Vulcan Chemicals - Executive Summary |
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PORT EDWARDS EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Vulcan-Port Edwards plant has a long-standing commitment to worker and public safety and to the protection of the environment. We are committed to operating and maintaining all of our processes in a safe and responsible manner, as demonstrated by the resources we invest to prevent accidents. As a member of the Chemical Manufacturers Association, we adhere to the principles of Responsible Care.. In addition to ensuring that our employees have the best possible training in the operation of our processes, we demand that safety be the first priority in the design, installation, operation, and maintenance of our processes. Our process equipment is designed, constructed and maintained using sound engineering practices and conforms to applicable industry codes and standards including those of the Chlorine Institute for equipment used in manufacturing and handling of chlorine. Our poli cy is to implement reasonable controls to prevent foreseeable releases of regulated substances. We have implemented maintenance and inspection programs to ensure site integrity. Examples of some such controls include 1) installation of pressure safety valves to prevent rupture of vessels due to overpressurization, 2) routine visual inspection and thickness checks to ensure vessels and piping are in good condition, 3) limiting inventory in chlorine storage tanks, 4) monitoring vessel and piping pressures. However, if a release does occur, trained personnel will respond to control and contain the release. Mitigation measures that have been included in our design include installation of isolation valves, excess flow valves which limit the amount of chemical released, a fully implemented emergency response plan, appropriate personnel protective equipment, and an alarm system for early notification of a release. Should a release occur, we use a dispersion model - Systematic Approach Fo r Emergency Response (SAFER), and meteorological data from our weather tower, to predict the plume direction and size, downwind ground level concentrations, and the estimated time at which the plume will reach off site areas. This information is communicated to 911 in case any actions need to be taken by emergency response agencies. STATIONARY SOURCE AND REGULATED SUBSTANCES The Vulcan-Port Edwards plant is primarily involved in manufacturing chlorine and other inorganic chemicals. As a part of these manufacturing processes, we produce chlorine and use sulfur dioxide as a feedstock. They are substances that are covered by the Risk Management Program (RMP) rule (40 CFR 68). Following is a brief description of the facility and a list of RMP-regulated processes at our facility. The maximum quantities of these regulated substances that may be present at the plant are 1.2 million pounds of chlorine and 240,000 pounds of sulfur dioxide. The RMP regulated processes are the chlorine pl ant, chlorine rail car loading, sulfur dioxide storage and handling equipment of the sodium hydrosulfite plant. These processes are Program Level 3. Vulcan products serve a multitude of vital needs throughout the United Sates and global economies. Chlorine is sold as a product and is also used as a feedstock in the manufacture of hydrochloric acid. Common uses of chlorine include treatment of municipal water supplies, sewage and wastewater. Chlorine is also used to make bleach. Sulfur dioxide is used as a feedstock in making sodium hydrosulfite. Our customers use sodium hydrosulfite in the paper industry to bleach paper. We use a combination of good design practices, release prevention programs, and an emergency response program to ensure the safety of our employees, the public, and the environment. We are committed to operating our facility in a safe and responsible manner. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPAs RMP rule (40 CFR 68) requires that we provide inf ormation about two types of off site consequence analysis scenarios: worst-case scenarios and alternative release scenarios. There are strict requirements for choosing and modeling worst-case release scenarios; as a result, these scenarios are often exceedingly conservative. The purpose of the alternative release scenarios is to provide emergency planners with more information about the chemicals we handle and about their relative hazards. The alternative release scenarios are more realistic than worst-case release scenarios but are still unlikely to happen. Following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures that limit exposure distances. Worst-case toxic release scenarios The worst-case release scenario representing the toxic substances handled by Vulcan is a catastrophic rupture of a storage tank containing chlorine. In this scenario, the entire contents of a full chlorine tank, 600,000 lb, is released to the atmosphere over a 10-min period. Although we have several safety and mitigation features on these storage tanks that would limit the release rate and/or quantity of the release, none of these measures is taken into account in evaluating this scenario. The chlorine released to the atmosphere in this scenario travels more than 25 miles before dispersing below the end point of 3 ppm. Approximately 110,000 people live within 25 miles of the storage tank. Some of the public and environmental receptors that are located within this distance are as follows: Public Receptors: County Parks, Recreation Areas, Boat landings, Hospitals, Shopping Malls, School Systems, Major commercial, office and industrial complexes. Environmental Receptors: State Wildlife Areas, State Fishery Areas, County Wildlife Area, and a National Wildlife Refuge. Alternative toxic release scenarios The alternative release scenario for chlorine is a break in the pipe used for loading chlorine from t he process into a rail car. The 2,900 lb of chlorine in the pipe is released to the atmosphere, and another 5,000 lb flows out over 5 minutes, which is the length of time required for a Vulcan employee to stop the release. The chlorine travels about 5 miles before dispersing below the end point of 3 ppm. Approximately 11,000 people live within this distance from the storage tank. Some of the public and environmental receptors that are located within this distance are as follows: Public Receptors: Boat landings, Nursing Home, Hospital, Shopping Malls, School Systems, Major commercial, office and industrial complexes. Environmental Receptors: No environmental receptors within this release distance. The alternative release scenario for sulfur dioxide is a break in the pipe used for unloading sulfur dioxide from the rail car into our process. The flow rate to the atmosphere is limited to 30,000 lb/hr, because a greater flow rate will activate the excess flow valve and shut off the flow. The release lasts for 5 min, which is the length of time required for a Vulcan employee to stop the release. The sulfur dioxide travels about 2.9 miles before dispersing below the end point of 3 ppm. Approximately 5,000 people live within this distance from the rail car. Some of the public and environmental receptors that are located within this distance are as follows: Public Receptors: Boat landings, Nursing Home, Shopping Malls, School Systems, Major commercial, office and industrial complexes. Environmental Receptors: No environmental receptors within this release distance. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. We are in compliance with OSHA's Process Safety Management (PSM) rule and this RMP rule. Our management system addresses each of the key features of a successful prevention program, as described below: PROCESS SAFETY INFORMATION The Vulcan-Port Edwards plant maintains a variety of technical documents that describe the chemicals and processes at our facility. These documents are kept up to date and are available to all employees and address important process parameters such as (1) operating limits for the equipment, (2) design basis and configuration of the equipment, and (3) physical properties and hazards of the chemicals used in our processes. Plant personnel rely on these documents to perform their job functions properly, consistently and in a safe manner. Chemical information is documented in material safety data sheets (MSDSs). MSDSs contain information concerning the physical properties and the hazards associated with each chemical. This information typically includes (1) toxicity information, (2) physical data, (3) reactivity and corrosivity data, (4) thermal and chemical stability data, and (5) hazards of mixing substances together. MSDSs are available to all employees, as well as the emergency responders in our community. Important process parameters are also documented and maintained. Engineering design documents include (1) safe operating limits, (2) block flow or simplified process flow diagrams, (3) process chemistry, (4) maximum intended inventories, (5) pressure relief system design basis and configuration, (6) piping and instrumentation diagrams, and (7) other information that is important for understanding the design intent, operating limits, and hazards of each process. PROCESS HAZARD ANALYSIS The Vulcan-Port Edwards plant has a comprehensive program for ensuring that the hazards associated with our processes are identified and controlled. Each process is examined in detail to ensure that all hazards are identified and that appropriate controls are in place to manage those hazards. Our hazard assessments focus on preventing injuries to the plant personnel, the community and preventing adverse impacts to the environment. A hazard and operabi lity (HAZOP) analysis or a What If / Check List is typically used for our process hazard analyses. A team comprising personnel with engineering, operations, and maintenance experience systematically examines each hazard in each section of the process and identifies potential causes and a range of possible consequences. The team then compares the hazard to the existing set of prevention and mitigation measures designed to contain that hazard, making further recommendations when deemed necessary. These recommendations are reviewed by management and are tracked until they are implemented. We update and revalidate each process hazard analysis every five years. The results and findings from these revalidation studies are documented and retained, and recommendations are tracked until resolved by management. OPERATING PROCEDURES Our engineers, operators, and supervisors work together to develop and maintain operating procedures that ensure the safe operation of our facility. These proc edures cover all modes of operation, such as (1) unit start up, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial start up of a new or improved process. Operating procedures are used as a reference by experienced employees and provide a consistent basis for training new employees. In addition to describing the steps for safely conducting operations, the procedures also contain valuable information about safe upper and lower limits, consequences of deviations, and applicable safety and health information. Operating procedures are annually certified as accurate to ensure that they are updated following process changes. TRAINING The Vulcan-Port Edwards plant trains workers to safely and effectively perform their tasks. Employees who are new to a process are given basic training that includes (1) a general overview of the process, (2) the properties of the substances used in the process and their associated hazards, and (3) a detailed review of the operating procedures for that process. Once they have demonstrated their understanding of this initial training, they are paired with an experienced operator to learn their specific job functions and tasks. After they demonstrate their competence in performing these tasks, they are allowed to work independently. Through oral reviews, written tests, and on-the-job demonstration, we ensure that our employees understand the training given to them. Both classroom and on the job training is provided. In addition to training in specific job functions, training is also provided on safe work practices. The frequency of refresher training is decided, in part, by our employees but is performed at least every three years. All training given to an employee is documented, along with the means used to verify that the training is understood. MECHANICAL INTEGRITY The Vulcan-Port Edwards plant maintains the mechanical integrity of our equipment to prevent equipment fai lures that could endanger workers, the public, or the environment. Our inspection and testing program helps identify equipment damage or deterioration before the equipment fails. Predictive maintenance technologies employed include vibration analysis, thermography and ultrasonic analysis. Vibration analysis is used for early detection of bearing problems on pumps and motors. Thermography is used to locate problems on electrical equipment and ultrasonic technology is used to determine the thickness of tank walls and piping. When a deficiency is found, maintenance personnel will correct the problem and try to identify the root causes of the deficiency so that future problems are avoided. Our quality assurance system ensures that new or replacement equipment meets the strict design standards required for service in our facility. The mechanical integrity system includes (1) inspection and testing procedures, (2) replacement equipment specifications, (3) procedures for safe work prac tices, (4) maintenance personnel training, and (5) required documentation. MANAGEMENT OF CHANGE We review any changes to our processes to determine if new hazards are introduced or existing prevention measures are threatened. Except for replacements-in-kind (e.g., replacing a valve with an identical valve), all changes are subjected to a hazard analysis to ensure that (1) new hazards are not inadvertently introduced into the system, (2) safety consequences resulting from the change are addressed, (3) operators in the process are notified of the change and made aware of possible repercussions, and (4) all training material, process safety information, and operating procedures are updated. The management of change system applies to changes in the chemicals used, process equipment, technology, procedures, and other facility changes. PRE-STARTUP REVIEW Whenever a change occurs that requires updating the process safety information, the Vulcan-Port Edwards plant performs a pre-startup safety review. This review ensures that safety features, procedures, personnel, and the equipment are prepared for service before the process is restarted. A pre-startup review will generally include field verification of new construction and also serves a quality assurance function by verifying that accident prevention measures are implemented correctly. Generally, a pre-startup review will ensure that (1) construction and equipment are consistent with design standards, (2) adequate operating, safety, and maintenance procedures are in place, (3) training for all affected employees is complete, (4) a process hazard analysis has been performed and (5) process hazard analysis recommendations have been addressed and (6) actions required for start up have been completed. INCIDENT INVESTIGATION The Vulcan-Port Edwards plant trains its employees to promptly investigate each incident that resulted in, or could have resulted in, injuries to employees, the public, or impact the environment . Incident investigations are designed to determine the facts, identify the root causes, and provide recommendations for ensuring that the incident does not recur. Corrective actions resulting from an incident investigation are tracked until they are resolved. Some examples of changes made as a result of incident investigations include developing new procedures or revising existing ones, changing equipment construction material and requiring operators to perform additional monitoring. EMPLOYEE PARTICIPATION The Vulcan-Port Edwards plant encourages employees to be involved in every aspect of process safety management and accident prevention. Employees are routinely asked to participate in process hazard analyses, incident investigations, management of change hazard analyses, and all other aspects of the prevention program. Employees have access to all information developed as part of the prevention program, and are specifically informed of any changes that occur in their process areas. The various ways employees are involved in the prevention program are documented in a written plan. SAFE WORK PRACTICES The Vulcan-Port Edwards plant has established safe work practices that ensure the safety of our employees. Examples of these procedures include (1) a hot work permit that is designed to control spark or flame-producing activities, (2) a permit and procedure to control confined space entry, and (3) a lockout / tagout procedure for isolating energy sources during maintenance. These procedures and permits ensure that operations and maintenance activities are performed safely. CONTRACTORS The Vulcan-Port Edwards plant uses contractors for various activities, such as maintenance and construction. All contractors are evaluated to ensure that they are well trained and are able to perform their job function in a safe manner. A contractors safety record and performance are reviewed during the selection process. Once a contractor is selected, the Vulcan-Port Ed wards plant provides training and procedures to ensure that contractor employees (1) perform their work in a safe manner, (2) are aware of the hazards associated with the area in which they will be working, (3) understand the emergency response procedures, and (4) report any hazards they find during their work. Our personnel periodically monitor contractor activities to ensure they are performing their work in a safe manner. COMPLIANCE AUDITS A compliance audit is performed periodically to help ensure that the prevention program activities at our facility are adequate and that safety issues are addressed effectively. Audits are performed by a team that is knowledgeable in our processes, but is independent of our facility, to ensure a thorough and complete evaluation. The audit team systematically evaluates each aspect of the prevention program, ensuring both compliance with the RMP rule and effective hazard prevention. The results of audits are documented, and recommendations are tracked until they are resolved. Compliance audits are conducted at least every three years. CHEMICAL-SPECIFIC PREVENTION STEPS The prevention program described previously ensures the safe operation of our facility by providing our employees with a system they can use to safely perform their job functions. This management system helps prevent hazards associated with equipment failures and human error. In addition to the prevention program, the Vulcan-Port Edwards plant has safety features built into the design of our facility that help to ensure safe process operation for our employees, the public, and the environment. These features may contain or control a release, detect a release, or reduce the consequences of a release. They may also prevent a release by providing strict design standards for process equipment. The following types of safety features are used in various processes in our facility: Release detection 7 Chlorine detectors in the production, storage and loading areas 7 Sulfur Dioxide detectors in the process, storage and unloading areas 7 Video surveillance of the loading/unloading area 7 Procedures requiring that a Vulcan-Port Edwards plant employee be present during loading and unloading operations 7 Procedures requiring that plant operators inspect their work area on a routine schedule Release containment and control 7 Valves to permit isolation of the process 7 Automated shutdown systems for some process parameters (e.g., high level, high pressure) 7 Manual shutdown systems located in the control room 7 Pressure relief valves and rupture discs 7 Excess flow valves on the chlorine and sulfur dioxide storage tanks and rail cars Release mitigation 7 Fire suppression equipment, including preconnected fire hoses and fire extinguishers are located through out the plant 7 Trained emergency response personnel 7 Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) FIVE-YEAR ACCIDENT HISTORY The Vulcan -Port Edwards plant has operated since August 12, 1968 (over 30 years) without a lost time injury to any plant employee. There have been no reportable injuries, environmental damage or equipment damage as a result of a chemical release from this facility during the past five years. EMERGENCY RESPONSE PROGRAM The Vulcan-Port Edwards plant maintains a written emergency response plan that is designed to protect employees, the public, and the environment. The procedures include all aspects of emergency response, including proper first-aid and other medical procedures, the use of emergency equipment, the use of personal protective equipment, evacuation plans, and community emergency response notification procedures. Procedures for maintaining emergency response equipment are also contained in the emergency response plan. There are procedures that address maintaining, inspecting, testing, and using the critical equipment needed in an emergency. Employees receive periodic training in t he duties they are expected to perform during an emergency, and any change in the emergency response plan is administered through the management of change process so that affected employees are notified. The emergency response plan is coordinated with local emergency responders (e.g., the fire department). This includes periodic meetings among community responders and facility representatives so that they are aware of the hazards of our processes. Communication channels with local responders are kept open 24-hours per day. This coordination and communication ensures that the public is quickly notified, if necessary, and that action is promptly taken to minimize the consequences of a release. We periodically conduct emergency response drills so that all participants are familiar with their duties during an emergency. The Vulcan-Port Edwards plant maintains a Citizen's Advisory Panel (CAP) as a sounding board to gather public input regarding our operations. This includes growth pl ans, transportation issues, public safety and our emergency response plans. Members of the CAP include School officials, Neighbors, the County Sheriff, a local Chemist, a Science Teacher, the Director - Emergency Government and employees of our Industrial Neighbor's. PLANNED CHANGES TO IMPROVE SAFETY The Vulcan-Port Edwards plant continuously strives to improve the safety of our processes. Suggestions for improving safety are regularly addressed through process hazard analyses, management of change procedures, incident investigations, and employee suggestions. Vulcan has implemented a comprehensive Year 2000 program that addresses all aspects of computer, microprocessor and software use throughout the company's business and industrial operations. At the plant, vulcan has inventoried equipment that uses computers, microprocessors and software. Equipment that performs date processing will be tested and /or upgraded to ensure that it is Year 2000 compliant. The following changes are currently under consideration. An automated emergency shut off system for bulk transfer of chlorine (loading). A containment system for the chlorine storage area. A change to the inlet chlorine line to the bleach system. |