La Porte Plant - Executive Summary
DUPONT - LAPORTE PLANT |
RISK MANAGEMENT PLAN
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
DuPont has a long-held, corporate level belief that all safety incidents and accidental releases can and must be prevented. This belief covers on and off-job injuries, occupational illnesses and accidental releases. DuPont is also committed to keeping its facilities ready to respond to any incident that occurs in spite of our best prevention efforts.
DuPont established PSM on a Corporate basis in 1979. General definitions, policies and organizational structure that implement PSM are given in Section S21A of the DuPont Safety and Occupational Health Guidelines. PSM goals, policies and procedures are embodied in numerous corporate manuals and documents such as Engineering Standards, Safety
Manuals and Guidelines.
DuPont's LaPorte Plant endorses, adheres to and carries out Corporate PSM policies, procedures and guidelines. The DuPont LaPorte Plant's Accidental Release Prevention policies come within the scope of the site's existing Process Safety Management (PSM) program. We apply PSM to all processes and chemicals at this site, not just those covered by the RMP Regulation.
The stated purpose of the LaPorte Plant's PSM Program is to manage and control the hazards in our processes, to protect individuals, plant equipment, our business integrity, and our community through the elimination of hazards. PSM involves the application of controls to our processes through operating & maintenance procedures and practices, training, management of change, equipment inspection, and auditing.
The Principles that govern the DuPont LaPorte Plant's PSM actions are:
--All injuries, incidents and occupational illnesses are preventable. We will work in a proactive,
ode rather than in a reactive mode.
--We will educate and develop people to achieve understanding, buy-in, and excellence in the field of
Process Safety Management such that serious process incidents are eliminated.
--We will obtain and apply consistent management support and resources from the entire business team
to eliminate potential serious process incidents.
--The total organization will maintain the will and energy to keep Process Safety Management in the
forefront at all times.
Over the years, the DuPont LaPorte Plant has established a number of records in the fields of safety, employee health and environmental protection that demonstrate our commitment to our PSM goals and policies. This commitment is further evidenced by the site's RMP 5-Year Accident History - there are none of these incidents on our record.
FACILITY DESCRIPTION AND REGULATED SUBSTANCES HANDLED
DuPont is a 200 year old American company that has been operating within the territorial
jurisdiction of the City of LaPorte, Texas, for over 50 years. We are one of the oldest and largest businesses in the LaPorte community. Over the years we have developed and maintained an outstanding relationship with our community.
The DuPont facility is situated on about 600 acres of property north and west of the intersection of State Highways 225 and 146, fronting on Upper San Jacinto Bay. We provide stable employment for about 850 company employees and 300 contractors.
DuPont is engaged in four (4) major businesses at the LaPorte Plant:
--Crop Protection Products - used for improving crop yields and quality at value adding prices
--Organic intermediates for Lycra(R) spandex fibers - used in hosiery and swim and athletic wear.
--Inorganic acids - used to produce Teflon(R) non-stick coatings and environmentally friendly refrigerants
--Plastics for auto safety glass and consumer packaging materials
Overall responsibility for the operation of DuPont's
LaPorte Plant is vested in a Plant Manager. All elements of the site's Risk Management Program, including safety, regulatory compliance, prevention of accidental spills and releases, and emergency response fall within the scope of the Plant Manager's responsibilities. Safety is also considered to be each employee's individual responsibility.
Below the Plant Manager level, the site's organizational structure is fluid. At the time this RMPlan was prepared, there were four (4) Business Unit Leaders (one for each of the major businesses previously listed) who report administratively to the Plant Manager. Each Business Unit Leader is responsible for
Process Safety Management (PSM), spill/release prevention, regulatory compliance and many aspects of Emergency Response within his/her individual Business unit.
Reporting to the "Crop Protection Products" Business Unit leader is a Site Leader-Environmental Affairs who has overall site responsibility for environmental regulatory compliance
including the development, implementation, and integration of the site's risk management program elements.
A Safety Supervisor who has overall site responsibility for Emergency Response and OSHA compliance reports directly to the Plant Manager.
Also reporting to the Plant Manager is a Shift Operations Leader (SOL) who has overall responsibility for plant operations. A SOL is on duty 24 hours per day, 7 days per week. The SOL carries a pager or radio at all times and can be contacted very quickly to deal with any type of release that might occur, and to coordinate emergency response efforts either on-site or off-site.
All operations at this facility including the Covered Processes listed below and the Environmental Control operations are attended 24 hours per day, 7 days per week by well trained, highly skilled personnel.
All accidental spills and releases occurring at this facility are documented, investigated and the residue, if any, is promptly cleaned up.
A high le
vel of security is maintained at the facility at all times:
--The facility is not open to the public.
--The facility is completely surrounded by a chain link security fence topped with barbed wire.
--Security personnel are on duty 24 hours per day, 7 days per week to observe and control all site
ingress and egress and to perform frequent on-site and perimeter patrols.
--A strict accounting is kept of everyone present at the facility - including employees, visitors, vendors,
contractors and delivery personnel
--Vehicular access is tightly controlled. Security personnel inspect all inbound and outbound vehicles.
Covered Processes and Regulated Substances
The RMP regulated substances and covered processes at this facility are:
Covered Process Regulated Substance
Formaldehyde -formaldehyde solution
Fluoroproducts -hydrofluoric acid
-vinyl acetate monomer
Each of the five Covered Processes listed above is a Program 3 Process. Any rail car or tank trailer being used for temporary storage of an RMP Regulated Substance is included within the scope of one of the Covered Processes listed.
The release scenarios presented in later sections of this RMPlan were developed in conjunction with, and according to protocols developed by, the East Harris County Manufacturers Association (EHCMA), the largest industrial manufacturing association in the United States.
"Look-up" Tables contained in EPA's Off site Consequence Analysis (OCA) Guidance were used to determine endpoint distances for both Worst Case and Alternative Release Scenarios. This EP
shows that all scenarios extend off-site and would reach our fence-line industrial neighbor, Noltex. Unless specifically noted, none of the scenarios impacts hospitals or prisons/correction facilities. Other off-site impacts are noted in the individual scenario summaries. "Landview III" Environmental Mapping Software was used to generate residential population estimates where needed.
Also in conjunction with EHCMA, the DuPont LaPorte facility has gone well beyond the regulatory requirement to make our RMP information available to the public. Our RMP information was actively communicated to the public in a series of "Roll-out" events conducted in February and March 1999. Community dialogue about Risk Management is an on-going process.
FIVE YEAR ACCIDENT HISTORY
In the five years immediately preceding the submittal date of this RMPlan, there were no accidental spills or releases of RMP regulated substances from covered processes at the DuPont LaPorte Plant that resulte
d in deaths, injuries or significant property damage on site, or known off site deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.
WORST CASE TOXIC RELEASE SCENARIO
This facility's worst case release scenario for an RMP regulated "Toxic" substance is the failure of an anhydrous hydrofluoric acid storage vessel. This scenario assumes instant vaporization of the released material and no active mitigation. EPA's OCA Guidance shows the impact of this release would extend off-site and impact all categories of receptors except Federal wilderness areas. Such an incident is extremely unlikely due to:
--instantaneous vaporization is not physically possible
--active mitigation systems are designed to be fail safe
--high integrity design of the storage vessel
--frequent inspections for vessel integrity
--routine preventive maintenance
--highly trained and skilled operators and supervisors attend the storage vessel 24 hours per day, 7
days per week
--TV monitors continuously scan the vessels and surrounding area
--state-of-the-art instrumentation includes chemical specific leak detectors
--dedicated storage space is reserved so material can be moved out of a leaking storage vessel
--an effective PSM Program
WORST CASE FLAMMABLE RELEASE SCENARIOS
Because this facility is rather large and widespread, and because endpoint distances for worst case flammable release scenarios are relatively short (~1/2 mile), three (3) worst case flammable scenarios have the potential to affect different off-site areas:
1) failure of a dimethylamine storage vessel followed by a vapor cloud explosion of the released material.
2) failure of a dimethylamine tank car followed by a vapor cloud explosion of the released material
3) failure of a high pressure gas loop (pipeline) that releases ethylene gas, followed by a vapor cloud
explosion of the released material.
Each of these scenarios assumes instant vaporization
of the released material and no active mitigation. EPA's OCA Guidance shows the impacts of these releases would extend off-site; however, USGS maps and knowledge of the area show these impacts would not reach any residences, schools or parks. Such incidents are extremely unlikely due to:
--active mitigation systems are designed to be "fail safe"
--high integrity design of storage vessels, rail cars and process piping
--frequent inspections for vessel and equipment integrity
--frequent preventive maintenance
--highly trained and skilled operators and supervisors attend this equipment 7 days per week, 24 hours
--effective PSM Program
ALTERNATIVE TOXIC RELEASE SCENARIOS
Chlorine - Severed one-inch unloading hose at the rail car spot. Assume automatic emergency isolation valves stop the leak within 10 minutes. EPA's OCA Guidance shows the impact of this release would extend off-site. USGS maps and knowledge of the area
show there are no residences, schools or parks in the impact area.
Methyl mercaptan - Severed two-inch unloading hose at the rail car spot. Assume automatic emergency isolation valves stop the leak within 10 minutes. EPA's OCA Guidance shows the impact of this release would extend off-site. USGS maps and the "Landview III" program census data show there are residences, but no schools or parks in the impact area.
Sulfur dioxide - Severed two-inch unloading hose at the rail car spot. Assume automatic emergency isolation valves stop the leak within 10 minutes. EPA's OCA Guidance shows the impact of this release would extend off-site. USGS maps and knowledge of the area show there are no residences, schools or parks in the impact area.
Formaldehyde - Liquid spills from a product storage tank into its diked secondary containment area, covering the entire diked area. Assume evaporation is stopped in 30 minutes by covering with foam. EPA's OCA Guidance shows the impact of this relea
se would extend off-site. USGS maps and knowledge of the area show there are no residences, schools or parks in the impact area.
Hydrofluoric acid - Severed two-inch loading hose at the rail car spot. Assume emergency shut-off switch activates isolation valves and shuts down the loading pump, stopping the release in 2 minutes. EPA's OCA Guidance shows the impact of this release would extend off-site. USGS maps and the "Landview III" program census data show there are residences, two schools and one public park in the impact area.
Oleum - Severed three-inch loading hose at the rail car spot. Assume emergency shut-off switch shuts down the loading pump, stopping the release in 10 minutes. EPA's OCA Guidance shows the impact of this release would extend off-site. USGS maps and knowledge of the area show there are no residences, schools or parks in the impact area.
Vinyl acetate monomer - Failure of a two-inch pipe releasing material to a curbed concrete pad forming a non-boiling
pool. Assume emergency shut-down systems operate correctly and the release is stopped in 60 minutes. EPA's OCA Guidance shows the impact of this release would extend off-site. USGS maps and knowledge of the area show there are no residences, schools or parks in the impact area.
ALTERNATIVE FLAMMABLE RELEASE SCENARIO
Ethylene - Failure of a 3-inch pipeline on the discharge of the Recycle Gas Compressor (RGC). Assume emergency shut-down systems operate correctly and the release is stopped in 10 minutes. EPA's OCA Guidance shows the impact of this release would extend off-site. USGS maps and knowledge of the area show there are no residences, schools or parks in the impact area.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL- SPECIFIC PREVENTION STEPS
DuPont's LaPorte Plant is regulated by and complies with OSHA's Process Safety Management (PSM) Regulation - 29 CFR 1910.119. Our PSM compliance program is directed toward preventing all serious process related chemical
incidents that might affect plant personnel (employees, contractors, visitors) off-site communities, or the environment, or result in significant loss of property or business. It involves the application of systems and controls to chemical manufacturing processes in a way that hazards are identified, understood and controlled so that process-related injuries and incidents are prevented. The site's Accidental Release Prevention Program falls within the scope of our existing PSM program.
The fourteen (14) key elements of this facility's PSM program are:
1. Process technology (PT)
2. Process hazards analysis (PHA)
3. Operating procedures and safe work practices
4. Management of change - technology
5. Personnel training and performance
6. Contractor safety performance
7. Management of change - personnel
8. Incident investigation and communication
9. Emergency planning and response
11. Quality assurance (QA)
12. Mechanical integ
13. Pre-start-up reviews
14. Management of "subtle" change
DuPont's PSM Program is applied to two categories of process activities:
--Higher Hazard Processes (HHP's) - any activity that manufacturers, handles, stores or uses hazardous
substances that, when released or ignited, can result in death or irreversible human health effects,
significant property or environmental damage, or off-site impacts due to acute toxicity, flammability,
explosivity, corrosivity, thermal instability, latent heat, or compression.
--Lower Hazard Operations (LHO's) - any activity that exclusively manufactures, handles, stores, or
uses any substance with low potential for death or irreversible human health effects, significant
property or environmental damage, or off-site impacts due to toxicity, asphyxiation, or mechanical
hazards including stored energy.
Specific Risk Reduction Achievements
During the time this RMPlan was in preparation, three (3) RMP Regu
lated Substances were eliminated from the site:
--Sulfur trioxide (SO3) - a 600 thousand pound storage tank was taken out of service and dismantled.
There is now less than a threshold quantity of this material in the Fluoroproducts Process.
--Aqueous Ammonia >20% - this material was eliminated from three (3) different processes by either
switching to a lower concentration material or lowering the inventory to less than threshold.
--Bromine - a process using this material was discontinued
In late 1984, storage of methyl isocyanate (now a RMP Regulated Substance) at this facility was eliminated as a result of the Bhopal, India, incident. The largest inventory of this material ever present is now two (2) pounds or less.
EMERGENCY RESPONSE PROGRAM
All employees at DuPont's LaPorte Plant are trained to recognize potential hazards associated with handling hazardous substances. Employees are trained in several independent ways of reporting actual and/or potential emergenc
y situations and securing assistance. All methods of emergency reporting result in the sounding of a site-wide alarm.
The site-wide alarm automatically alerts the entire facility to the emergency, activates one of two previously designated Emergency Operations Centers (EOC) and summons the Emergency Response Team (ERT) to the incident location. An Emergency Response Team (ERT) is on duty at the facility 24 hours per day, 7 days per week.
The sounding of the site-wide alarm also initiates a number of other processes including:
--immediate mobilization of site emergency response resources
--preliminary assessment of the situation
--dispersion modeling to gauge the potential for off-site impact
--establishment of a Command Post near the incident location
At the Command Post, an Incident Commander (IC) takes charge of the situation and organizes and directs the ERT. The widely recognized National Fire Academy Incident Command System (ICS) is used to m
anage safety, tactics, strategy, personnel, equipment, logistics and other resources.
The site's Emergency Response Team (ERT) is trained to a high level of proficiency in incident command, interior structural fire fighting, fume and vapor suppression, emergency medical treatment (EMT) including cardiac care and invasive procedures, high angle and confined space rescue and hazardous material response. The purpose of the ERT is to assist the facility in safeguarding employees and the community from the threat of fire, injuries, fume releases, medical illnesses, entrapment and other types of emergencies. Minimum staffing levels for these skills and functions have been established and are available on-site at all times.
A roster of off-shift emergency responders is maintained for call-out in the event additional personnel are required. Full utilization of this resource can bring as many as 80 more trained emergency responders to bear on an incident.
This facility maintains an on-sit
e medical facility staffed by a physician and Registered Nurses. A fully equipped advanced life support ambulance is maintained on-site and there is a helicopter landing pad on-site.
Site security forces are available around the clock to coordinate with local law enforcement agencies, monitor communications, establish road blocks and/or take other appropriate responses as necessary to control personnel and traffic.
If necessary, a number of off-site resources can be brought to bear on a major incident:
--Channel Industries Mutual Aid (CIMA) can provide essentially unlimited resources of specialized
equipment and apparatus, trained personnel and consumable supplies such as foam.
--Life Flight helicopter service is available for urgent or life threatening medical emergencies
--LaPorte Emergency Medical Service can provide mobile intensive care during ground transport of
casualties to any of several nearby hospitals
--Additional traffic control and off-site shelter-in
-place or evacuation can be provided by City of LaPorte
Police and/or the Harris County Sheriff's Department.
All of these potential providers of emergency response services have been included in the facility's contingency planning process.
Once life safety issues have been addressed (including exposure control and confinement), and the incident has been successfully mitigated, clean-up operations commence. If it is found necessary to remove hazardous substances, health hazards, and/or materials contaminated with them (i.e., soil) from the site of the incident, the clean-up will comply with one of the following:
--Work will be performed by area personnel thoroughly trained on area hazards, protective equipment,
and work practices,
--Work will be performed by a contractor certified as a clean-up operator under 29 CFR 1910.120,
paragraphs B through O. A site contract exists with a local Discharge Clean-up Organization [DCO],
certified by the Texas Ge
neral Land Office, for this purpose.
A Transportation Emergency Reporting Procedure (TERP) Team based at the LaPorte Plant is also available to respond to off-site transportation emergencies involving chemicals in transit to or from this facility. The primary function of this technically trained team is to make an immediate incident assessment, mitigate when possible, and summon a fully equipped DuPont Regional Hazardous Material (HAZMAT) Response Team if needed.
PLANNED CHANGES TO IMPROVE SAFETY
On the submittal date of this RMPlan, capital projects are underway to:
--replace a significant segment of the facility's underground fire main piping system
--replace one (of three) 2500 gpm diesel firewater pumps
--upgrade the siren portion of the site's emergency alarm system (the electronic control portion has been
upgraded within the past 2 years)
Serious consideration is also being given to capital projects for:
--installation of a high elevation panoramic TV camera for
use by the EOC to monitor an emergency
situation anywhere on site
--purchase of a new fast attack monitor truck with greater capabilities than the existing truck
Several upgrades in safety procedures and systems are underway:
--the site's "Line break" procedure is being improved
--the site's Incident Investigation procedure is being enhanced to focus on better identifying and
correcting the root causes of incidents
--a new system is being implemented to assure that all safety procedures are reviewed at least every 3
--a new system is being implemented to assure better follow-up of audit findings and recommendations
As a result of a recently completed corporate security audit, several enhancements will be made in site security equipment, organization and procedures. Recommendations being considered include:
--adding more TV cameras to enhance perimeter monitoring
--changing the role of the current security force "working leader" to that of a true
--enhancing procedures, training and personnel testing in the areas of:
-investigating suspicious people and packages
-dealing with disorderly and/or intoxicated people
-dealing with domestic situations
-use of force
-hostage and weapons situations
-incidents of violence