The Procter & Gamble Manufacturing Company - Executive Summary |
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Executive Summary Kansas City Soap Plant What We Do The Procter & Gamble Kansas City Soap Plant manufactures liquid dish detergents and raw materials for use in our own products and for sale to other companies. These include "Dawn," "Ivory," and "Joy," which might be found in a home kitchen. This plant has been in operation since 1905, and it is the first Procter & Gamble plant opened outside of Cincinnati, our corporate headquarters. In Kansas City and elsewhere, Procter and Gamble has a long-standing commitment to a safe work environment for employees and minimizing the impact of our operations on the environment. Experienced, qualified employees manage safety and environmental programs with the active support of the plant's management. The goal of all of these professionals is to prevent incidents from occurring. The plant has several employee safety teams that train regularly to monitor areas where chemicals are stored and to quickly react to incidents in order to prevent injury to workers. Procter & Gamble is always looking for opportunities to improve the safety of our operations. For example, several changes to the Epichlorohydrin system are currently being studied for possible implementation. The Kansas City plant has an excellent history of safe operations. There has never been an injury or property damage to anyone off the site in the history of this plant. In March of 1999 we had a small release of Dimethylamine which did not travel off site, but did cause injury to an individual who was working on site near the release. This release, as with any incidents or near misses on site, was followed by a thorough incident investigation and follow up action steps to prevent recurrence. Chemicals Used in Kansas City Subject to EPA Report P&G's Kansas City Soap Plant uses four chemicals that are subject to reporting under this filing to the U.S. Environmental Protection Agency (EPA). All are necessary materials used to manufacture soaps and det ergents. Sulfur trioxide is delivered to our plant by rail cars and is unloaded into an indoor tank. This tank is externally inspected once each year and the metal walls are routinely tested for integrity. A dike to contain any potential spill protects the area where the material is transferred from rail cars to the tank. A foam system can blanket the area with a water-based foam. This foam system may be activated by an employee in a remote location. The diked area drains to the inside of the building that houses the storage tank. Video cameras monitor the loading and storage areas. The storage tank is maintained at the proper temperature to keep the sulfur trioxide in a liquid state. Any vapors present in the tank are collected in a mist vacuum and put through a scrubber. When used in the detergent-making process, sulfur trioxide is completely consumed. Dimethylamine is delivered by dedicated rail cars and is unloaded into three tanks. These tanks are above ground and surr ounded by a dike to contain any spills around the tanks or the unloading area. These tanks are regularly inspected, inside and out. The walls of the metal tanks are routinely tested for integrity. The tank and unloading area also are protected by a water deluge system that discharges water automatically if it senses heat. The water system can also be activated manually at the site or from a remote location in the event of an incident. Fire fighting nozzles also are located around the tanks and can deliver high volumes of water into the storage area. Employees monitor the area via video cameras. The dimethylamine used to manufacture detergents is completely consumed in chemical reactions during the process. Bromine comes to the Kansas City plant in dedicated trucks and is unloaded into a tank. The tank is located in a covered spill-containment area. The unloading area also is protected against spills. This tank is externally inspected every year and internally inspected every two years. The tank is protected by a foam system, and is monitored by video cameras. When the tank is emptied for maintenance, any vapors remaining are collected in a mist vacuum and scrubber system. Bromine is mostly consumed during the making of detergents. The small amount that is not, is recovered and sent back to the supplier for reprocessing. Epichlorohydrin is delivered to our plant in dedicated rail cars and is unloaded into two tanks. Dikes surround the unloading and tank storage areas, and both locations are grounded. Neither tank is allowed to be more than half full, which allows the transfer of the contents from one to the other during maintenance. Each tank is inspected internally every year and the integrity of the metal walls is routinely examined. Both the storage and unloading areas are protected by a foam or water deluge system that employees can activate remotely. The deluge system discharges whenever it senses heat. Fire fighting nozzles are located ar ound the tanks, as are remote video cameras. Epichlorohydrin is completely consumed in the manufacturing of detergent. EPA Report Assumptions For this report to EPA, Procter & Gamble was required to analyze both a "worst case" and an "alternative" scenario. The federal agency defined "worst case" to be an instantaneous release, during a time of light winds and stable weather conditions. This instantaneous release could be caused by an earthquake or tornado, or by a plane hitting the tank. The worst case assumes that none of the existing safety systems work and that there was no emergency response. Neither of these is likely; the Kansas City, Kansas, Fire Department and Hazardous Materials (HazMat) team are trained to respond to incidents of this type. An "alternative" release was defined as a 10-minute release from a single part of the system, such as an unloading line. This release is assumed to take place during normal weather conditions. Foam suppression or shut-off valves were assumed to be activated within 10 minutes. Release Scenarios: Assessment of Impact Because there has never been a release with off site impact of any of the four chemicals subject to this analysis, the effects of a major release are unknown. However, a computer model has been used to calculate potential impact of the unlikely "worst case" and "alternative" releases. For sulfur trioxide, the computer model estimated the distance a vapor cloud would travel given the assumed worst case conditions. In this case, the vapor cloud would travel off site and affect the community population. The population impact estimated is based on the total number of people living within the radius of the vapor cloud distance. In the unlikely event of any release, the wind would be expected to blow the cloud in only one direction, so the entire area would not be impacted. Therefore, the population impact presented in the RMPlan would overestimate the actual number of people impacted by a worst ca se release. In the alternative scenario for sulfur trioxide, the vapor would have off site impact, though the range of impact is significantly smaller. The alternative release for sulfur trioxide is a leak from a flange in the unloading line. For dimethylamine, the worst case scenario distance does affect a small number of community residents. The worst case event is a vapor cloud fire. The alternative release would disperse the material in a short distance that would not impact any off-site residents. The alternative release for dimethylamine is a leak in an unloading line. For bromine and epichlorohydrin, the alternative releases would allow vapor to spread only short distances. There are no off-site residents in these areas. The alternative release for bromine is a leak in a process line. For epichlorohydrin the alternative release is an unloading line failure. How We Prevent Releases The worst case scenarios listed above are unlikely to happen because they assume there w ill be no effective safety systems or emergency response. Procter & Gamble has conducted a detailed hazard study of each of these chemicals. Company engineers and operators identified potential points from which a chemical may be spilled or leaked during the process. We have used that analysis to design better systems, train operators and maintenance employees and to develop accident prevention and response systems. As described above, each chemical is contained within a tank system appropriate for that service. Well-trained operators monitor the conditions 24 hours per day via video cameras, temperature and pressure gauges, and other instruments. Volumes in the tanks also are monitored. Tanks are not refilled unless the arriving truck or rail car can be emptied completely. This helps prevent overflows and spills. As called for in the Occupational Safety and Health Administration (OSHA) Process Safety Management system, plant operating systems are repeatedly assessed and improved. Process technicians, engineers and the site safety teams work together to bring about these improvements. Some products of this improvement process are the mist vacuum system and triple redundant controls. In the event of an incident, the Kansas City plant has systems to respond quickly. Processes can be shut down on an emergency basis. Spills or leaks can be noted immediately and reported to control room operators. The plant has a direct line to the Kansas City, Kansas Fire Department for quick reporting of releases. The fire and police departments have developed procedures to communicate instructions to the public in the event some action is needed. These communications can be carried out either by radio or TV broadcast or through direct communications in the streets. We have held joint response drills with the Kansas City, Kansas fire department and Haz Mat Team annually for over 15 years. These allow training of new people and polishing the skills of experienc ed responders. The emergency response teams tour our facility regularly so they are familiar with the location of critical equipment. These regular activities help bring about excellent communications between Procter & Gamble and local emergency responders. All Procter & Gamble employee who work in the vicinity of these four chemicals have been thoroughly trained in the company's standard operating procedures for both routine and non-routine operations. These workers participate in the annual drills with local emergency preparedness officials. Company and Employee Commitment The Kansas City Soap Plant's outstanding safety and environmental record is a product of the commitment of the company and all employees. Employees participate in safety and environmental teams that have been responsible for an improved workplace. Some of them are active away from work, too. P&G employees are active members of the MidAmerica Regional Council (MARC) Air Quality Forum and are leaders of the Wyandotte County Coalition for Chemical Safety. The plant works actively with the Kansas City, Kansas/Wyandotte County Emergency Management and the Kansas City, Kansas, Fire Department and HazMat Team. P&G has donated fire-fighting equipment to these organizations and has sponsored their attendance at training seminars. The Kansas City Soap Plant has received recognition for its safety and environmental accomplishments including: Recognition of 1 million safe work hours (almost 2 years) - September 1998, Kansas Water Environmental Association Pretreatment Compliance Award - 1997, 1998 and 1999 and Kansas Department of Health and Environment Recognition for Notable Achievement in Pollution Prevention - 1997. Conclusion P&G takes very seriously its responsibility to manage its Kansas City Soap Plant in a way that protects its employees and surrounding neighbors. We have completed this report to provide the public with information about our activities at this plant. The computer mo del represents the best estimate of results of accidents as defined by the U.S. EPA. We believe that given our safety record, the many controls instituted to maintain a safe operation, and our commitment to continuous improvement that neither the worst-case or alternative event is likely to happen. |