Rubicon Inc. - Executive Summary |
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Executive Summary Rubicon Inc. is located near the city of Geismar in Ascension Parish. Specifically, Rubicon is located on Highway 75 about 1 mile south of the intersection of Highway 75 and Highway 73. Rubicon's Louisiana Risk Management Program Facility Identification Number is 1468. Rubicon handles seven chemicals that are regulated under the Risk Management Program. They are Ammonia, Chlorine, Ethylene Oxide, Formaldehyde, Phosgene, Propylene Oxide, and Toluene Diisocyanate. These chemicals are contained in one regulated process called Polyurethanes. This process produces two products: 1. Polyurethanes which consists of Toluene Diisocyanate and Methylene Diisocyante, and 2. Diphenylamine. These products have a wide variety of commercial uses including automotive, building materials, appliances, footwear, and sporting goods. Accidental Release Prevention Program Rubicon's philosophy on accidental release prevention is a portion of our overall philosophy on safety which is to provide our employees a safe work place. By providing our employees a safe work place, the public is kept safe as well. Rubicon has done a good job in achieving this goal as evidenced by our safety record. Rubicon has worked over seven million man hours without a lost time accident and our injury rate is well below the industry average. Also, during the past five years, we have not had a release of a regulated risk management chemical which had on onsite or offsite impact. Rubicon has many programs in place for accident prevention in order to maintain this record and improve upon it. These programs include good engineering design and the use of standards such as API are used in the design of a proposed project. Continuing Hazard Studies are conducted on our existing units and any change which is made to a unit. Various safety procedures are in place to prevent releases such as Lock Out/Tag Out, Confined Safe Entry Procedure and Entry Permit, Electrical Work Procedure, Hot Work Procedure, Railroad Blue Flag Procedure, Policy for Hose Use and Utility Line Labeling, and Policy for Controlled Valves. Each unit has a Unit Policy Book that include procedures (such as management, operational, communications, safety, environmental, personnel, traffic, and benefits) specific to the Unit. Each unit conducts extensive training for operators to gain knowledge of the processes and associated hazards. Each unit utilizes continuous process control and monitoring with manual overrides. The operators perform visual inspections of process equipment daily. A trained contract maintenance crew knowledgeable of Rubicon processes and chemicals is utilized by each unit. Each unit performs industrial hygiene monitoring of personnel including continuous wearing of phosgene badges for those units that use phosgene. Each incident that occurs is investigated and the results of these investigations is shared among the units. Rubicon also performs two other functions which pre vent accidents. First, we have a quality control system in place which monitors all incoming raw materials and products to prevent reactivity and incompatibility. Secondly, there is an onsite Inspection and Testing Department which inspects and tests all process equipment according to API standards. This department also includes Reliability Engineers that investigate root cause and the prevention of repetitive failures. Most of the programs listed above are part of OSHA's Process Safety Management Program which Rubicon is required to comply with. However, Rubicon had these programs in place prior to when the Process Safety Management Program became effective. These are the programs that are necessary to achieve our main goal of providing a safe work place. Risk Management Program Release Scenarios Worst Case Scenario Rubicon's worst case release scenario is the failure of a chlorine railcar that holds 180,000 pounds of chlorine. This scenario produced the largest radius of imp act of all the regulated chemicals. The release was modeled using the Safer Trace Air Dispersion Model Version 8.0b. All the inputs required by 40 CFR 68.25 for the worst case scenario analysis were utilized in the model. The resulting impact from this scenario is a radius of forty-two miles. The release is modeled using the assumption that the wind is blowing in all directions simultaneously. This produces an impact area shaped like a circle with the release site being at the center of the circle. In event of an actual release the area of impact would be in the shape of a slice of pie spreading out along the direction of the wind with the release site being at the tip of the slice of pie. Rubicon is reporting this release scenario impact as greater than twenty-five miles in the RMP submital due to large inaccuracies of the air dispersion model past five miles and due to the extreme conservatism used in the assumptions for the worst case scenario. EPA states in their offsite con sequence analysis guidance document concerning worst case scenario modeling: "The consequences of an accidental chemical release depend on the conditions of the release and the conditions at the site at the time of the release. This guidance provides reference tables of distances, based on results of modeling, for estimation of worst-case and alternative scenario consequence distances. Worst-case consequence distances obtained using these tables are not intended to be precise predictions of the exact distances that might be reached in the event of an actual accidental release. For this guidance, worst-case distances are based on modeling results assuming the combination of worst-case conditions required by the rule. This combination of conditions occurs rarely and is unlikely to persist for very long. To derive the alternative scenario distances, less conservative assumptions were used for modeling; these assumptions were chosen to represent more likely conditions than the worst-case assumptions. Nevertheless, in an actual accidental release, the conditions may be very different. Users of this guidance should remember that the results derived from the methods presented here are rough estimates of potential consequence distances. Other models may give different results; the same model also may give different results if different assumptions about release conditions and/or site conditions are used. The reference tables of distances in this guidance provide results to a maximum distance of 25 miles. EPA recognizes that modeling results at such large distances are highly uncertain. Almost no experimental data or data from accidents are available at such large distances to compare to modeling results. Most data are reported for distances well under 10 miles. Modeling uncertainties are likely to increase as distances increase because conditions (e.g., atmospheric stability, wind speed, surface roughness) are not likely to remain constant over large distances. Thus, at large distances (e.g., greater than about 6 to 10 miles), the modeling results should be viewed as very coarse estimates of consequence distances. EPA believes, however, that the results, even at large distances, can provide useful information for comparison purposes. For example, Local Emergency Planning Committees (LEPCs) and other local agencies can use relative differences in distance to aid in establishing chemical accident prevention and preparedness priorities among facilities in a community. Since worst-case scenario distances are based on modeling conditions that are unlikely to occur, and since modeling of any scenario that results in large distances is very uncertain, EPA strongly urges communities and industry not to rely on the results of worst-case modeling or any modeling that results in very large toxic endpoint distances in emergency planning and response activities. Results of alternative scenario models are apt to provide a more reasonable basis for planning and re sponse." Alternate Case Scenarios Ammonia Rubicon's alternate scenario for ammonia is a relief valve failure on the ammonia storage tank. This release lasts twenty minutes and releases 11,080 pounds of ammonia. The resulting impact of this release is a radius of 0.8 miles. The release is modeled using the assumption that the wind is blowing in all directions simultaneously. This produces an impact area shaped like a circle with the release site being at the center of the circle. In event of an actual release the area of impact would be in the shape of a slice of pie spreading out along the direction of the wind with the release site being at the tip of the slice of pie. The meteorological conditions used in this assessment are the average meteorological conditions for 1988 through 1992 from the Baton Rouge Airport. Chlorine Rubicon's alternate scenario for chlorine is a hose failure during the unloading of chlorine. This release lasts twenty minutes and releases 12,280 pounds of chlorine. The resulting impact of this release is a radius of 4.1 miles. The release is modeled using the assumption that the wind is blowing in all directions simultaneously. This produces an impact area shaped like a circle with the release site being at the center of the circle. In event of an actual release the area of impact would be in the shape of a slice of pie spreading out along the direction of the wind with the release site being at the tip of the slice of pie. The meteorological conditions used in this assessment are the average meteorological conditions for 1988 through 1992 from the Baton Rouge Airport. Ethylene Oxide Rubicon's alternate scenario for ethylene oxide is a relief valve failure on the ethylene oxide storage tank. This release lasts twenty minutes and releases 10,000 pounds of ethylene. The resulting impact of this release is a radius of 1.1 miles. The release is modeled using the assumption that the wind is blowing in all directions simultaneousl y. This produces an impact area shaped like a circle with the release site being at the center of the circle. In event of an actual release the area of impact would be in the shape of a slice of pie spreading out along the direction of the wind with the release site being at the tip of the slice of pie. The meteorological conditions used in this assessment are the average meteorological conditions for 1988 through 1992 from the Baton Rouge Airport. Formaldehyde Rubicon's alternate scenario for formaldehyde is a hose failure during the unloading of formaldehyde. This release lasts twenty minutes and releases 20,000 pounds of formaldehyde. The resulting impact of this release is a radius of 0.7 miles. The release is modeled using the assumption that the wind is blowing in all directions simultaneously. This produces an impact area shaped like a circle with the release site being at the center of the circle. In event of an actual release the area of impact would be in the shape of a slice of pie spreading out along the direction of the wind with the release site being at the tip of the slice of pie. The meteorological conditions used in this assessment are the average meteorological conditions for 1988 through 1992 from the Baton Rouge Airport. Phosgene Rubicon's alternate scenario for phosgene is a transfer line failure caused by a crane severing the line during the transferring of phosgene. This release lasts five minutes and releases 3,800 pounds of phosgene. The resulting impact of this release is a radius of 9.7 miles. The release is modeled using the assumption that the wind is blowing in all directions simultaneously. This produces an impact area shaped like a circle with the release site being at the center of the circle. In event of an actual release the area of impact would be in the shape of a slice of pie spreading out along the direction of the wind with the release site being at the tip of the slice of pie. The meteorological conditions used in this assessment are the average meteorological conditions for 1988 through 1992 from the Baton Rouge Airport. Propylene Oxide Rubicon's alternate scenario for propylene oxide is a hose failure during the unloading of propylene oxide. This release lasts twenty minutes and releases 20,000 pounds of propylene oxide. The resulting impact of this release is a radius of 0.7 miles. The release is modeled using the assumption that the wind is blowing in all directions simultaneously. This produces an impact area shaped like a circle with the release site being at the center of the circle. In event of an actual release the area of impact would be in the shape of a slice of pie spreading out along the direction of the wind with the release site being at the tip of the slice of pie. The meteorological conditions used in this assessment are the average meteorological conditions for 1988 through 1992 from the Baton Rouge Airport. Toluene Diisocyanate Rubicon's alternate scenario for tol uene diisocyanate is the failure of a vessel called the TDI reboiler during the normal production of toluene diisocyanate. This release lasts ten minutes and releases 500 pounds of toluene diisocyanate. The resulting impact of this release is a radius of 1.4 miles. The release is modeled using the assumption that the wind is blowing in all directions simultaneously. This produces an impact area shaped like a circle with the release site being at the center of the circle. In event of an actual release the area of impact would be in the shape of a slice of pie spreading out along the direction of the wind with the release site being at the tip of the slice of pie. The meteorological conditions used in this assessment are the average meteorological conditions for 1988 through 1992 from the Baton Rouge Airport. Five Year Accident History During the past five years, Rubicon has not had a release from a covered process which resulted in a death, an injury, or significant property damag e on site, or a known offsite death, injury, evacuation, sheltering in place, property damage, or environmental damage. Emergency Response Program Rubicon's Emergency Response Program consists of two elements: preparation and response. Our philosophy is prevention first and preparedness for response to incidents if needed. Practices at Rubicon for preventing situations that could possibly lead to a release incident are the training of Internal Emergency Response Units. These units are a Fire Brigade, HAZMAT personnel and equipped van, medical first responders with equipped ambulance and a first aid station with nurse, specialized teams in vertical and confined space rescue teams, and emergency incident drills. Another important aspect of Rubicon's Emergency Response Program is communication. Rubicon has the following internal and external communication systems in place for emergency response for coordination with Ascension Parish Sheriff and Office of Emergency Preparedness: two way radios, public announcement systems in the Units, telephone system with backup, cellular phones and faxes, alarm and horn warning systems, "88" phone system, GAMA radio, community sirens that can be heard over 40 miles, Cam telephone message system for 2.5 mile radius, and local television and radio. Rubicon also works closely with outside authorities and other neighboring companies to coordinate emergency response. These are Geismar Area Mutual Aid (GAMA), State Police, Ascension Parish Sheriff Department, Ascension Parish Office of Emergency Preparedness, Geismar Fire Department, Prairieville Fire Department, Red Cross, Riverview Medical Center (Gonzales), Ascension Hospital (Gonzales), Our Lady of the Lake Regional Hospital (Baton Rouge), General Medical Center (Baton Rouge), and Summit Hospital (Baton Rouge). In most cases, Rubicon performs annual training with these organizations or provides information about Rubicon that is necessary for coordinated emergency response. Ru bicon has also developed many Emergency Action Plans for many types of emergencies. These include SPC/SPCC Plan, RCRA Contingency Plan, Policy for Emergency Action, Procedure for Emergency Brigade, Procedure for "88" Phone System, Emergency Procedure for Radiation Sources, Evacuation Procedure, Bomb Threat Procedure, and a Hurricane Procedure. Response practices used during any kind of emergency which causes a release are basically the same. These practices include, wind socks to determine wind direction, a Safer System for dispersion modeling of gas release, monitoring on-site and off-site by HAZMAT response personnel for chlorine, phosgene, ammonia, ethylene oxide, propylene oxide, toluene diisocyanate, water curtains for air releases, and equipment and/or unit shutdown(s). Planned Changes to Improve Safety Rubicon's current philosophy on major safety improvements is to evaluate the use of pipelines in place of tank trucks or rail cars for transportation of chemicals. Switching to pipelines allows Rubicon to reduce storage of these chemicals and it promotes less handling of these chemicals through less loading and unloading. Pipelines also benefit the public because there is less transportation of these chemicals through their neighborhoods thus lowering the possibility of accidents. Currently Rubicon has installed pipelines for chlorine, ethylene oxide, formaldehyde, benzene, and nitric acid with other chemicals being evaluated for pipelines. The bottom line is that Rubicon already conducts our business safely and effectively which is demonstrated by our outstanding safety record. Rubicon has, for the last 28 years effectively managed our systems to minimize risk to our employees, our neighbors and our community. Rubicon is committed to maintaining this high standard of performance and plans to enjoy many more safe, productive years in this area. Rubicon is a good company and an excellent neighbor. Rubicon will continue to strive towards improving th e safety of our facility for our employees, our near neighbors, and our community. |