Callaway Chemical Company - LOS Plant - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The LOS plant has a long-standing commitment to worker and public safety and to the protection of the environment. We are committed to operating and maintaining all of our processes in a safe and responsible manner, as demonstrated by the resources we invest to prevent accidents. As a member of the Chemical Manufacturers Association, we adhere to the principles of Responsible Care.. In addition to ensuring that our employees have the best possible training in the operation of our processes, we demand that safety be the first priority in the design, installation, operation, and maintenance of our processes. We have implemented maintenance and inspection programs that ensure site integrity. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. Examples of controls to prevent releases include (1) installation of pressure relief valves to prevent rupture of vessels due t o overpressurization, (2) routine visual inspection and thickness checks to ensure vessels and piping are in good condition, (3) using materials of construction that are compatible with the process chemistry and (4) vessel pressure and temperature are continuously monitored. However, if a release does occur, trained personnel will respond to control and contain the release. Mitigation measures that have been included in our design include installation of isolation valves, fire suppression systems in areas where flammable chemicals are present and fire fighting equipment in all process areas, a fully implemented emergency response plan, appropriate PPE and an alarm system for early notification of a release. The local fire department and hazmat team are also familiar with our site and our ER team has trained with them. STATIONARY SOURCE AND REGULATED SUBSTANCES The LOS plant is primarily involved in manufacturing polyamine, polyamide and polyacrylamide polymers and also makes gl ycidyl ethers and esters. As a part of this manufacturing process, we use three substances that are covered by the risk management program (RMP) rule (40 CFR 68). When handling these materials, we use a combination of good design practices, an accidental release prevention program, and an emergency response program to ensure the safety of our employees, the public, and the environment. We are committed to operating our facility in a safe and responsible manner. Following is a brief description of the facility and a list of RMP-regulated processes at our facility. The LOS plant is situated on a 31 acre site that also includes Callaway's Technical Center. Covered chemicals include Dimethylamine, Epichlorohydrin and Ethylenediamine. Maximum quantities of these chemicals are 300,000 pounds of epichlorohydrin, 61,500 pounds of dimethylamine and 42,000 pounds of ethylenediamine. All processes are subject to Program Level 3. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPAs RMP rule (40 CFR 68) requires that we provide information about two types of offsite consequence analysis scenarios: worst-case scenarios and alternative release scenarios. There are strict requirements for choosing and modeling worst-case release scenarios; as a result, these scenarios are often exceedingly conservative. The purpose of the alternative release scenarios is to provide emergency planners with more information about the chemicals we handle and about their relative hazards. The alternative release scenarios are more realistic than worst-case release scenarios but are still unlikely to happen. Following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures that limit exposure distances. Worst-case toxic release scenario The worst-case toxic release scenario for Callaway-LOS is a catastrophic rupture of a storage tank containing epichlorohydrin. The entire quantity of epichlorohydrin, 300,000 lb, is released t o our containment dike. The containment dike greatly reduces the offsite effect of the release by limiting the size of the liquid pool that results from this spill. The epichlorohydrin that evaporates from this pool travels approximately 0.40 miles before dispersing below the toxic endpoint. Approximately 50 people live within this distance from the storage tank. The public and environmental receptors that are located within this distance include: a few houses, Bull Creek and several industries in the Columbus East Industrial Park. Worst-case flammable release scenario The worst-case flammable release scenario for Callaway-LOS is a catastrophic rupture of a storage tank containing dimethylamine solution. Although the dimethylamine solution is a liquid at ambient conditions, we assume that all 61,500 lb of the solution (containing 36,900 pounds of dimethylamine) vaporizes and explodes. The pressure wave resulting from this explosion travels about 0.25 miles before reaching the 1 -psi overpressure endpoint. No people live within this distance from the storage tank. The public and environmental receptors that are located within this distance include: Bull Creek and several industries in the Columbus East Industrial Park. Alternative toxic release scenario The alternative release scenario for ethylenediamine is a break in the hose used for unloading ethylenediamine from a tank truck. A total of 7,050 lb escapes through this hose over a 3 minute period before the operator can close the valve and forms a liquid pool on the concrete area surrounding the storage tank. The ethylenediamine evaporates from the liquid pool and travels less than 0.1 miles before dispersing below the toxic endpoint. No people live within this distance from the storage tank. The public and environmental receptors that are located within this distance include: Bull Creek. The alternative release scenario for epichlorohydrin is a break in the hose used for unloading epichlorohydrin fro m a railcar. A total of 7,380 lb escapes through this pipe over a 2 minute period before the operator can close the valve and forms a liquid pool. The epichlorohydrin evaporates from the liquid pool and travels about 0.20 miles before dispersing below the toxic endpoint. No people live within this distance from the storage tank. The public and environmental receptors that are located within this distance include: Bull Creek and several industries in the Columbus East Industrial Park. Alternative flammable release scenario The alternative release scenario for dimethylamine is a break in the hose used for unloading dimethylamine from a tank truck. A total of 10,000 lb escapes through this hose before the operator can close the valve and forms a liquid pool on the concrete. The pool ignites, and the resulting fire poses a thermal hazard to anyone within about 0.05 miles from the storage tank. No people live within this distance from the storage tank. The public and environmental receptors that are located within this distance include: Bull Creek and three industries within the Columbus East Industrial Park. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management system addresses each of the key features of a successful prevention program, as described below in Sections 4.1 through 4.12. PROCESS SAFETY INFORMATION The LOS plant maintains a variety of technical documents that describe the chemicals and processes at our facility. These documents are kept up to date and are available to all employees and address important process parameters such as (1) operating limits for the equipment, (2) design basis and configuration of the equipment, and (3) physical properties and hazards of the chemicals used in our processes. Chemical information is usually documented within Material Safety Data Sheets (MSDSs). MSDSs conta in information concerning both the physical properties and the hazards associated with each chemical. This information typically includes (1) toxicity information, (2) physical data, (3) reactivity and corrosivity data, (4) thermal and chemical stability data, and (5) hazards of mixing substances together. MSDSs are available to all employees, as well as the emergency responders in our community. MSDS's for all LOS chemicals are maintained on site. Important process parameters are also documented and maintained. Engineering design documents may include (1) operating limits, (2) block flow or simplified process flow diagrams, (3) process chemistry, (4) maximum intended inventories, (5) design basis and configuration, (6) piping and instrumentation diagrams, and (7) other information that is important for understanding the design intent, operating limits, and hazards of each process. PROCESS HAZARD ANALYSIS The LOS plant has a comprehensive program for ensuring that the hazards as sociated with our processes are identified and controlled. Each process is examined in detail to ensure that all hazards are identified and that appropriate controls are in place to manage those hazards. A hazard and operability (HAZOP) analysis is typically used for our process hazard analyses. A team comprising personnel with engineering, operations, environmental and maintenance experience systematically examines each hazard in each section of the process and identifies potential causes and a range of possible consequences. The team then compares the hazard to the existing set of prevention and mitigation measures designed to contain that hazard, making further recommendations when deemed necessary. These recommendations are resolved by management and are tracked until they are implemented. We update and revalidate each process hazard analysis every five years or whenever a significant change is made. The results and findings from these revalidation studies are documented and retained, and recommendations are tracked until resolved by management. OPERATING PROCEDURES Our engineers, operators, and supervisors work together to develop and maintain operating procedures that ensure the safe operation of our facility. These procedures cover all modes of operation, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new or improved process. Operating procedures are used as a reference by experienced employees and provide a consistent basis for training new employees. In addition to describing the steps for safely conducting operations, the procedures also contain valuable information about safe upper and lower limits, consequences of deviations, and applicable safety and health information. Operating procedures are annually certified as accurate to ensure that they are updated following process changes. The LOS Plant also operates using the Callaway batchsheet system. Batchsheets are the detailed operating procedures for making a batch of product. The batchsheets include process deviation codes describing the actions to take under various conditions (e.g., high temperature, high pressure, loss of cooling, etc) that may be encountered while manufacturing batches of hazardous chemicals. TRAINING The LOS plant trains workers to safely and effectively perform their tasks. Employees who are new to a process are given basic training that includes (1) a general overview of the process, (2) the properties of the substances used in the process and their associated hazards, and (3) a detailed review of the operating procedures for that process. Once they have demonstrated their understanding of this initial training, they are paired with an experienced operator to learn their specific job functions and tasks. After they demonstrate their competence in performing these tasks, they are allowed to work independently. Through oral reviews, written tests, and on-the-job demonstration, we ensure that our employees understand the training given to them. The frequency of refresher training is decided, in part, by our employees but is performed at least every three years. All training given to an employee is documented, along with the means used to verify that the training is understood. MECHANICAL INTEGRITY The LOS plant maintains the mechanical integrity of our equipment to prevent equipment failures that could endanger workers, the public, or the environment. Our inspection and testing program helps identify equipment damage or deterioration before the equipment fails. When a deficiency is found, maintenance personnel will correct the problem and try to identify the root causes of the deficiency so that future problems are avoided. Our quality assurance system ensures that new or replacement equipment meets the strict design standards required for service in our facility. The mechanical integrity system includes (1) insp ection and testing procedures, (2) replacement equipment specifications, (3) procedures for safe work practices, (4) maintenance personnel training, and (5) required documentation. MANAGEMENT OF CHANGE We review any changes to our processes to determine if new hazards are introduced or existing prevention measures are threatened. Except for replacements-in-kind (e.g., replacing a valve with an identical valve), all changes are subjected to a hazard analysis to ensure that (1) new hazards are not inadvertently introduced into the system, (2) safety consequences resulting from the change are addressed, (3) operators in the process are notified of the change and made aware of possible repercussions, and (4) all training material, process safety information, and operating procedures are updated. The management of change system applies to changes in the chemicals used, process equipment, technology, procedures, and other facility changes. PRE-STARTUP REVIEW Whenever a change occurs t hat requires updating the process safety information, the LOS plant performs a pre-startup safety review. This review ensures that safety features, procedures, personnel, and the equipment are prepared for service before the process is restarted. A pre-startup review will generally include field verification of new construction and also serves a quality assurance function by verifying that accident prevention measures are implemented correctly. Generally, a pre-startup review will ensure that (1) construction and equipment are consistent with design standards, (2) adequate operating, safety, and maintenance procedures are in place, (3) training for all affected employees is complete, and (4) a process hazard analysis has been performed, if necessary. INCIDENT INVESTIGATION The LOS plant trains its employees to promptly investigate each incident that resulted in, or could have resulted in, serious injury to employees, the public, or the environment. Incident investigations are desi gned to determine the facts, identify the root causes, and provide recommendations for ensuring that the incident does not recur. Corrective actions resulting from an incident investigation are tracked until they are resolved. Incident investigations are conducted in accordance with Callaway Safety Standard 201 and utilize Non-Conformance Notices (NCN's) that are defined through our ISO Problem Elimination System Procedure (AP-010). EMPLOYEE PARTICIPATION The LOS plant encourages employees to be involved in every aspect of process safety management and accident prevention. Employees are routinely asked to participate in process hazard analyses, incident investigations, management of change hazard analyses, and all other aspects of the prevention program. Employees have access to all information developed as part of the prevention program, and are specifically informed of any changes that occur in their process areas. The various ways employees are involved in the prevention prog ram are documented in a written plan. SAFE WORK PRACTICES The LOS plant has established safe work practices that ensure the safety of our employees. Examples of these procedures include (1) a hot work permit that is designed to control spark- or flame-producing activities, (2) a permit and procedure to control confined space entry, and (3) a lockout/tagout procedure for isolating energy sources during maintenance. These procedures and permits ensure that operations and maintenance activities are performed safely. CONTRACTORS The LOS plant uses contractors for various activities, such as maintenance and construction. All contractors are evaluated to ensure that they are well trained and are able to perform their job function in a safe manner. A contractors safety record and performance are reviewed during the selection process. Once a contractor is selected, the LOS plant provides training and procedures to ensure that contractor employees (1) perform their work in a safe manner , (2) are aware of the hazards associated with the area in which they will be working, (3) understand the emergency response procedures, and (4) report any hazards they find during their work. Our personnel periodically monitor contractor activities to ensure they are performing their work in a safe manner. COMPLIANCE AUDITS A compliance audit is performed periodically to help ensure that the prevention program activities at our facility are adequate and that safety issues are addressed effectively. Audits are performed by a team that is knowledgeable in our processes, but is independent of our facility, to ensure a thorough and complete evaluation. The audit team systematically evaluates each aspect of the prevention program, ensuring both compliance with the RMP rule and effective hazard prevention. The results of audits are documented, and recommendations are tracked until they are resolved. Compliance audits are conducted at least every three years. CHEMICAL-SPECIFIC PREVEN TION STEPS The prevention program described previously ensures the safe operation of our facility by providing our employees with a system they can use to safely perform their job functions. This management system helps prevent hazards associated with equipment failures and human error. In addition to the prevention program, the LOS plant has safety features built into the design of our facility that help to ensure safe process operation for our employees, the public, and the environment. These features may contain or control a release, detect a release, or reduce the consequences of a release. They may also prevent a release by providing strict design standards for process equipment. The following types of safety features are used in various processes in our facility: Release detection 7 Procedures require that a LOS plant employee be present during loading and unloading operations Release containment and control 7 Valves to permit isolation of the process 7 Automated shutdown sy stems for some process parameters (e.g., high level, high pressure) 7 Manual shutdown systems located in the control room 7 Diked areas designed to contain a release 7 Pressure relief valves and rupture disks that discharge safely to the atmosphere Release mitigation 7 Fire suppression equipment 7 Trained emergency response personnel 7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 7 Spill clean-up equipment FIVE-YEAR ACCIDENT HISTORY Our five-year accident history shows that we have had no accidental releases of covered chemicals at our facility. EMERGENCY RESPONSE PROGRAM The LOS plant maintains a written emergency response plan that is designed to protect employees, the public, and the environment. The procedures include all aspects of emergency response, including proper first-aid and other medical procedures, the use of emergency equipment, the use of personal protective equipment, evacuation plans, and community em ergency response notification procedures. Procedures for maintaining emergency response equipment are also contained in the emergency response plan. There are procedures that address maintaining, inspecting, testing, and using the critical equipment needed in an emergency. Employees receive periodic training in the duties they are expected to perform during an emergency, and any change in the emergency response plan is administered through the management of change process so that affected employees are notified. The emergency response plan is coordinated with local emergency responders (e.g., the fire department). This includes periodic meetings among community responders facility representatives so that they are aware of the hazards of our processes. Communication channels with local responders are kept open 24-hours per day. This coordination and communication ensures that the public is quickly notified, if necessary, and that action is promptly taken to minimize the consequence s of a release. We periodically conduct emergency response drills so that all participants are familiar with their duties during an emergency. PLANNED CHANGES TO IMPROVE SAFETY The LOS plant continuously strives to improve the safety of our processes. Suggestions for improving safety are regularly addressed through process hazard analyses, management of change procedures, incident investigations, and employee suggestions. Callaway Chemical has implemented a comprehensive Year 2000 program that addresses all aspects of computer, microprocessor and software use throughout the company's business and industrial operations. At the plant, the Year 2000 program addresses computers, microprocessors and software controlling operations of the plant. |