Akzo Nobel Chemicals Inc. - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies: Concern for health, safety and environmental issues forms an integral part of Akzo Nobel's business policy. Akzo Nobel actively supports the guiding principles of the Business Charter for Sustainable Development of the International Chamber of Commerce and the Responsible Care program of the chemical industry. In addition to compliance with regulatory requirements, the following general objectives are pursued: Health: Akzo Nobel seeks to conduct its activities in such a way as to prevent harm to the health of its employees and other persons. Safety: Akzo Nobel strives to prevent all injuries associated with its activities and those of its contractors. Environment: Akzo Nobel protects the environment by minimizing the environmental impact of its activities and its products through appropriate design, manufacturing, distribution, use and disposal practices. To meet these objectives, Akzo Nobel is guided by the following principles: 7 integration of Safety, Health and Environment ('SHE') into operations as a line of responsibility 7 implementation of a SHE policy for all of our activities and products leading to a sustainable business 7 open internal and external communication including SHE reporting 7 cooperation with others in the development of SHE regulations, industry standards and in resolving problems created by past handling and disposal of hazardous substances 7 improvement of SHE aspects of products and processes through targeted research 7 motivation of employees to work in a SHE-responsible manner by proper education and training. Facility Description and Regulated Substances Handled : The Lima facility, which began operation in October 1993, is situated on approximately 6 acres located between BPAmoco and Clark Refinery. The facility consists mainly of a manufacturing/administrative building and three tank farms. The main products manufactured at the Lima facility are called ch elates. Chelates are chemical compounds that have the ability to complex or interact with metal ions like calcium and iron and change the property of the metal ion. For example, chelates will prevent hard water metal ions like calcium from forming precipitates and scale. Because of their unique ability to chelate metals, these chelate products are used in numerous household cleaners, personal care products, photographic processing and a host of industrial applications like pulp and paper manufacture, latex polymerization and energy production to name a few. The Lima facility creates all of its products through hydrocyanic acid ('HCN') chemistry. The facility takes HCN, which is a co-product in the manufacturing of acrylonitrile, from the adjacent BPAmoco facility. The HCN is received through a pipeline from the BPAmoco facility and is piped into reactors. The HCN is reacted with various raw materials to produce the different chelates and other products. The Lima facility han dles four regulated substances above the threshold quantities - HCN, ethylenediamine ('EDA'), formaldehyde solution, and aqueous ammonia. HCN is not 'stored' on-site - it is taken from the BPAmoco pipeline and placed directly into process vessels. EDA is received in rail tank cars and is stored on-site in a 30,000 gallon storage tank. EDA is used as a raw material in the process. Formaldehyde is received in tank trucks and is stored in a 30,000 gallon storage tank. Formaldehyde is also used as a raw material in the process. Aqueous ammonia is a raw material in one process and a co-product in another process. It is stored in one of two 30,000 gallon storage tanks, depending on which process it is associated with. Aqueous ammonia is delivered and shipped in tank trucks. Worst-Case Release Scenario and Alternative Release Scenarios: The Lima facility has reviewed all the covered processes at the facility to determine which Worst Case Release Scenario and Alternative Release Scenarios (ARS) would be reported. All scenarios were calculated using the RMP*Comp software, which is based on the EPA Offsite Consequence Analysis ('OCA') Guidance. All assumptions made in the OCA guidance (i.e. wind speed and stability, release elevation, etc.) were used in the scenario evaluation. Based on the number of buildings and structures surrounding the plant, urban topography was used in all modeling. In each ARS evaluation, the facility chose to consider 'worst case' type conditions (i.e. response teams taking longer than expected, etc.). The Worst Case Scenario, which involves a toxic release from the cyanide weigh tank (a tank used to verify the weight of HCN prior to being placed in the reactor) results in offsite impacts on neighbors, a public recreation area (the Rotary River Walk) and industrial facilities. This scenario takes into consideration administrative controls that limit the amount of HCN in the weigh tank, which include operating procedures, operato r training, computer interlocks and redundant monitoring systems. These controls limit the weight of HCN in the weigh tank, which has a capacity of 5,800 pounds, to the maximum charge weight of 2,900 pounds. In addition to the administrative controls, a containment dike, considered passive mitigation, would control the release as the HCN is liquefied by refrigeration. This concrete dike acts to control the release to the atmosphere because it reduces the surface area of the release and thus reduces the release rate. The ARS for HCN involves a toxic release caused by a gasket leak on the feed pump from the HCN weigh tank to the reactor. The feed pump creates a flow rate that averages approximately 20 lb/min. The gasket leak would allow approximately 20% of the flow to be released. Due to HCN monitoring equipment located around the weigh tank, the control room operators would know immediately that an HCN leak existed and could shut the pump down and close all necessary valves fr om the control room. It is assumed the release can be stopped and the system isolated within 10 minutes. All of the material released would be contained in the containment dike around the weigh tank and weigh tank pump because the HCN is liquefied by refrigeration. This reduces the surface area of the release and thus reduces the release rate to 4 pounds/minute. The release would have offsite impacts on the industrial facilities adjacent to the facility, but would not impact other public or environmental receptors. The ARS for EDA involves a toxic release caused by total failure of the offloading hose from the rail car to the storage tank. The rail car offloads from the top and is pressurized to assist the pump in offloading. The failure of the line would allow the EDA to release through the failed hose until the pressure is released and/or the valve on the discharge connection is closed. It is assumed it will take the response team 30 minutes to accomplish this. All of the material released would be contained in the containment dike around the rail car and offloading pump. This reduces the surface area of the release and thus reduces the release rate to 17.9 pounds/minute. The release would have offsite impacts on the industrial facilities adjacent to the facility, but would not impact other public or environmental receptors. The ARS for Formaldehyde Solution involves a toxic release caused by total failure of the offloading hose from the tank truck to the storage tank. The tank truck offloads from the bottom of the truck. It is assumed the entire contents of the tank truck releases through the discharge line prior to it being shut down. The release would be contained in the containment dike around the storage tank and truck offloading area. This reduces the surface area of the release and thus reduces the release rate to 0.8 pounds/minute. The release would have offsite impacts on the industrial facilities adjacent to the facility, but would n ot impact other public or environmental receptors. The ARS for aqueous ammonia involves a toxic release caused by total failure of the offloading hose from the tank truck to the storage tank. The tank truck offloads from the bottom of the truck. It is assumed the entire contents of the tank truck releases through the discharge line prior to it being shut down. The release would be contained in the containment dike around the storage tank and truck offloading area. This reduces the surface area of the release and thus reduces the release rate to 45.2 pounds/minute. The release would have offsite impacts on the industrial facilities adjacent to the facility, but would not impact other public or environmental receptors. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps: The facility strives to prevent accidental releases through many varied approaches. First, the facility has complied with the OSHA PSM regulation since the facility was built in 1993. The facility has applied the spirit of the PSM regulation to all facility activities, not just those covered by the regulation. This is evidenced by the facilities involvement with the Chemical Manufacturers Association's Responsible Care program. Due to this proactive approach, procedures are already in place and active for the RMP covered processes. The facility has many technological prevention steps, which include: 7 computerized control systems 7 computerized interlocks and permissives 7 redundant controls on critical systems In addition, the facility has trained operators running the processes. Each operator goes through extensive training, including classroom, computer based and on-the-job training prior to becoming certified operators. To assist the operators in running the plant safely, the facility has many operating procedures. These procedures direct operators in how to properly run the given process. The facility also has a trained maintenance staff to properly maintain all process equipment. Maintenance team members perform many tasks, ranging from preventative inspections and testing to calibrations to repairs of equipment. Key to the entire prevention program is involving the operators in all aspects of the plant SHE programs. The Lima facility operators are an integral part in Process Hazard Analyses, Pre-Startup Safety Reviews, operating and SHE procedures development and modifications, Managements of Change, Incident Investigations, and many other areas. Five-Year Accident History: The Lima facility has had no accidental releases as defined by the EPA of listed chemicals from covered processes. Emergency Response Program: The Lima facility has a comprehensive emergency response program that follows the National Response Team One Plan guidance. The facility is prepared to address many types of emergencies, including chemical releases, medical emergencies, and fires. The facility has three internal alarm systems, a fire alarm, an evacuation alarm and an emergency alarm. If the event requires off-site assistance, phone calls will be made to the appropriate agencies. Arrangements have been made with the Shawnee Fire Department to assist with any emergency in which they are needed. Shawnee Fire Department has toured the facility and been involved with some of the on-site annual training excercises. The emergency response plan has been reviewed with the Shawnee Fire Department and other local response agencies that might be called in on an emergency. The Emergency Response Team, which currently consists of all chemical operators, is trained to address all types of emergencies. Each team member goes through extensive training on the chemicals handled on-site, their hazards, proper emergency response techniques, first aid and CPR, proper use of fire extinguishers and many other topics. In depth annual refresher training for the entire team involves a mixture of classroom training and hands-on respon se excercises. In addition, each shift conducts one emergency response drill every month, ranging from chemical emergencies to medical emergencies to combinations of both. Planned Changes to Improve Safety: The Lima facility is always looking for ways to improve on safety related issues. Through Incident Investigations and other related tools, improvements in operations or equipment will be evaluated and implemented, as necessary. The facility continually trains employees in the areas of health, safety and environmental protection. This training includes monthly training on various topics, annual refresher training in emergency response, hazard communication and many other areas, etc. |