Witco Corporation Gretna Plant - Executive Summary
WITCO CORPORATION, GRETNA PLANT |
RISK MANAGEMENT PLAN
2119 LDEQ Facility ID Number
1. Introduction and Background
The Accidental Release Prevention (ARP) requirements mandated in Section 112r of the 1990 Clean Air Act Amendments were promulgated by the Environmental Protection Agency (EPA) on June 20, 1996. These requirements are codified in 40 CFR 68, Subparts A through H. Under the ARP program, processes with chemical quantities on site exceeding the listing threshold quantities have applicable requirements.
Witco Corporation produces petroleum sulfonates, and refrigeration oils at the Gretna Plant. As defined by the regulations, the Gretna Plant stores the following toxic chemical in excess of the threshold quantitiy: oleum. The plant does not store any flammable chemicals as defined by the regulation.
The Witco Gretna Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in safety and en
vironmental protection, employee safety training, and safety in the design, installation, operation and maintenance of plant equipment. Witco's written safety and environmental policy states that "Safety Is Unequivocally Our Number One Priority." Gretna has implemented reasonable controls to prevent and mitigate probable releases of hazardous chemicals. Should a release occur, trained personnel would respond to control and contain the release.
2. Description of the Stationary Source and Regulated Substance
Witco's Gretna Plant is a petroleum additives and refrigeration oil manufacturing facility located at 1805 Fourth Street in Harvey, LA. The plant is situated on approximately 65 acres on the west bank of the Mississippi River, in Jefferson Parish. This location is just down river from the Harvey Canel. The plant is bounded on the north by the Mississippi River, on the west by an industrial park, on the east by a bulk storage facility, and on the south by properties which inclu
de commercial and residential properties, and govenment offices.
The Witco Corporation has operated the Gretna facilty since 1960. The products are utilized in industries including refrigeration and cooling, and marine lubrication. The facility is operated twenty-four hours a day, seven days a week, fifty-two weeks a year. Approximately 131 employees are employed full time at the site. Plant manufacturing areas are broken down into Refrigeration Oil, and Petroleum Additives.
3. Worst Case Release Scenario and Alternate Release Scenario
The Risk Management Program (RMP) rule requires the development of accidental release scenarios for the toxic chemical, oleum, which is used at our site.
A worst-case scenario and alternate release scenario are designed to calculate the potential impact to the surrounding community. EPA defines a worst-case scenario as the complete release of the largest inventory of a chemical over ten minutes under weather conditions that would allow the chemi
cal to travel the farthest distance at ground level. It also assumes that none of the facility mechanical controls or safety systems are operational. A worst-case scenario is highly unlikely to occur.
Given the severe guidelines of a worst-case scenario, a more realistic alternate release or planning scenario was also developed to more closely resemble a real world event. This scenario involves a smaller release and allows safety systems to be included in the release containment and dispersal calculations. Alternate release scenarios are useful to local government and industry when preparing emergency response plans.
Worst-Case Toxic Release Scenario
The worst case toxic release for the Gretna Plant would be a catastrophic failure of the oleum storage tank. Assuming all safety systems fail in the worst possible weather conditions, using EPA mandated criteria, the off-site impact has been determined utilizing the Safer Trace program, and the results are as shown below.
Chemical - O
Hypothetical Release Scenario - Tank Failure
Mitigating Measures - None
Largest Quantity on Site (lbs.) - 858,421
Distance to Toxic Endpoint - 1.26 miles
However, this scenario is highly unlikely to occur, as the tank is equipped with pressure safety relief devices. The vessel is also contained within a concrete secondary containment area. The tank level is monitored by the unit operators.
Alternate Toxic Release Scenario
Alternate release scenarios are those which are more likely to occur than worst-case release scenarios. The alternate release scenario for the Gretna Plant has been calculated utilizing EPA's default modeling parameters.
Chemical - Oleum
Release Scenario - 2-inch loading hose or piping connection broken off during liquid transfer
Mitigating Measures - None
Distance to Endpoint - 0.20 miles
However, this scenario is unlikely to occur. Oleum transfers are monitored by operation personnel and the oleum truck drivers.
Furthermore, this scenario is unlikely to
impact up to 0.20 miles as the plant will utilized trained emergency personnel, and water spray to minimize the release of the sulfur trioxide, while contacting off-site responders if the release would impact off-site populations.
4. General Accidental Release Prevention Program
At Witco, safety is our number one priority. The Gretna Plant is therefore committed to ensuring the continued safety of its employees and the community by implementation of the best safety management practices. These practices concentrate on accident prevention and preparedness to prevent incidents and to minimize the effects of any accident that may occur. These practices apply to all chemicals stored, handled, and produced at the plant.
General accidental release prevention is a part of the Gretna Plant's program for all chemicals stored and handled at the facility. Emphasis is on release prevention through equipment inspection and frequent observation of equipment for early detection and control o
f any leaks found. The facility prevention program is detailed in the various site emergency plans which include Unit Operating Procedure #08.01(Site Emergency Response Plan), the site Spill Prevention Control and Countermeasure Plan (SPCC), and the EPA and Coast Guard OPA 90 plans.
5. Five Year Accident History
The site has not had a significant accident or release involving Oleum within the last five years.
6. The Gretna Emergency Response Program.
A plant-wide emergency response program is in place at the Gretna facility. This plan integrates OSHA requirements with emergency response, spill containment and control, and measures to prevent storm water contamination at the Plant. The plan includes specific measures for Oleum in addition to plans for all chemicals stored and handled at the facility.
7. Planned changes to improve safety.
The facility is committed to continually improving safety for all materials handled at the plant with emphasis on Oleum. The plant
programs will utilize employee participation, process hazard reviews, and information obtained from incident investigations to help improve plant safety.
The plant has taken steps to minimize the hazards from oleum by minimizing the volume kept in storage, and by working to eliminate it's use entirely from plant processes.