Procter & Gamble Ivorydale - Executive Summary |
|
PREVENTION IS OUR FIRST PRIORITY - LONG-STANDING COMMITMENT TO SAFETY AND ENVIRONMENTAL STEWARDSHIP Procter & Gamble (P&G) has a long-standing commitment to maintaining a safe work environment for our employees and minimizing the impact of our operations on the environment, as outlined in our Corporate Environmental Policy. Our safety and environmental programs are managed by qualified employees on site, and are actively supported by the participation of all employees and all management, and a strong central staff. The goal of both the safety and environmental programs is prevention. Safety teams which focus on training and special projects have been formed in every department across this site. Although P&G's safety record is already among the best in the business, we are constantly striving for improvement. We have recently begun a project to eliminate the storage of sulfur trioxide (SO3) on site. This new system will generate, and immediately use, SO3 directly from raw material s, resulting in a safer operation. This system will be operational by June 2000. P&G is very committed to the safety and protection of our employees and our neighbors. P&G employees are active participants in the Local Emergency Planning Commission (LEPC). P&G has supported emergency response capabilities in the community by providing financial support to the Greater Cincinnati Hazardous Materials Unit. Many employees participate in their community as volunteer fire fighters and emergency medical technicians. Many employees receive first aid and CPR training as part of our sites emergency response team. P&G is also very committed to the safety and protection of the natural environment. This manufacturing site has reduced it wastes by over 60% over the last 5 years. P&G has received numerous environmental awards. P&G employees have participated in the Hamilton County Environmental Priorities Project, Mill Creek Restoration Project, Hamilton County gas cap testing for cleaner air, the "Do Your Share for Cleaner Air" program, and the Winton Hills Winton Place collaborative to address environmental concerns in the neighborhood. P&G has been a member of the Alliance for Chemical Safety since its founding and is a participating member in the Three Hills Community Advisory Panel. SYSTEMS AND PROCESSES FOR SAFE USE OF SULFUR TRIOXIDE The P&G Ivorydale site manufactures an ingredient for laundry detergent. Sulfur trioxide (SO3) is one of the key raw materials used to make the ingredient. SO3 is delivered to our site by dedicated, specially-designed tanker trucks and is unloaded into a storage tank. The storage tank is above ground, enclosed in a building, and has liquid containment. The tank is visually inspected and the metal walls are routinely tested for integrity. The truck unloading area is contained by a dike. The storage and unloading areas are remotely monitored continuously by video cameras placed in critical areas. The storage tank is maint ained at the lowest possible temperature in order to keep the SO3 in a liquid state for use in our process. Any slight amount of vapors present when opening the tank truck for unloading and during maintenance are collected in a mist vacuum and scrubber system, used to remove those vapors from the air. SO3 is completely consumed in the making of the detergent ingredient by our processes. MINIMIZING POTENTIAL FOR ACCIDENTAL ATMOSPHERIC RELEASES A detailed hazard study has been conducted, per the requirements of the OSHA Process Safety Management (PSM) system, to identify potential points from which SO3 may be spilled or leaked from the process. These points have received special consideration during the process design, the training of operators and maintenance personnel, and in the development of our accident prevention and response systems. The study is updated routinely by a team of specially trained employees and engineers. Training, maintenance, controls, operating practices , and purchasing requirements are revised based on the results of these hazard studies. A "worst case release" is defined by EPA as an instantaneous release of the single largest vessel, during a time of light winds and stable weather conditions. An instantaneous release of this kind could be caused by an earthquake or by an airplane hitting the tank truck. The worst case release assumes that no emergency response would occur, even though both the site response team and the local Hazardous Materials team are trained to respond to this type of spill. The spill of an entire tanker truck would be confined to an existing diked area. Therefore, although we have prepared for this scenario, we feel it is extremely unlikely to occur. The alternative release scenario is defined as a scenario which results in a release with off-site consequences and which occurs during more routine weather conditions. The scenario chosen by the site as the one potential scenario with the largest off-sit e consequences would be failure of a transfer hose during unloading of the SO3 from the tank truck. Mitigation and response mechanisms may be considered when analyzing this scenario. The use of foam suppression systems, containment dikes, emergency response team efforts and all other process safety mechanisms in place would limit the impact of this scenario. Again, we believe this scenario is very unlikely to occur, but we have prepared for it with our prevention and emergency response plans. In order to estimate the off-site consequences of any release, modeling was done using the OCA Guidance from USEPA, as well as a more sophisticated model, PHAST, that is able to account more accurately for the specific factors involved in a release of SO3. Data were reported for the results of the modeling. Both cases would have offsite consequences. ASSESSMENT OF PLANT COMMUNITY - HUMAN AND ENVIRONMENTAL SAFETY CONSIDERATIONS The goal of the safety & environmental programs at P&G is preve ntion. In order to best prepare for prevention of community impacts, a computer model was run to estimate the distance a vapor cloud at a certain concentration (predetermined by EPA) could travel in the unlikely event of the worst case scenario as defined above, with no available emergency response. In this worst case scenario, the affected distance from the tank was calculated using the EPA guidance and another model that allowed for better analysis of this particular chemical. Once the distance was determined for the release, a study was done of the impact on populations, including sensitive receptors, such as churches, schools and shopping centers, and environmental receptors. Should such an incident actually occur and since the winds would blow the cloud in only one direction, or would disperse the cloud more quickly if it was to blow in multiple directions, the actual impacts would be less than those presented for the worst case release. The same procedure was applied to the alternative case scenarios chosen and the one with the greatest impact was reported. For the same reasons, we expect the actual impacts to be less than those reported should this incident actually occur. However, we planned for the full extent of the modeling results. Should either of these incidents occur, population around the plant, including some schools, could be affected. SAFETY AND PREVENTION The first line of defense at our plant is accident prevention. The entire SO3 system has numerous and redundant process controls, detection and alarm systems, and an emergency shut-down system. Highly skilled operators monitor the process around the clock from a control room equipped with cameras and computers that monitor important data on the liquid levels in the tanks, the temperature and pressure of the tank contents, operating parameters and important unloading information such as the tanks volume. SO3 will be unloaded into the storage tank only when there is enough space to allow unloading all the contents of the trucks load. This procedure of hookup, unload, and disconnect only once minimizes the risk of accidental spills. The equipment and process have been designed to withstand all expected occurrences and to respond either automatically or with operator intervention should some deviation be noted in the operation of any of the equipment. Even the tank truck drivers receive specialized training to handle this material safely. Detailed operating and maintenance procedures are used to ensure everyone is using the best known methods for safe operation. Routine preventive maintenance is performed on the system and equipment to prevent problems from developing. Some equipment is routinely replaced to prevent problems from occurring. The process design and operating systems are continually assessed and improved through a procedure detailed by the OSHA regulations for Process Safety Management (PSM). Process operators, engineers, and the site safety leaders work together to implement the OSHA PSM program. Improvements resulting from these assessments over the last five years included improvements to our piping inspection program, additional alarm installation, an improved emergency shutdown system and several improvements to the mist eliminator (vacuum and scrubber) system. In the event of an accident, the site has systems to respond to the spill or leak quickly. Spills or leaks of SO3 can be quickly communicated to the emergency responders by personnel on the scene from phones located in the control room and throughout the SO3 unloading and storage areas. Since SO3 forms a white cloud if released, visual detection is very reliable. All operators carry walkie-talkies and are in constant contact with the control room. Notification of a problem to security at the main gate office will result in immediate notification to the entire site via walkie-talkies, pagers, alarms and phone contact. If warranted, contact with the loca l fire department will be made by the main gate personnel. The fire department will respond to the plant within minutes of receiving the request for assistance. The police and fire departments have procedures to manage communications and instructions to the public by means of the emergency siren, TV and radio broadcasts, and by direct communications in the streets of affected neighborhoods. Response drills are conducted annually with the aid of the local emergency responders. The drills allow the opportunity to train new responders, to refresh the skills of the experienced responders, and to improve the communications and response systems. Equipment that may be used to respond during a real emergency, such as a foam system, is activated during these drills. The local Fire department and Hazmat teams are toured through the site on a regular basis to maintain their awareness of what is on site and where critical materials are stored. HISTORY OF SAFE OPERATIONS The Ivorydale si te has an excellent history of SO3 system safety. There have been no reportable accidents at this site involving SO3 or the SO3 system that caused injury or property damage to anyone on site or off site in the history of the plant. We have experienced one minor incident in the last five years, resulting in a small release with no off-site consequences. ALL EMPLOYEES RECEIVE SAFETY AND ENVIRONMENTAL TRAINING All of the SO3 system operators have been qualified in all of our standard operating procedures. The operating procedures include both routine and non-routine operations. Employees trained in hazardous materials response are available around the clock. Employees participate in the emergency response drills held annually. The results of both hazard assessments and the emergency response drills are communicated to the operating teams. Special environmental and emergency response training is conducted at least annually with all employees to refresh them on procedures and to in troduce new improvements. EMERGENCY RESPONSE PLANS DEVELOPED WITH LOCAL EXPERTS An emergency response plan has been developed and coordinated with the LEPC, including the fire department, hospitals, and police. As recommended by the EPA, this plan is developed using their "One Plan" guidance for ease of use. This plan is the basis for the drills which are conducted annually. Improvements are made to the plan on a regular basis as a result of learnings from the drills or as changes occur. |