Witco Corporation, Janesville Plant - Executive Summary |
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Witco Janesville RMP Executive Summary 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 listed threshold quantities have applicable requirements. Witco Corporation produces surfactants at the Janesville plant. As defined by the regulations, the Janesville plant stores the following toxic chemicals in excess of the threshold quantities: ethylene oxide, propylene oxide, methyl chloride, and epichlorohydrin. The Witco Janesville plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in safety and environmental 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." Witco's Janesville plant has implemented reasonable controls to prevent and mitigate probable releases of hazardous chemicals. In the unlikely event of a release, trained personnel would respond to control and contain the release. DESCRIPTION OF STATIONARY SOURCES AND REGULATED SUBSTANCES Witco's Janesville plant is a derivatives-producing facility located at 2001 Afton Road in Janesville, Wisconsin. The plant is situated on approximately 25 acres on the south side of Janesville in Rock County. Residential property to the north, Panoramic Packaging, Inc. to the east, farmland to the west, and the Rock River to the south occupy the immediate area surrounding the facility. Derivatives have been manufactured at the Witco Janesville plant since 1957. The plant manufactures a variety of fatty nitrogen derivatives using batch reactor pr ocessing involving alkylation, amidation, alkoxylation, esterification, and oxidation of fatty amines, short-chain amines, fat and vegetable oils and acids, alcohols, and glycols. The products are used by manufacturers of soaps, detergents, fabric softeners, and various health and personal care products, primarily for household consumer usage. The facility employs approximately 87 employees and is operated 24 hours a day, seven days a week. WORST-CASE RELEASE SCENARIO AND ALTERNATE RELEASE SCENARIOS The Risk Management Program (RMP) rule requires the development of accidental release scenarios for the toxic chemicals at our site. A worst-case scenario and alternate release scenario are designed to evaluate 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 chemical to travel the farthest distance at ground level. It als o assumes that none of the facility's mechanical controls or safety systems is operational. A worst-case scenario is a highly unlikely event. Given the severe guidelines of a worst-case scenario, more realistic alternate release or planning scenarios were also developed to more closely resemble a real world event. These scenarios involve smaller releases and allow safety systems to be included in the release containment and dispersion calculations. These alternate release scenarios are useful to local government and industry to prepare emergency response plans. Worst-Case Toxic Release Scenario The worst case toxic release for the Janesville plant would be the catastrophic failure of an ethylene oxide storage tank. Assuming all safety systems fail in the worst possible weather conditions, and a total release of the entire tank contents of 143,000 pounds in 10 minutes using EPA mandated criteria, the off-site impact is predicted to be up to 8.7 miles as calculated by the EPA's R MP*Comp model. However, this scenario is highly unlikely to occur, as the tank is equipped with pressure safety relief devices should overpressure threaten to catastrophically rupture the vessel. The vessel is also contained within a concrete secondary containment area, equipped with a water deluge system to suppress any ethylene oxide vapors released. The tank level, pressure, and temperature are continuously monitored by operator-manned control systems. In addition, the vessel undergoes routine mechanical integrity inspections, which include piping systems, instrumentation, and unloading facilities. The facility also maintains a fully trained emergency response team (ERT), available to respond to emergencies 24 hours a day. Furthermore, this scenario is unlikely to impact up to 8.7 miles as the plant would utilize the water deluge system and emergency response team to minimize the release of ethylene oxide, while contacting off-site responders if the release would impact off-s ite populations. Alternate Toxic Release Scenarios Alternate release scenarios are those which are more likely to occur than the worst-case release scenario. Alternate release scenarios are those that lead to concentrations above the endpoint specified by EPA, which extend past the facility's fenceline. The facility has utilized EPA's default modeling parameters, and assumed releases at ground level. All alternate release modeling was performed utilizing EPA's RMP*Comp model, which yielded a toxic endpoint of less than 0.1 miles for all scenarios modeled. In order to determine a more precise distance, the SAFER. Systems TRACE model was used. This model yielded actual distances reported in feet, and all scenarios modeled resulted in no off-site impact. - Ethylene Oxide: The alternate release scenario surrounds a release due to a gasket failure on a 1-inch transfer line requiring 3 minutes to abate. The calculated release rate is 30 pounds per minute with a toxic endpoint of 21 6 feet, having no off-site impact. - Propylene Oxide: The alternate release scenario surrounds a release due to a gasket failure on a 1-inch sparge line requiring 5 minutes to abate. The calculated release rate is 40 pounds per minute with a toxic endpoint of 154 feet, having no off-site impact. - Methyl Chloride: The alternate release scenario surrounds a release due to a gasket failure on a 1-inch transfer line requiring 5 minutes to abate. The calculated release rate is 40 pounds per minute with a toxic endpoint of 20 feet at ground level. However, at 100 feet above ground level, the toxic endpoint is at approximately 640 feet due to the vapor density of methyl chloride. Regardless, due to neglibile toxicity at ground level, no off-site impact results. - Epichlorohydrin: The alternate release scenario surrounds a release due to a gasket failure on a 1-inch transfer line requiring 3 minutes to abate. The calculated release rate is 30 pounds per minute with a toxic endpoint of 227 feet, having no off-site impact. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The Janesville plant maintains a rigorous Process Safety Management program, which satisfies all applicable requirements of both OSHA's Process Safety Management Rule 29 CFR 1910.119 and EPA's Risk Management Rule 40 CFR 68. The facility maintains policies and programs that address required program elements as follows: Employee Participation: The facility encourages employees to participate in all facets of process safety and accident prevention programs. Examples include participation in Process Hazard Analyses (PHAs), operating procedure development, injury and/or incident investigations, unsafe act and/or condition reporting, safety committee meetings, plant safety meetings, pre-manufacturing meetings, management of change reviews, etc. Process Safety Information: Process safety information is compiled prior to beginning any PHA or PHA revalidation effort to assure proper documentation is av ailable for the review team's utilization during the PHA process. Process safety information is kept evergreen through the utilization of the management of change process as well as periodic internal and corporate audit verifications. Process Hazard Analysis: The facility maintains a procedure to assure PHAs and PHA revalidations are conducted within prescribed timeframes. A management system is in place to document and track PHA action items to timely completion, assigning resources as needed to maintain demonstrable progress. Operating Procedures: The facility maintains a procedure for creating operating procedures, which includes all requirements specified by OSHA and EPA. Annual reviews are conducted as required. Operating procedures are reviewed and updated as required by the management of change process and through suggestions made by operators. Training: The facility maintains a written and walkthrough training program for operations, maintenance, and distribution personn el. Facility personnel undergo training on OSHA, EPA, and DOT required subjects on an ongoing basis. Operations and maintenance personnel have received both PSM overview training as well as specific process hazards overview training. Refresher training is conducted at least every three years. Contractors: The facility maintains a contractor qualification program which meets all OSHA and EPA requirements. Contractors receive hazard identification training prior to commencement of work and are monitored by the internal auditing program to assure compliance with all OSHA, EPA, and Witco standards. Pre-Startup Safety Reviews: The facility maintains an active program to perform pre-startup safety reviews on all changes to assure that all phases of the change have been installed correctly, personnel have been trained as required, and maintenance procedures are in place to safely maintain the equipment. Mechanical Integrity: The facility maintains an extensive mechanical integrity prog ram that covers not only PSM and RMP covered equipment but also other equipment at the site. Routine maintenance procedures are in place for critical equipment and tests required complying with PSM and RMP, following manufacturer recommendations. Safe Work Practices: The facility maintains safe work practice policies which govern Hot Work, Confined Space, Lockout/Tagout, and Line Breaking, which meet or exceed all OSHA and EPA requirements. Compliance with these procedures is assured through the plant's internal auditing process. Management of Change: The facility maintains an active management of change process which governs all changes made at any time of the day or night, in accordance with OSHA and EPA requirements. Incident Investigation: The facility investigates all incidents and near misses in a timely fashion which meets or exceeds all OSHA and EPA requirements utilizing a multi-discipline incident investigation team. The incident investigation team is comprised of manag ement, operations, maintenance, and laboratory personnel, and its members are available to investigate incidents 24 hours a day. Emergency Response: The facility maintains a trained Emergency Response Team (ERT) with members either on-site or on-call 24 hours a day, seven days a week. The facility has emergency plans and procedures in place, and has communicated these with local regulating agencies. Compliance Audits: The facility undergoes qualifying Process Safety Audits every three years in accordance with OSHA and EPA requirements. Additional audits are performed on a periodic basis through the plant's internal audit program. SPECIFIC PREVENTION STEPS The facility maintains the ongoing integrity of equipment through its mechanical integrity program. Chemical processes are well documented through the ISO 9000 system, which are shared with operations prior to implementation of a new process. Primary mitigation for hazardous events includes relief devices, deluge systems, fir e monitors, foam protection, sprinkling systems, and secondary containment. FIVE-YEAR ACCIDENT HISTORY The facility has had no releases in the last five years that meet the criteria for accidental release reporting as defined within 40 CFR 68.42. PLANNED CHANGES TO IMPROVE SAFETY Witco Janesville has several elements of the management system of the accident prevention program in place to continue to improve safety throughout the facility. The plant uses the elements of PSM/RMP to continuously improve safety by focusing on: - involving employees in all aspects of process safety; - rigorously maintaining the ongoing processes of Management of Change, Process Hazard Analysis, and Mechanical Integrity; - investigating and reviewing all incidents to learn from them and prevent future incidents; and - ensuring, at a minimum, compliance with all OSHA, EPA, and Witco standards by undergoing Process Safety Audits. By remaining committed to a safe workplace and community, and by adherin g to the belief that "Safety is unequivocally our number one priority", the safety of the Witco Janesville Plant will continue to improve. |