Elf Atochem North America, Inc. - Executive Summary |
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EXECUTIVE SUMMARY Introduction A Risk Management Program has been implemented at Elf Atochem North America Inc.'s Portland production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Executive Summary is organized to correspond with specific EPA RMP definitions and requirements, including: - Introduction - Elf Atochem policies to protect health, environment, and safety; - Facility identification and regulated substances in covered processes; - Hazard Assessment; - Prevention Program; - Five Year Accident History; - Emergency Response Plan; and - Planned changes to improve safety. Elf Atochem Policies for Health, Environment, and Safety Risk management and safety have been important concerns at Elf Atochem North America for many years; this RMP for malizes and documents these activities. Elf Atochem North America is committed to conducting its operations in a safe, responsible manner and to reducing risks to health and the environment. This commitment to health, environment, and safety (HES) starts with the CEO. Senior management routinely dedicates time to a review of HES matters, including safety. This emphasis on safety is carried through to the facility level, where the Plant Manager and the Safety Committee regularly review safety performance, address potential opportunities for improvement, and strive for continuous improvement. The success of Elf Atochem North America's HES programs is also reflected by a strong commitment to safety by employees and contractors. Elf Atochem North America's HES programs includes policies, procedures, standards, and guidance materials designed to fulfill Elf Atochem's commitment to health, environment, and safety. These materials include Risk Management Program guidance to help our fa cilities prevent and/or reduce the risk of accidents. Facility Identification and Regulated Substances in Covered Processes The Elf Atochem North America Portland facility is located at 6400 N.W. Front Avenue, Portland, Oregon. The facility manufactures chlorine, sodium hydroxide, hydrogen, and sodium chlorate by continuous electrolytic processes. Hydrochloric acid is also produced at the site. Chlorine is present above the minimum threshold for RMP applicability and is regulated at the site under 40 CFR Part 68, the Risk Management Program (RMP) Rule. Hazard Assessment - Worst Case Scenario The worst case accidental release scenario is a catastrophic failure of the largest chlorine storage vessel. Chlorine is stored as a liquid in a tank which is administratively limited to a maximum of 350 tons, and this quantity was assumed to be released over 10 minutes in the worst-case scenario. The administrative controls are reinforced in written operating procedures and by a wei ght alarm on the tank. Although this scenario has an offsite impact, it should be noted that regulatory agencies and Elf Atochem recognize that the worst-case scenario is an extremely unlikely event. Worst-Case Mitigation Measures Multiple layers of preventive measures make it very unlikely that a significant chlorine release will occur. The storage vessel is a thick walled steel tank with concrete foundations supported by numerous piling driven into the ground to refusal at a basalt layer. The tank receives a complete internal inspection at least every two years. The tank is surrounded by a concrete containment structure which would limit the spread of chlorine. Active mitigation systems cannot be considered in determining the impacts of the worst-case scenario, but active mitigation measures should effectively reduce the risk associated with an RMP incident. These measures include: -The chlorine storage vessel is surrounded by area chlorine monitors which continuously prov ide information to chemical operators. The monitors provide an early indication of a leak and are provided with audible alarms. -An emergency storage tank of equal size is maintained at the site. This tank is always empty and is not used for normal inventory storage. Chlorine can be pumped from the damaged tank into the emergency tank to reduce the amount potentially released. -A continuous monitoring system keeps the operators informed of the weight of product in the tank. The tank is normally kept from near empty to approximately 12% full. The tank is rarely ever filled over 30%. Several times a day the operators transfer the contents of the vessel to railcars for shipment. -A pressure relief system is provided for the tank which utilizes pressure relief valves, a buffer tank, and an absorption/scrubbing system. -Excess flow valves are provided on the tank pumps. -A pressure relief system is provided on the tank to capture and neutralize vapors. Hazard Assessment - Alt ernative Release Scenario The Alternative Release Scenario is the failure of a chlorine railcar loading hose. This scenario was selected based on input from the plant's employees and from the plant's Community Advisory Panel. Although the Alternative Release Scenario is somewhat more likely than the Worst Case Scenario, the magnitude of the Alternative Release Scenario selected is still an unlikely event. The Risk Management Plan includes information on mitigation and prevention measures implemented by Elf Atochem North America to reduce the risk of this event. Alternative Release Scenario: Mitigation Measures While the Alternative Release Scenario is, by definition, more likely than the Worst-Case Scenario, it is still very unlikely given the facility's prevention program. Elf Atochem North America has an array of prevention and mitigation measures to prevent the release or reduce the potential impact of the release. Examples of the prevention and mitigation measures include: -The chlorine railcar loading hoses are replaced and the piping is inspected on a regular schedule to ensure they are in good condition. -Chlorine monitors are maintained on all four sides of the railcar loading area and another chlorine monitor is positioned at the railcar dome. These monitors can activate an alarm system which will warn operators of any leak in the area. The monitors can also activate an automatic shutdown system which will shut off the loading pump, and secure the transfer piping and the railcar. -A system is provided on the chlorine railcar so that if movement is detected, the automatic shutdown system will activate to secure the transfer piping and the railcar. -The automatic shutdown system can also be manually activated by pushing a button either at the railcar loading station, or remotely from another building. General Accidental Release Prevention Program A prevention program is in place to minimize the risk of hazardous chemical releases in ac cordance with the Occupational Health and Safety Administration (OSHA) Process Safety Management (PSM) standard (29 CFR 1910.119) and EPA Risk Management Program. The prevention program covers those processes that handle chlorine. The prevention program provides a structured approach to preventing accidents. Some of the specific activities in the prevention program include: -In-depth process hazards analyses are completed and revalidated every five years by qualified personnel using techniques approved under the OSHA PSM standards; -Written operating procedures (kept up-to-date) are used for training and directing the work of operators, who receive refresher training every three years; -Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety; -A safety work permit system assures that work is done safely and properly; -A management system is in place to ensure that c hanges are managed safely; -Critical equipment and chlorine piping are inspected on a planned, periodic basis to assure proper operating condition; -Pre-startup reviews are done to ensure that conditions for safe operation have been satisfied prior to starting new or modified equipment; -Incidents are investigated and actions taken as part of a continuous improvement effort; and -Routine audits are conducted to assure that safe practices are being followed. This systematic approach to process safety involves employees and strives for continuing improvements in accident reduction. The training, qualifications, and safety awareness of our operations, maintenance, and emergency response personnel are a key element in reducing and mitigating accidents. Chemical-Specific Prevention Steps: Worst-Case Scenario Measures that would prevent a chlorine storage tank failure center on the design, construction, and inspection of the tank. These measures include: -The chlorine storage tanks are pressure vessels which are designed and constructed in accordance with American Society of Mechanical Engineers (ASME) pressure vessel standards using industry standard materials of construction. -Chlorine pressure vessels are inspected both as part of the plant's Mechanical Integrity Program and by authorized inspectors in accordance with the State of Oregon's Boiler and Pressure Vessel rules. -The risk of over-filling is addressed by using a scale alarm. -The risk of over-pressure is addressed by a system of pressure relief valves which are connected by piping to buffer tanks. The buffer tanks are connected to a chorine absorption/scrubbing system. -Access to the facility is restricted through security barriers and trained security personnel, thereby minimizing the risk to the tank of vehicular damage or sabotage. -No flammable materials are allowed near the chlorine tank. Construction throughout the facility is noncombustible, and fire hazards are strictly controlled. C hemical-Specific Prevention Steps: Alternative Release Scenario The Alternative Release Scenario selected is the failure of a chlorine railcar loading hose. The most likely cause of such a failure would be for the railcar to be moved while the loading hose is still connected. Prevention steps for this scenario include: -During loading a derail mechanism is set in front of the railcar which prevents other railcars from entering the loading area. -Rail stops (or wheel chocks) are used to prevent movement of the car. -A sign placed on the track ahead of the railcar and a blue flashing light indicate the railcar is being loaded. -Elf Atochem North America carefully controls the railroad switch crew and prohibits hooking up to a railcar that is still connected to the loading system. -A motion sensor on the railcar will activate the automatic shutdown system for railcar loading. The loading pump will automatically shut off, and the transfer pipe and railcar will be secured. -Chlori ne monitors in the loading area can also activate the automatic shut down system. Five -Year Accident History From the beginning of 1994 to the present, there have been only four accidents/releases of chlorine that meet EPA criteria for the Five-Year Accident History. Three releases each involved less than one pound of chlorine gas with no offsite impacts. In 1997, a failed piping connection at the railcar loading area resulted in a release of 105 pounds of chlorine. The only reported effect outside the plant was odor, which was noticed at an adjacent industrial site. Emergency Response A written emergency response plan is maintained at the facility. The plan was developed in cooperation with the local emergency responders. The plan includes procedures for notifying local emergency responders, other agencies, and the public in the event of an incident. The plan also includes documentation of proper first-aid and medical treatment necessary to treat accidental human exposure s; procedures for the use of emergency response equipment and for its inspection and testing; a description of the training program for all employees in relevant emergency response procedures; and procedures for review and update, as appropriate, of the emergency response plan to reflect changes at the facility, and to ensure that employees are informed of these changes. Based on the direction of the plant's Community Advisory Panel, Elf Atochem North America has also adopted a Planning Release Scenario. This scenario consists of a release event approximately ten times larger than the Alternative Release Scenario. This scenario will be used for emergency response planning. Planned Changes to Improve Safety Portions of the Process Safety Management program/ Risk Management Program have been extended to other plant processes not covered by these rules. Written operating procedures have been established for all plant processes and an extensive accidental release prevention program i s utilized for the plant's hydrogen system. Certification I certify to the best of my knowledge, information, and belief formed after reasonable inquiry, that the information submitted is true, accurate, and complete. Signature of Highest-Ranking Official on Site Date Name (Print) Date |