Rhodia, Inc., Baton Rouge Facility - Executive Summary |
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General Executive Summary for the Risk Management Plan at the Rhodia, Baton Rouge facility. LDEQ facility I.D. # 1314 Date of report: 6/16/99 1. Accidental Release Prevention and Emergency Response Policies We at Rhodia, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Sulfuric Acid Manufacturing; Liquid Sulfur Dioxide Manufacturing; Hazardous Waste Incineration; Diphenols Ethers Manufacturing. We have 10 regulated substances present at our facility. These substances include Oleum (Fuming Sulfuric acid) [Su lfuric acid, mixture with sulfur trioxide], Sulfur dioxide (anhydrous), Propionitrile [Propanenitrile], Ethyl chloride [Ethane, chloro-], Methyl chloride [Methane, chloro-], Vinyl acetate monomer [Acetic acid ethenyl ester], Carbon disulfide, Epichlorohydrin [Oxirane, (chloromethyl)-], Methyl mercaptan [Methanethiol] and Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-]. Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide] is used as a chemical intermediate, as a drying agent and is a raw material for dyes and detergents. Sulfur dioxide (anhydrous) is used as a chemical intermediate, refrigerant, bleaching and food processing. Propionitrile [Propanenitrile] Ethyl chloride [Ethane, chloro-], Methyl chloride [Methane, chloro-], Vinyl acetate monomer [Acetic acid ethenyl ester], Carbon disulfide, Epichlorohydrin [Oxirane, (chloromethyl, Methyl mercaptan [Methanethiol] , Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] is received as a waste stream for energy recovery and raw material value. The maximum inventory of Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide] at our facility is 16040580.00 lb. while Sulfur dioxide (anhydrous), Propionitrile [Propanenitrile], Ethyl chloride [Ethane, chloro-], Methyl chloride [Methane, chloro-], Vinyl acetate monomer [Acetic acid ethenyl ester], Carbon disulfide, Epichlorohydrin [Oxirane, (chloromethyl)-], Methyl mercaptan [Methanethiol] and Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] are present at our facility in quantities of 2836501.00 lb., 188665.00 lb., 101596.00 lb., 95412.00 lb., 38556.00 lb., 35939.70 lb., 24020.00 lb., 15755.00 lb. and 14000.00 lb. respectively. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the r equired offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations and the EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Liquid Sulfur Dioxide Manufacturing. In this scenario 300000 lb. of Sulfur dioxide (anhydrous) is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 80% of the maximum capacity of the source by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 19 miles is obtained corresponding to a toxic endpoint of 0.0078 mg/L. The alternative release scenario for Oleum (Fum ing Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide] involves a release from Unit 2 Acid Plant. The scenario involves the release of 2174.16 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.01000 mg/L of Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide] is 0.19 miles. The alternative release scenario for Propionitrile [Propanenitrile] involves a release from a pipe flange. The scenario involves the release of 5274.27 lbs. of liquid and is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of reducing the surface area of the li quid release. The release is also assumed to be controlled by emergency shutdown system(s). These active mitigation systems have the effect of reducing the length of time the release would occure. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0037 mg/L of Propionitrile [Propanenitrile] is 3.0 miles. The alternative release scenario for Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] involves a release from a pipe flange. The scenario involves the release of 1899.03 lb. of toxic liquid and is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of reducing the surface area of the liquid pool. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0070 mg/L of Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] is 2.0 miles. The alternative release scenario for Carbon disulfide involves a release from a pipe flange. The scenario involves the release of 4728.29 lbs. of toxic liquid and is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of reducing the surface area of the liquid pool. The release is also assumed to be controlled by emergency shutdown system(s). These active mitigation systems have the effect of reducing the duration of the release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.16 mg/L of Carbon disulfide is 0.87 miles. The alternative release scenario for Epichlorohydrin [Oxirane, (chloromethyl)-] involves a release from a pipe flange. The scenario involves the rele ase of 3365.63 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of reducing the surface area of the liquid pool. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.076 mg/L of Epichlorohydrin [Oxirane, (chloromethyl)-] is 0.81 miles. The alternative release scenario for Sulfur dioxide (anhydrous) involves a release from the failure of an unloading hose. The scenario involves the release of 1500 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 1 minutes. The release is also assumed to be controlled by emergency shutdown system(s). These active mitigation systems have the effect of reducing the durati on of the release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 0.6 miles. The alternative release scenario for Vinyl acetate monomer [Acetic acid ethenyl ester] involves a release from a pipe flange. The scenario involves the release of 7546.25 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of reducing the surface area of the liquid pool. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.26 mg/L of Vinyl acetate monomer [Acetic acid ethenyl ester] is 0.54 miles. The alternative release scenario for Methyl chloride [Methane, chloro-] involves a release from Diphenols. The scenario involves the release of 5586.40 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of reducing the surface area of the liquid pool. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.82 mg/L of Methyl chloride [Methane, chloro-] is 0.27 miles. The alternative release scenario for Methyl mercaptan [Methanethiol] involves a release from Hazardous Waste Incineration. The scenario involves the release of 817.52 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 20 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of reducing the surface area of the liquid pool. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.049 mg/L of Methyl mercaptan [Methanethiol] is 0.27 miles. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Diphenols. In this scenario 101596 lb. of Ethyl chloride [Ethane, chloro-] is released. The release quantity has been limited to 80% of the maximum capacity of the source by a system of administrative controls. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.28 miles is obtained corresponding to an endpoint of 1 psi over pressure. The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Diphenols. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the rel ease of 611.45 lb. of Ethyl chloride [Ethane, chloro-] in minutes. Passive mitigation controls such as sprinkler system(s) are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include sprinkler system(s). Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi over pressure is 0.02 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Rhodia, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis O ur facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Checklist, What If/Checklist (combined), HAZOP and Fault Tree. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 12/01/1998. Operating Procedures For the purposes of safely conducting activities within our covered processes, Rhodia, Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operato rs involved in the processes. Training Rhodia, Inc. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every year and more frequently as needed. Mechanical Integrity Rhodia, Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Rhodia, Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 04/09/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Rhodia, Inc.. The most recent review was performed on 06/02/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Rhodia, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 07/06/1998. T hese audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Rhodia, Inc. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Rhodia, Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particu lar. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Rhodia, Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History There have been 3 accidental releases of regulated substances from our facility within the last 5 years. The first release took place on 12/21/1995 and involved 209 lb. of Sulfur dioxide (anhydrous). No deaths or injuries occurred offsite as a result of this accident. Onsite, there were no deaths or injuries. Another release, of 5264 lb. of Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide], occurred on 03/30/1996. No deaths or injuries occurred offsite as a result of this accident. Onsite, there were no deaths or injuries. Another release, of 650 lb. of Sulfur dioxide (anhydrous), occurred on 04/26/1996. No deaths or injuries occurred offsite as a result of this accident. Onsite, there were no deaths or injuries. 6. Emergency Response Plan Rhodia, Inc. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. The plan is reviewed by the LEPC and coordinates with the Parish Plan. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a mo dified emergency response. East Baton Rouge LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety In order to encourage continuous improvement in all elements of Process Safety the facility regularly reports progress of improvement efforts that are described in the Process Safety Management Plan. Many of these improvements are results of audits and other reviews such as Management of Change, Process Hazard Analysis, Accident Investigations and others. |