
In order to achieve these objectives we have laid down a number of principles that apply throughout the DSM organization: 
7 SHE management is just as important as production, marketing, profitability and product quality. 
7 All our sites are subject to the same SHE standards. 
7 Each site has its own SHE management system. 
7 Each site is subject to regular audits. 
7 Each site reports on its SHE performance. 
7 Each site actively communicates with the neighboring community. 
WHO IS DSM Che 
micals North America, Inc.? 
The DSM facility in Augusta was originally a joint venture between DSM of The Netherlands and PPG Industries of Pittsburgh, PA. Founded in 1962, the joint venture's first production facility was a nitrogen fertilizer complex. In 1964, Nipro, Inc., (the predecessor of today's DSM Chemicals) was organized to manufacture caprolactam, a monomer of nylon used in nylon fiber production. Subsequent expansions of DSM Chemicals resulted in two additional caprolactam plants in Augusta, in 1974 and 1976, which made DSM Chemicals the largest independent supplier of caprolactam in the U.S.  In 1999 nylon 6 production  began at the DSM Augusta site. In late 1999, a carpet recycle facility will begin recovering the original pure caprolactam from waste carpet and nylon scrap. 
WHAT DOES DSM Chemicals MEAN TO AUGUSTA? TO GEORGIA? 
The DSM Chemicals plant facilities and sales offices in Augusta mean jobs for approximately 376 company employees and 250 contract employees. In ter 
ms of dollars, DSM Chemicals means annual domestic sales in excess of $108,000,000, export sales of over $75,000,000 and an annual payroll of over $25,000,000. 
What is Caprolactam? 
Caprolactam is the primary raw material in the production of nylon 6. At the Augusta DSM plant the caprolactam is stored in tanks in the liquid state by keeping it heated to 1700 F and in the flaked solid state in bags. The liquid product is shipped to local customers and the solid product is shipped to foreign customers. DSM's customers convert the caprolactam to nylon 6 and then make carpets, lining materials, clothing, shoes, stockings, and lingerie.  
 
 
 
 
Oleum 
Basic Information 
7 Oleum, also known as fuming sulfuric acid, is basically a clear liquid with a slight milky-gray tint and a severely irritating odor. Exposure to the liquid causes tissue destruction. Oleum is a severe fume hazard. The fumes are sulfur trioxide, are severely irritating and concentrations over 3 ppm are harmful.  
7 Oleum is used a 
s a sulfating agent, dehydrating agent, in dyes, in explosives, and in petroleum refining. At DSM it is used to convert our intermediate product to our final product, caprolactam. After it is neutralized with ammonia, the oleum is in turn converted to ammonium sulfate, a by-product fertilizer. 
Worst Case  Release Scenario 
7 A full 279,000 gallon tank of 24% oleum fails catastrophically. 4,490,000 pounds of oleum are released instantaneously. A containment dike will limit the downwind impact of this scenario. 
7 EPA look-up tables predict the fumes will travel 1.9 miles before the fume concentration in air will fall to 3 ppm, which is considered a safe level.  
 
Alternate Release Scenario 
 
7 A supply pipe fails while transferring 24% oleum at the rate of 250 gallons per minute. The release continues for 10 minutes before it is discovered and the flow is stopped. 43,000 pounds of oleum are released.  
7 EPA look-up tables predict the fumes will travel 0.47 mile before the fume concentration 
in air will fall to 3 ppm, which is considered a safe level.   
 
Five Year Accidental Release History  
There was one spill of oleum during the last five years. There were no offsite effects from this 3,000 pound spill but the local emergency management agency was notified. 
 
Chemical - Specific Prevention Steps 
 
7 Oleum tank fumes are vented to a scrubber that recovers the fumes. 
7 Oleum tanks and pumps are diked to limit spills and the downwind impact of the above scenarios. 
7 Oleum is piped to our plant from the nearby supplier, thus, eliminating the risk of spills while unloading from tanker trucks. 
7 A spare storage tank is maintained. 
 
            
Ammonia 
Basic Information 
7 Ammonia is a colorless gas with a very strong pungent odor, that is supplied to DSM as a liquid at high pressure and low temperature via piping. Ammonia is very irritating to mucous membranes, eyes and skin. Direct contact with liquid ammonia can cause severe burns. The vapor is extremely irritating and concentrations 
over 200 ppm are harmful.  
7 Ammonia is one of the most commonly used chemicals in the United States for a variety of industrial, commercial and agricultural purposes. DSM uses it as a refrigerant and as a raw material to produce aqua ammonia and hydroxylamine. 
Worst Case Release Scenario 
7 A 3" supply pipe fails while transferring liquid ammonia at the rate of 300 gallons per minute. The release continues for 10 minutes before it is discovered and the flow is stopped. 27,440 pounds of ammonia are released. No controls are considered.  
7 EPA look-up tables predict the ammonia vapors will travel 3.8 miles before the vapor concentration in air will fall to 200 ppm, which is considered a safe level. 
Alternate Release Scenario 
7 A >"  supply pipe fails while transferring ammonia gas. The release continues for 10 minutes before it is discovered and the flow is stopped. The total release is 500 pounds.  
7 EPA look-up tables predict the ammonia vapors will travel 0.19 miles before the vapor  
concentration in air will fall to 200 ppm, which is considered a safe level. 
Five Year Accidental Release History 
There was one spill of ammonia during the last five years. There were no offsite effects from this 130 pound gas release but the local emergency management agency was notified. 
Chemical - Specific Prevention Steps 
 
7 Ammonia inventory was minimized by the removal of an ammonia tank. Inventory is limited to the contents of piping from our supplier, PCS Nitrogen, located close to our plant. 
 
Planned Changes to Improve Safety 
 
7 A new piping inspection program will periodically monitor the condition of ammonia piping. 
Aqua Ammonia 
Basic Information 
7 Aqua ammonia is also known as ammonia water, ammonium hydroxide and household ammonia in very dilute solution. Aqua ammonia is a colorless liquid with a strong characteristic odor. Concentrations of solution range up to 30% ammonia in water. Like ammonia, aqua ammonia is very irritating to mucous membranes, eyes and skin. The vap 
or is extremely irritating and concentrations over 200 ppm are harmful.  
7 Aqua ammonia is used for a variety of industrial, commercial, agricultural, pharmaceutical and household purposes. DSM uses it to neutralize oleum and produce a by-product fertilizer, ammonium sulfate. 
Worst Case Release Scenario 
7 A full 50,000 gallon tank of 22% aqua ammonia fails catastrophically. 380,000 pounds of aqua ammonia are released instantaneously. No controls are considered.  
7 EPA look-up tables predict the ammonia vapors will travel 3.4 miles before the vapor concentration in air will fall to 200 ppm, which is considered a safe level. 
Alternate Release Scenario 
7 A >" supply pipe fails while transferring liquid aqua ammonia. The release continues for 10 minutes before it is discovered and the flow is stopped. The total release is 10,620 pounds.  
7 EPA look-up tables predict the ammonia vapors will travel 0.19 mile before the vapor concentration in air will fall to 200 ppm, which is considered a sa 
fe level. 
 
Five Year Accidental Release History 
There was one spill of aqua ammonia during the last five years. There were no offsite effects from this 3,000 gallon spill but the local emergency management agency was notified. 
 
Chemical - Specific Prevention Steps 
 
7 A spare storage tank is maintained. 
 
Planned Changes to Improve Safety 
 
7 New process data monitors and computer system alarms are planned to alert operators of possible ammonia releases. 
 
Methane 
Basic Information 
7 Methane, also known as natural gas, is a colorless, odorless, tasteless and highly flammable gas that is lighter than air. Natural gas is delivered with a strong odorizer to give it a distinctive smell. Methane can be a simple asphyxiant by displacing oxygen from the atmosphere; otherwise, no acute or long term health effects are known. Natural gas can also exist in a liquid state at cryogenic temperatures of -260 degrees F. In the liquid form it is colorless and non-flammable; however, the cold vapors are v 
isible at the liquid surface and will ignite. Skin contact with liquid natural gas may cause cryogenic burns or frostbite; tissue damage may result from inhalation of super cooled vapors.  
7 Methane is primarily used as a fuel. At DSM, it is used in the gaseous state as a fuel and as a raw material to produce hydrogen, an intermediate product. At DSM it is stored in the liquid state and is vaporized prior to use. 
Worst Case Release Scenario 
7 A full 1,200,000 gallon tank of liquid natural gas (LNG) fails catastrophically. 4,150,000 pounds of methane are released instantaneously. A vapor cloud explosion is assumed to occur. This tank is surrounded by a containment dike, which will limit the downwind impact of this scenario. 
7 EPA look-up tables predict the blast effects of a vapor cloud explosion will travel 0.29 mile before the over pressure level is reduced below one psi, which is the point at which only slight injuries are expected due to flying debris. 
Alternate Release Scenario 
7 A 
n unloading hose fails while a full 9,500 gallon tanker truck of LNG is being unloaded into the tank. A large pool of LNG forms in the ditch, flows away from the truck and begins to vaporize. A  vapor cloud fire is assumed to occur.  5500 pounds/minute of LNG are released during the 15 minute period it takes the Emergency Response Team to close the shut-off valves.  
7 EPA look-up tables predict the radiant heat effects of a vapor cloud fire will travel 0.20 miles before the concentration falls to the lower flammability limit of  5 % by volume. 
 
Five Year Accidental Release History 
There were no spills or releases of methane during the last five years . 
Chemical - Specific Prevention Steps 
 
7 LNG tank vapors are vented to a compressor that recovers the vapors for in plant use as fuel. 
7 LNG storage tank is surrounded by a containment dike. 
7 LNG storage tank is equipped with fire suppression systems. 
 
Cyclohexane 
Basic Information 
7 Cyclohexane is a colorless liquid with a slightly swe 
et and somewhat pleasing odor. Cyclohexane is very flammable in air even in small volumes. The flammable vapors are heavier than air and tend to accumulate on the ground rather than disperse. Cyclohexane is not a listed chemical subject to EPA's Risk Management Plan regulation; however, it is considered the most serious hazard in the DSM plant. 
7 Cyclohexane is used in the manufacture of nylon, as a solvent and as a paint and varnish remover. DSM uses it as a raw material to produce caprolactam. 
Worst Case Release Scenario 
 
7 A process pipe fails while transferring liquid cyclohexane at a temperature above its atmospheric boiling point. 600,000 pounds of cyclohexane are released and immediately vaporize. A vapor cloud explosion is assumed to occur. No controls are considered. This scenario was selected because it actually happened at a DSM facility in England with catastrophic results. 
7 EPA look-up tables predict the blast effects of a vapor cloud explosion will travel 0.64 mile befor 
e the over pressure level is reduced below one psi,  which is the point at which only slight injuries are expected due to flying debris. 
Alternate Release Scenario 
 
7 An unloading hose fails while a full 28,000 gallon rail tank car of cyclohexane is being unloaded into the tank. Large pools of cyclohexane form in the ditches beside the railroad tracks. A  pool fire is assumed to occur. 1800 gallons per minute of cyclohexane are released during the 15 minutes it takes the Emergency Response Team to close the shut-off valve.  
7 EPA look-up tables predict the radiant heat effects of a pool fire will travel 0.2 mile before the heat intensity falls to 5 KW/M2, which is the point at which only second degree burns  are expected after 40 minutes exposure. 
Five Year Accidental Release History 
There were four spills of cyclohexane during the last five years; the two largest were each 8,000 gallons. There were no offsite effects but the local emergency management agency was notified. 
Chemical - S 
pecific Prevention Steps 
 
7 Cyclohexane storage tank is surrounded by a containment dike or wall. 
7 Cyclohexane storage tank is equipped with fire suppression systems. 
7 Cyclohexane storage tank fumes are vented to a recovery system to eliminate emissions. 
7 Cyclohexane process areas are equipped with vapor detection systems that will automatically activate  a water sprinkler system. 
7 Cyclohexane process areas are equipped with heat sensors that will automatically activate a water sprinkler system. 
7 Cyclohexane process areas are equipped with several containment dikes to limit the impact of spills and the above scenarios. 
7 Cyclohexane process vessels and piping in hot service are made of crack resistant stainless steel, welded, x-rayed and hydrostatically tested to the most rigorous standards of the ASME codes. 
7 Cyclohexane vapors from vessels and safety valves are vented to a flare to be burned and thus limit any further downwind hazard. 
 
Cyclohexane (Continued) 
Planned Changes to 
Improve Safety 
 
7 Cyclohexane storage tank is periodically inspected to find and fix flaws. 
7 Cyclohexane storage tank vacuum breaker is heated and insulated to prevent pluggage during cold weather. 
7 Cyclohexane rail cars are purged with nitrogen gas to reduce explosive hazard. 
7 Cyclohexane process piping with open ends are capped to prevent inadvertent spills or fires. 
 
 
We prevent these accidents by 
Designing for Safety 
7 Tanks are made of crack-resistant carbon steel, welded, x-rayed and tested per API 620 or 650.  
7 Process data are continuously monitored by computer system alarms to alert operators. 
7 System design incorporates multiple layers of protection, that is, redundant safeguards. 
7 Operating personnel work in blast proof buildings capable of withstanding nearby fire or explosion. 
Maintaining our plant 
7 Maintenance personnel are trained and highly skilled. 
7 Critical equipment including tanks, relief devices, hoses, piping, instruments and shutdown systems are teste 
d and inspected regularly to assure proper operation. 
7 Preventive Maintenance program is in place and practiced. 
7 Equipment is tested and rechecked by operations after it is worked on by maintenance. 
Operating safely 
7 Operators are trained and certified per OSHA  requirements. 
7 Continuous computer and operator monitoring and surveillance. 
7 Written operating and safety procedures based on process risk analysis and OSHA standards. 
7 Controlled entry to all operating and storage areas. 
7 Work permit system to control hazardous work in operating areas. 
Auditing our operations 
7 Independent audits and reviews: 
7 Fire protection 
7 Government agencies- DOT, OSHA, US EPA, GA EPD. 
7 Internal audits and reviews : 
7 ISO9000 
7 PSM 
7 DSM Headquarters 
7 Management Safety Inspections 
7 Operator Safety Inspections 
7 Prestartup Safety Reviews prior to startup of new or modified equipment in a process area. 
7 Process Hazard Analyses. 
7 Review of proposed design changes for proper design and compl 
ete documentation. 
7 Routine safety audits of safe work practices. 
7 Investigation of all accidents and incidents to determine the root cause. 
 
In-Plant Emergency Response 
Training and Preparation 
7 Written plant emergency response plan. 
7 Simulation drills conducted regularly. 
7 Critiques of drills and actual events. 
7 Participation in simulation drills with community responders. 
7 Emergency Response Team, 90 member, available 24 hours per day. 
7 Emergency Response Team trained in fire fighting, spill control and first aid. 
7 Emergency response equipment, including full fire fighting capabilities, located throughout facility. 
If a release does occur 
7 Emergency Response Team activated. 
7 Warning devices installed to warn on-site and neighboring personnel with preprogrammed messages. 
7 Computer system provides weather conditions and modeling of gas/vapor releases. 
7 Preplanned release scenarios available to allow quick preliminary evaluation of impact. 
7 Fire monitors and automatic 
sprinklers provide a water spray to cool tanks and knockdown vapors. 
7 Modern spill containment equipment located on site for quick spill containment.
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