Dupont - Edge Moor, DE Facility - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

1.0     ACCIDENTAL RELEASE PREVENTION AND EMERGENCY 
   RESPONSE POLICIES 
 
At the DuPont White Pigment and Mineral Products Edge Moor Plant near Wilmington, Delaware, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including- 
 
- A description of our facility and use of substances regulated by EPA's RMP regulation 
- A summary of results from our assessment of the potential offsite consequences from accidental chemical releases 
- An overview of our accidental release prevention programs 
- A five-year accident history for accidental releases of chemicals regulated by EPA' 
s RMP rule 
- An overview of our emergency response program 
- The certifications that EPA's RMP rule requires us to provide 
- The detailed information (called data elements) about our risk management program 
 
2.0     STATIONARY SOURCE AND REGULATED SUBSTANCES 
 
Our facility produces titanium dioxide (Ti02) using a variety of chemicals and processing operations. We produce titanium dioxide, a hiding agent used in paint, paper and plastics, is produced via the chloride process. In the Chloride process, titanium bearing ore, chlorine and petroleum coke are combined to produce titanium tetrachloride. The titanium tetrachloride is subsequently oxidized to titanium dioxide using phosphorus trichloride. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: 
 
 
Hazardous Material 
 
Use at Facility 
Chlorine (Cl2) 
Production of titanium tetrachloride 
Titanium tetrachlori 
de (TiCl4) 
Intermediate for titanium dioxide 
Phosphorus trichloride (PCl3)     
Production of titanium dioxide 
 
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 
 
3.0     KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS 
 
EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: 
 
3.1    Worst-case Release Scenarios -- Regulated Toxic Chemicals 
 
The worst-case scenario for chlorine involves the failure of a chlorine storage tank containing 180,000 pounds of chlorine released over a 10 minute time interval. The weather conditions for this release were defined by the EPA 
. This type of release could result in potential impact to public as well as environmental receptors. Determinations were made using EPA's RMP COMP (tm), version 1.06 and  Land View III (tm) Environmental Mapping Software obtained from the U.S. Department of Commerce. 
 
3.2    Alternative Release Scenario - Regulated Toxic Chemicals 
 
The alternative release scenario for chlorine involves release of chlorine from the oxidation reactor over a time interval 10 minutes. The reactor is contained within a building, therefore passive mitigation was used. This type of release could result in potential impact to public receptors.  
 
The titanium tetrachloride alternative release scenario involves a release from a broken unloading hose over a time interval 5 minutes with complete conversion to hydrochloric gas. No administrative controls or mitigation measures were considered for this scenario. This type of release could result in potential impact to public receptors.  
 
The phosphorus trichloride alt 
ernative release scenario involves a release from a broken unloading hose over a time interval 5 minutes with complete conversion to hydrochloric gas. No administrative controls or mitigation measures were considered for this scenario. This type of release could result in potential impact to public receptors.  
 
No environmental receptors are impacted by the any of the alternative release scenarios. Public and environmental receptors were determined using United States Geological Survey (USGS) maps. The weather conditions used were EPA defaults.  Determinations were made using Cameo (tm) with Aloha (tm) and Land View III (tm) Environmental Mapping Software obtained from the U.S. Department of Commerce. Cameo (tm) with Aloha (tm) is used by most Local Emergency Planning Commissions (LEPC) for emergency response planning and modeling. 
 
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingen 
cy cases. 
 
4.0     GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: 
- Process safety information (i.e. process technology) 
- Process hazard analysis 
- Operating procedures and safe work practices (including hot work) 
- Training and performance 
- Mechanical integrity 
- Quality assurance 
- Management of change (technology and subtle) 
- Pre-startup review 
- Compliance audits 
- Incident investigation and reporting 
- Employee participation 
- Hot work 
- Contractors (safety and performance) 
- Management of change-personnel 
- Emergency planning and response 
 
These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set the way  
we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 
 
5.0     FIVE- YEAR ACCIDENT HISTORY 
 
We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: 
 
On November 6, 1996, Edge Moor had an accidental release of approximately 60 pounds of titanium tetrachloride due the overfilling of a tank. There was no off-site impact or injuries as a result of this release. 
 
On April 29, 1996, Edge Moor had an accidental release of approximately 360 pounds of titanium tetrachloride due a pump failure. There was no off-site impact or injuries as a result of this release. 
 
For each of these incidents, we have conducted formal incident investigations to identify and correct the root causes of the events. 
 
6.0     EMERGENCY RESPONSE PROGRAM 
 
We ma 
intain an emergency response plan, which meets all the requirements stated in the RMP rule. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency responders. Our program is detailed in our Edge Moor Emergency Procedure Manual. 
 
7.0     PLANNED CHANGES TO IMPROVE SAFETY 
 
As part of a continual effort to improve safety, reduce environmental impacts and increase the facility's ability to quickly response to emergencies, we intend to perform the following projects: 
 
- Diking of process vessels containing titanium tetrachloride in the production area 
- Integrate chlorine sensors into the plant process control system 
- Redesign relief system for titanium tetrachloride purification area to reduce potential emissions 
- Reduction of fugitive emissions in titanium tetrachloride oxidation area by improvement of existing ventilation syste 
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