Arch Chemicals, Inc. - Shreveport Plant - Executive Summary |
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2340 LDEQ Facility ID Number Arch Chemicals, Inc. Shreveport, Louisiana RMP Executive Summary 1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Arch Chemicals, Inc. - Shreveport Plant, 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 management activities that we have designed and implemented, including: a. A description of our facility and use of substances regulated by EPA's RMP regulation b. A summary of results from our assessment of the potential offsite consequences from accidental chemical releases c. An overview of our accidental release prevention programs d. A five-year accident history fo r accidental releases of chemicals regulated by EPA's RMP rule e. An overview of our emergency response program f. 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 g. The certifications that EPA's RMP rule requires us to provide h. The detailed information (called data elements) about our risk management program 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility produces oleum by passing sulfur trioxide gas through a packed tower and contacting it with 35% oleum. 98% or 99% sulfuric acid is added to the tower to control the product strength at approximately 35% oleum. Oleum has been identified by the EPA as having the potential to cause significant offsite consequences in the event of a substantial accidental release. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards tha t are posed to our employees, the public, and the environment by our use of this chemical. 3.0 OFF-SITE CONSEQUENCE ANALYSIS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario(s) - Regulated Toxic Chemicals The worst case scenario selected for the Arch - Shreveport facility involves the catastrophic rupture of one of the 1000 ton Oleum storage tanks into a diked area. Worst case meteorological data as defined in the RMP rule was used in the evaluation. Based on the tables provided in the Rule, the estimated exposure distance would be approximately 0.81 miles. Approximately 10 residences are within this radius, along with a number of public receptors adjacent to the facility. The Emergency Response Progra m developed for the facility will address releases of this magnitude. A more likely scenario would be one where a two-inch loading line separates from a railcar. However, due to constant attendance by employees, the duration of this release would only be approximately one minute, and the distance to the endpoint would be only 0.64 miles. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. We maintain a number of programs to help prevent accidental releases and ensure safe operation. The accident prevention programs in place include, among others: - 24-hour operator oversight - Tank and piping inspections - Use of proper materials of construction - Process Hazard Analyses (Hazard and operability analysis/keyword reminder check) - Industrial hygiene surveys - "Near miss" incident investigations - Hazcom training - PPE training As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: - 24-hour operator oversight of oleum process These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5.0 FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. However, there have been no significant chemical releases from the oleum process within the five-year report period. When incidents do occur, we conduct formal incident investigations to identify and correct the root causes of the events. 6.0 EMERGENCY RESPONSE PROGRAM We maintain an Emergency Response P lan which has been coordinated with the local fire department and the LEPC. Our plan provides the essential planning and training for effectively protecting the workers, the public, and the environment during emergency situations. 7.0 PLANNED CHANGES TO IMPROVE SAFETY We are in the process of installing continuous level measurement instrumentation for our Oleum Storage tanks to help prevent and/or improve our response to accidental chemical releases. |