Georgia Gulf Corporation - Plaquemine Facility - Executive Summary |
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General Executive Summary for Chemical Manufacturing Facilities 2694 - LDEQ Facility ID Number GEORGIA GULF CORPORATION, PLAQUEMINE FACILITY 1. Accidental Release Prevention and Emergency Response Policies Georgia Gulf Corporation, Plaquemine Facility is 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 and to protect people, property and the environment. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass the manufacture of Aromatic Chemicals, Electrochemicals and Polyvinyl Chloride (PVC) Resins. We have two regulated substances above the RMP threshold qu antity present at our facility. These substances are Chlorine, and Vinyl chloride monomer. Chlorine and is used in the manufacture of vinyl chloride monomer. Vinyl chloride is used for feedstock in the manufacture of PVC resin. 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 required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance 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 of chlorine from its storage vessel (91% of the storage capacity is released). The scenario involves a large release which creates a 1 cm pool from which evaporation takes place over a 10 minute period. In order for this worst case scenar io to occur the storage vessel would have to be almost completely destroyed, all of our safety systems would have to fail, all of our personnel would have to do nothing, the vessel would have to be full, and specific weather conditions would have to be present. In the unlikely event that every one of these conditions was to occur, the maximum distance to the EPA's toxic endpoint of .0087 mg/L or 3 ppm is greater than 25 miles. Although the EPA does not allow companies to consider any active safety measures when analyzing the worst case scenario, Georgia Gulf has a number of safety systems in place to prevent a release from ever occurring at the chlorine storage vessel. The vessel meets strict design and construction standards. It is constructed of 1 inch-thick steel and wrapped with a 1 = inch-thick layer of insulation to help control the temperature and pressure inside the vessel. To prevent the vessel from over pressuring and releasing, the vessel has two relief valves. These r elief valves are tested every two years. An isolation valve is located on the discharge of the vessel to shut off flow if there is a rupture downstream of the valve. Numerous instrument alarms are in place to warn of potential equipment malfunction, including multiple pump malfunction. In addition, we have a facility-wide leak detection and repair program to identify and repair leaks before they could ever result in an emergency. The alternative release scenario for Chlorine involves a release from a chlorine rail car unloading hose. The scenario involves the release of 20000 lb. of chlorine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The release is estimated to take place over a period of 10 minutes. The release is also assumed to be controlled by Operator Intervention. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of chlorine is 6.2 miles. Georgia Gulf has installed safet y systems to prevent a railcar unloading hose failure from occurring. The hoses used at Georgia Gulf exceed the design and construction requirements for our railcar unloading conditions. Each unloading hose is inspected prior to each use, and the hose fittings are replaced whenever indications of visible wear are present. There is a relief valve on every railcar to prevent the railcar and unloading hose from over pressuring. We have instrument alarms to warn of potential equipment malfunction and equipment shutdowns to shut off flow. Each station is monitored by an operator. An automatic shutoff valve is located on each railcar to shut off flow if the unloading hose fails. We have multiple remote block valves, check valves, and a control valve that can shut off flow to the railcar unloading line to isolate and limit any release. An operator is located at all times within 100 feet of the railcars, which will ensure that the release can be manually isolated quickly. The worst c ase release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release of Vinyl chloride monomer (VCM). In this scenario 8500000 lb. of VCM is released. 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 1.22 miles is obtained corresponding to an endpoint of 1 psi over pressure. Georgia Gulf has a number of safety systems in place to prevent a release from ever occurring at the sphere. The spheres where VCM is stored meet strict design and construction standards. It is constructed of 1 1/4 inch-thick steel. To prevent the vessel from over pressuring and releasing, the sphere has two relief valves. These relief valves are tested every two years. An automatic isolation valve is located on the discharge of the sphere to shut off flow if there is a r upture downstream of the valve. Numerous instrument alarms are in place to warn of potential equipment malfunction, including multiple pump malfunction alarms and automatic shutdowns on the sphere pumps. Remote valves are installed to isolate and limit any release from the sphere. In addition, we have a facility-wide leak detection and repair program to identify and repair leaks before they could ever result in an emergency. This program includes scheduled monitoring of pumps, valves, connectors, and other equipment using portable hydrocarbon leak detectors. When a leak is found, it is repaired and remonitored to verify that it is leak free. The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release of VCM. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 38000 lb. of Vinyl chloride in 5 minutes. The scenario involves a the mechanical failure of a pressure relief valve causing it to li ft prior to reaching its set point. The release duration is also controlled by active mitigation measures that include operator intervention. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi over pressure is 0.13 miles. No offsite population or receptors are effected. Georgia Gulf carries out maintenance checks on a regular basis to ensure proper operation of relief valves. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 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 accidental release prevention and proce ss safety managements programs that are in place at our facility. Process Safety Information (PSI) Georgia Gulf maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis (PHA) Our 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 "HAZOP" and/or"What If". The studies are undertaken by a team of qualified personnel with expertise in engineering, process operations, and environmental, health and safety, and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, we maintain written operating procedures. These procedures address various modes of ope ration 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 workers involved in the processes. Training Georgia Gulf 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 three years and more frequently at intervals determined by the complexity of the process and employee input. Mechanical Integrity Georgia Gulf 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 pers onnel 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 to manage changes in process chemicals, technology, equipment and procedures. 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 prior to working with the modified process. In addition operating procedures and associated PSI are updated as required. 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 Georgia Gulf. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Incident Investigation Georgia Gulf 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 We 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 particular. Georgia Gulf has been recognized by the Chemical Manufacturers' Association for having Employee Involvement pr ograms that are "Examples of Excellence in the Chemical Industry." 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. Georgia Gulf Corporation, Plaquemine Facility 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 Georgia Gulf Corporation has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, only one accidental release of a regulated substance has occurred during this period. There has been only one accidental release of a regulated substance from our facility within the last 5 years. This release took place on 04/11/1995 and involved 478 lb. of Hydrogen Chloride (conc. 37% or greater) and 63 lb. of Vinyl Chloride No deaths or injuries occurred on or offsite. 6. Emergency Response Plan Georgia Gulf has 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. 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 modified emergency response. Emergency responders are trained or drilled on a quarterly basis. Iberville Parish Office of Emergency Preparedness is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Retaliation of our Process Hazard Analysis and Operator Requalification are some of the major steps we want to take to improve safety at our facility. These changes have already begun. |