Arch Chemicals, Inc. - Executive Summary |
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1254 LDEQ Facility ID Number ARCH CHEMICALS, INC LAKE CHARLES, LOUISIANA RISK MANAGEMENT PLAN EXECUTIVE SUMMARY Arch, Lake Charles, Louisiana, is committed to operating and maintaining all of our processes, especially those using hazardous substances, in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as the protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented. The RMP rule requires that this site provide an executive summary in the RMPlan. This summary provides the following items: Accident Release prevention and emergency response policies Description of stationary sources and regulated substances at facility Offsite Consequence analysis results General accidental release prevention program and chemical specific prevention steps Five year accident history Emergency Response Plan Chemical Specific Prevention steps Planned changes to improve safety ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Arch has a long-standing commitment to worker and public safety. This commitment is demonstrated by resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES Arch is located in Westlake, Louisiana. Our facility produces hydrazine in the form of hydrazine solutions, anhydrous hydrazine, dimethyl hydrazine and methyl hydrazine using a variety of chemicals and processes. Because of the nature of our facility, anhydrous hydrazine, dimethyl hyd razine and methyl hydrazine use the same equipment and therefore are never produced at the same time. The Lake Charles site has the following EPA regulated toxics: chlorine, ammonia, hydrazine, dimethyl hydrazine, and methyl hydrazine. The following EPA flammables are also located on our site: dimethylamine and methyl amine. Dimethylamine and methyl amine are never stored on the site at the same time. The following are the maximum storage capacities that can be found on our site: Chlorine 360,000 pounds Ammonia 140,500 pounds Hydrazine 1,980,200 pounds Dimethyl hydrazine 176,500 pounds Methyl Hydrazine 180,700 pounds Dimethylamine 270,100 pounds Methyl amine 270,500 pounds OFFSITE CONSEQUENCE ANALYSIS RESULTS EPA's RMP rule requires that we provide information about the worst-case release scenario and alternative release scenarios for our facility. The following are brief summaries of these scenarios. Arch's worst case release scenario involves a railcar of chlorine emptying its contents over a ten minute time period. Using EPA's plume dispersion calculation (Lookup Tables) and the most detrimental weather conditions, it is estimated that significant public exposures would be realized a significant distance from the source of the release. This assumes Arch has not taken any steps to mitigate the effects of the release. Arch has significant safety procedures as well as emergency response procedures, chlorine monitors around the work area, other operating and response procedures in place to prevent such a release from occuring and to mitigate the effects of a catastrophic release, should one occur. Arch has examined a series of alternative release scenarios where toxic chemicals could be released into the en vironment. In the case of the alternate release scenarios, we examined the following releases: Chlorine-- a release of chlorine resulting from overfilling the reactor. We estimate 84 pounds would be released with an potential impact range of 0.5 miles. Ammonia-- a release from our ammonia pipeline would result in approximately 1780 pounds released and a potential impact range of 0.14 miles. Hydrazine--we modelled a release that actually occurred when a tank leaked and 490 pounds of hydrazine (as part of a hydrazine solution) was released into the environment. The model estimated an impact zone of approximately 0.04 miles. 1,1 Dimethyl hydrazine-- we estimated 1510 pounds would be released should a transfer hose fail. The impact zone would be 0.71 miles Methyl Hydrazine-- we estimated a pipe leak would release 1700 pounds and have an impact ratio of 0.43 miles. In all of the above cases, the general public would not be affected. Only industrial personnel from nearby faciliti es would potentially be exposed to levels equalling or exceeding the ERPG 2 published concentrations. Arch has also examined the effects of releases involving our regulated flammable chemicals. Our worst case scenario involves a railcar of dimethylamine exploding. The effect of this blast would be felt 0.41 miles from the blast point. In our alternate case release scenario involving flammable substances, we estimated 1800 pounds would be involved in a vapor cloud explosion of dimethylamine or methylamine. The farthest impact zone is estimated to be 0.06 miles. Again, this would not affect the general public. ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at ARCH. Because processes at the site are regulated by the EPA RMP regulation, they are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the acciden t prevention program. EMPLOYEE PARTICIPATION ARCH encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis team. Employees have access to all information created as part of the site accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the site and addresses each accident prevention element. In addition, the site has a number of initiatives under way that address process safety and employee safety issue. These initiatives include forming teams to promote both process and personal safety. These teams typically have members of management and union employees from various areas on the teams. The first is our BASS team which uses behavioral based safety techniques to change the basic structure of work. This process has a mission to create a no-name no-blame environment that enables employees to change at-risk behaviors through education, observation analysis and feedback so all employees can enjoy an accident free workplace. ARCH's GOAL is ZERO team is implementing an intiative aimed at developing an environment where the employee culture develops an intolerance for incidents in the areas of safety, environmental, transportation and process operations. The team is composed of a cross-section of the plant population charged with developing an effective plan, training peers, setting good examples, and placing safety responsibility into the hands of all employees, instead of a department. With the intention that employee participation provides the freedom to determine just what is required to achieve zero incidents. Behavior based studies generated from the BASS observations, as well as intense root cause analysis of incidents that do occur, are also components of the overall Goal is Zero effort. Progress is tracked by management against a vision map established for the site to follow. Though still in its infancy, there are signs that the initiative is having a positive impact on plant performance. PROCESS SAFETY INFORMATION ARCH keeps a variety of technical documents that contain key information which maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assiged responsibility for maintaining up-to-date process safety information. These documents are available to employees upon request. Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in Material Safety Data Sheets (MSDSs). This information is suppl emented by documents that specifically address known corrosion and known hazards associated with the inadvertent mixing of chemicals. For specific process areas, ARCH documented safety related limits for specific process parameters (e.g. temperature, level, composition) in a Standard Operating Instruction (SOI). ARCH ensures the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel and protective instrument systems (e.g. automated shutdown systems). ARCH also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. PROCESS HAZARD ANALYSIS ARCH has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. ARCH uses a combination of the hazard and operability (HAZOP) analysis technique along with a What-If checklist to perform these evaluations. The analyses are conducted by individuals with operating, maintenance and engineering expertise and facilitated by someone with PHA expertise . This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The findings of the PHA team are converted in action items/projects which are then assigned t o the appropriate personnel. PHA items with a higher risk are given priority status for implementation. All action items are tracked until they are complete. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, ARCH conducts periodic reviews of the hazard analysis. These reviews are conducted at least every five years. The results and findings from these updates are documented, tracked and retained. Once again, team findings are converted to action items and other projects for implementing the team's suggestions. OPERATING PROCEDURES ARCH maintains written procedures that address various modes of process operations, such as: (1) unit startup, (2) normal operations, (3) temperary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent trainin g of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The Management of Change process ensures operating procedures are updated as process changes are made. In addition, ARCH maintains key process parameter documents that provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readliy available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. TRAINING To complement the written operating procedures, ARCH has implemented a training program for all employees involved in operating a process. New employees undergo a computer based training session. After successfully completing this training, the new employee undergoes an on-the-job training segment where the employee must demonstrate competancy in certain job related skills. All operators r eceive periodic refresher training. In many cases, that training is refreshed annually. CONTRACTORS ARCH uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, ARCH has procedures in place to ensure that all contractors: (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform ARCH personnel of any hazards they find during their work. This is accomplished by providing contractors with: (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, ARCH evaluates contractor safety programs and performance during the selection of a contrac tor. Site personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. PRE-STARTUP REVIEWS (PSSR) PSSR are conducted for any facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. MECHANICAL INTEGRITY ARCH has established procedures and practices to maintain pressure vessels, piping sy stems, relief and vent systems, controls, pumps and compressors and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on: (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans and (5) applicable work practices to help ensure that they perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and test are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g. a dequate wall thickness for pressure vessels). Another integral part of mechanical integrity is quality assurance. ARCH incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. SAFE WORK PRACTICES ARCH has long-standing, safe work practices in place to help ensure worker and process safety. Examples of these include: (1) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (2) a procedure for the safe removal of hazardous materials before process piping or equipment is opened, (3) a permit and procedure to control spark producing activities (i.e. hot work) and (4) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others) along with training of affected personnel, form a system to help ensu re that operations and maintenance activities are performed. MANAGEMENT OF CHANGE ARCH has a comprehensive system to manage change to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process-operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to: (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. INCIDENT INVESTIGATION ARCH promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damag e, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence and publishes these results for the whole facility to see. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. COMPLIANCE AUDITS To help ensure that the accident prevention program is functioning properly, ARCH periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audit are conducted at least every three years. Corrective actions taken in response to the audit team's findings are tracked until they are complete. FIVE YEAR ACCIDENT HISTORY We keep records for significant accidental chemical releases that occur at our facility. Arch has had one accident involving the RMP chemical hydrazine. On October 8, 1998, hydrazine was involved in a fire at our facility. The result was property damage but no impact to the community or environmental receptors was involved. EMERGENCY RESPONSE ARCH maintains a written emergency response plan, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public, if a release occurs and post incident cleanup and decontamination procedures. Employees receive training in these procedures as necessary to perform their specific emergency response duties. Updates to this program are made based on modifications to the manufacturing process or as other significant information is developed. Our plan is submitted to the Local Emergency Planning Committee and we participate with the LEPC and other industry in coordinating emergency drills and other community emergency planning activities. PLANNED CHANGES TO IMPROVE SAFETY ARCH, Lake Charles, has committed to becoming an OSHA VPP site. A task force has been commissioned to develop and implement a plan to obtain this certification. As this program develops, changes to the site which will ultimately reduce the potential for accidents will be put in place. |