Rhodia Inc. - Dominguez Plant - Executive Summary |
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a. Rhodia, Inc. is committed to the safety and well-being of its employees and the public. Rhodia's policy is to implement reasonable measures to prevent a release of hazardous material from occurring, to provide early detection of a release in the unlikely event that one would occur, and to have in place a contingency plan to respond promptly yet safely to such a release. b. This Risk Management Plan (RMP) has been prepared to address the handling of the following federal regulated substances at the Rhodia facility located at 20720 S. Wilmington Ave., Carson, CA 90746:- - Sulfur dioxide - Oleum 25% c. Sulfur dioxide is present in solution in spent acid received by the facility. It is also present as a gas within the Plant 4 sulfuric acid regeneration plant and dissolved in weak acid in the Plant 4 sulfuric acid regeneration plant. d. Oleum, otherwise known as fuming sulfuric acid, is a mixture of sulfuric acid and sulfur trioxide. The strength is usually expressed as a percent age of free sulfur trioxide in the acid. Oleum is present at a strength of 25% in the Plant 4 sulfuric acid regeneration plant. Normally no oleum is produced for storage or shipment. However, storage and shipment by tank truck may take place as a back up operation for a sister Rhodia facility. e. The worst case toxic release was determined to be the release of the contents of the heavy spent acid tank and subsequent evolution of sulfur dioxide from the acid spill. The alternate release of sulfur dioxide was the release of acid gas containing sulfur dioxide from the sulfuric acid regeneration plant as a result of a torn duct expansion joint. The alternate release of oleum was a spill of oleum as a result of overfilling a tank truck during unloading. All scenarios have toxic endpoints which extend offsite. Credit was taken for passive mitigation (e.g. containment dikes and sumps) in modeling liquid spills. No credit for other measures to prevent and/or mitigate the aforementioned releas es was taken in modeling the releases. f. Rhodia has a comprehensive release prevention program meeting RMP Prevention Program and OSHA Process Safety Management (PSM) requirements. Physical safeguards to prevent a release of a regulated substance include best industry practices for the design and construction of equipment, piping and instrumentation, monitoring, alarm and shutdown systems. Procedural and other safeguards are also used. g. There have been no accidents at this facility which meet the criteria for inclusion in the Five-year Accident History Component of the Risk Management Plan. h. Rhodia has a comprehensive emergency response program in place to provide prompt but safe response to halt and/or mitigate a release. Rhodia's Emergency Response Team is well trained and well equipped to handle a wide range of emergencies. Rhodia has worked closely with Los Angeles County Fire Department (LACFD) in developing its response plan. The LACFD participates annually in Incident C ommander training for the Rhodia Emergency Response Team. i. Rhodia has undertaken numerous changes to improve safety at the Dominguez Plant. The most recent is the discontinuation of liquid sulfur dioxide transloading operations. These operations involved the presence of 90 ton rail cars of sulfur dioxide at the facility. Changes to improve safety which are planned but not yet implemented are:- - Instrumentation upgrades for the oleum handling facilities. - Fire protection improvements in the heavy spent acid storage area. - Reevaluation of the Plant 4 emergency shutdown system and impact on fugitive sulfur dioxide emissions. |