Grant Chemical Division - Executive Summary
3387 LDEQ Facility ID Number |
Accidental Release Prevention and Emergency Response Policies
The Ferro Corporation, Grant Chemical Division (Grant Chemical) has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as the training of personnel and consideration of safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of substances. If, in spite of all precautions, a release does occur, Grant Chemical's trained personnel will respond to control and contain the release.
Description of the Facility and Regulated Substances Handled
Grant Chemical manufactures, processes and store specialty chemicals in Zachary, East Baton Rouge Parish, Louisiana and evaluated the facility to determine if any regulated flammable or toxic substances exceeded threshold quantities. Based on process knowledge, G
rant Chemical identified the regulated substances and quantities kept on site. The facility uses five regulated substances in four separate processes. The chemicals and largest quantity on site (either as largest quantity in a single process or total quantity of mixtures) are: acetaldehyde (37,000 lbs); ethyl chloride (74,000 lbs); formaldehyde (60,000 lbs); methyl chloride (220,000 lbs); and phosphorus tricloride (88,000 lbs).
In addition, Grant Chemical is subject to Occupational Safety & Health Administration (OSHA) Process Safety Management (PSM) and is classified under a listed SIC Code (2869). Therefore, the four Grant Chemical processes are classified as Program 3 processes under the Accidental Release Prevention (ARP) Program.
Flammable Substances: The endpoint for the worst-case release of flammable substances is 1 pound per square inch (psi) over pressure (i.e., 15.7 psia) for vapor cloud explosions. The ARP Program requirement for flammables
assumes an instantaneous release and vapor cloud explosion. The distances to the endpoint of 1 psi over pressure for the worst-case release of ethyl chloride using the EPA lookup table is 0.25 miles.
Toxic Substances: Toxic endpoints are listed in Appendix A to 40 CFR Part 68 (Table of Toxic Endpoints). Each of the three regulated toxic substances at Grant Chemical was reviewed to determine the substance with the greatest distance to endpoint. Based on the EPA lookup tables, a worst-case release of methyl chloride results in a distance to the toxic endpoint of approximately 3 miles.
Alternative Release Scenarios
Alternative release scenarios are those that are more likely to occur than the worst-case release scenario. Alternative release scenarios for toxic substances should be those that lead to concentrations above the endpoint beyond the facility's fence line. Conditions considered for alternative release scenarios are: a release rate dependent upon scenario; use of
typical meteorological conditions at the stationary source; the actual release height; and consideration of active and passive mitigation systems.
Flammable Substances: A single alternative release scenario for all flammable substances is required under the ARP Program. A hypothetical release scenario has been identified for ethyl chloride as follows. A 2-inch nozzle on the ethyl chloride tank breaks off, allowing release of the contents into the tank dike. The ethyl chloride will vaporize and may ignite in a vapor cloud explosion. The distance to the 1 psi over pressure endpoint for the alternative-case release of ethyl chloride using the EPA lookup table is less than 0.06 miles.
Toxic Substances: One alternative release scenario for each toxic substance is required under the ARP program. A hypothetical release scenario has been identified for the regulated toxic substances at Grant Chemical to determine the distance to an endpoint for each. Based on the EPA lookup ta
bles, the substances and the distances to toxic endpoints are: formaldehyde (0.06 miles); methyl chloride (0.81 miles); phosphorus trichloride (0.26 miles).
General Accidental Release and Chemical Specific Prevention Program
At Grant Chemical, processes regulated by the EPA's risk management program (RMP) regulation are also subject to the OSHA's PSM standard, and a brief summary of each OSHA PSM element is provided.
Employee Participation: Grant Chemical encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as members of process hazard analysis (PHA) teams. In addition, Grant Chemical has a number of initiatives under way that address process safety and employee safety issues. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant
Process Safety Information: Grant Chemical keeps a variety of technical documents that are used to help maintain safe operation of the processes. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information.
Chemical-specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals.
The plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that s
afety features in the process are not compromised.
Process Hazard Analysis (PHA): Grant Chemical has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure the adequate controls are in place to manage these hazards.
Grant Chemical primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.
The PHA team finding
s are forwarded to management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, Grant Chemical periodically updates and revalidates the hazard analysis results.
Operating Procedures: Grant Chemical maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. The procedures are kept current and accurate by revising them a
s necessary to reflect changes made through the management of change process.
Training: To complement the written procedures for process operations, Grant Chemical has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations if they are not already familiar with such operations. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level.
Contractors: Grant Chemical uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do
in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, Grant Chemical evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Reviews (PSSRs): Grant Chemical conducts a PSSR for any facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one add
itional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
Mechanical Integrity: Grant Chemical has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process.
ntenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). Another integral part of the mechanical integrity program is quality assurance. Grant Chemical incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.
Hot Work Permits and Other Safe Work Practices: Grant Chemical has long-standing safe work practices in place to help ensure worker and process safety. A hot work permit system is used to control po
tential ignition sources. Other procedures include: confined space entry; lockout/tagout to ensure isolation of energy sources; work permits to assure safe removal of hazardous substances before process piping or equipment is opened; and personal protective equipment to provide employee protection. Training of personnel in safety procedures helps ensure that operations and maintenance activities are performed safely.
Management of Change: Grant Chemical has a comprehensive system to manage changes to all covered processes. This system addresses changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process ope
rating limits, and equipment information, as well as procedures, are updated to incorporate these changes.
Incident Investigation: Grant Chemical promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident.
Compliance Audits: To help ensure that the accident prevention program is functioning properly, Grant Chemical periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Both hourly and staff personnel participate as audit team members.
Chemical-Specific Prevention Steps
The processes at Grant Chemical have hazards specific to the individual chemicals that must be managed to ensure continued safe op
eration. These are addressed through operating procedures for the BzPA, DXA, DXL and Glymes Units. In addition to other measures, flammable materials (ethyl chloride and others) are stored and used under nitrogen blanket to prevent mixing with air which could form flammable mixtures. Toxic substances are stored under pressure (methyl chloride) or under nitrogen blanket (acetaldehyde) at lower pressures to prevent atmospheric venting or introduction of air or moisture (phosphorus trichloride).
Grant Chemical has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release.
Five-Year Accident History
Grant Chemical has not had any accidental releases during the past five years which meet the criteria for an accidental release per 40 CFR 68.42.
Emergency Response Program Information
Grant Chemical maintains a written emergency response plan to protect worker and public safety as wel
l as the environment during an emergency. The plan consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including first aid and medical treatment, evacuation and accounting for personnel, notification of local emergency response agencies and the public if a release occurs, incident mitigation and post-incident cleanup and decontamination requirements. The plant routinely performs maintenance on emergency equipment including tests and inspections and provides employee training on equipment use. Employees receive training as necessary to perform their specific emergency response duties. The emergency response plan is updated when necessary based on modifications made to plant processes or for changes in personnel.
The overall emergency response program for Grant Chemical is coordinated with East Baton R
ouge Parish emergency response officials and the Zachary Fire Department. Periodic meetings with response agency personnel are conducted to discuss needs and concerns in the event of an incident at the plant. Grant Chemical has around-the-clock communications capability with state and federal agencies and with local emergency response agencies through a hotline system to access additional emergency equipment and services (i.e., firefighting equipment, manpower, ambulances, hospitals, law enforcement, and HAZMAT operations). Notification of the public by local officials can also be accomplished through hotline notifications. Grant Chemical conducts periodic emergency drills that involve local emergency response organizations.
Planned Changes to Improve Safety
Grant Chemical has several elements of the management system of the accident prevention program in place to improve safety throughout the facility. These elements are part of an overall ongoing safety improvement process.