Hawkins Point Plant - Executive Summary

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Risk Management Plan 
for Hazardous Chemical Handling 
At 
Millennium Inorganic Chemicals, Inc. 
Hawkins Point Plant Manufacturing Facility 
 
 
 
 
Millennium Inorganic Chemicals, Inc. 
3901 Fort Armistead Road 
Baltimore, MD 21226 
 
 
 
June 3, 1999 
 
 
TABLE OF CONTENTS 
 
SECTION 1 - RISK MANAGEMENT PLAN INFORMATION 
   Page 
Executive Summary    ....................................................................................................................     5 
1.    Registration   .............................................................................................................................      7 
2.    Offsite Consequence Analysis - Toxics: Worst Case   ..............................................................     10 
3.    Offsite Consequence Analysis - Toxics: Alternative Release   .................................................     12 
4.    Five Year Accident History   .....................................................................................................     21 
5.    Prevention Program   
.................................................................................................................        30 
6.    Emergency Response   ...............................................................................................................     34 
7.    Certification   .............................................................................................................................     35 
 
SECTION 2 - RISK MANAGEMENT PLAN SUPPORT DETAIL 
 
2A.  INTRODUCTION   ...............................................................................................................             37 
2B.  HAZARD ASSESSMENT   ...................................................................................................        39 
   1.    Applicability   ...................................................................................................................     39 
   2.    Offsite Consequence Analysis Parameters   ......................................................................    39 
   3.    Worst Case  
Release Scenario Analysis   ...........................................................................        41 
   4.    Alternative Release Scenario Analysis   ............................................................................    42 
   5.    Offsite Impacts - Population   ............................................................................................    43 
   6.    Offsite Impacts - Environment   ........................................................................................        43 
   7.    Review and Update   .........................................................................................................        43 
   8.    Documentation   .................................................................................................................        44 
   9.    Five-Year Accident History   .............................................................................................        44 
 
2C.    PREVENTION PROGRAM    ................................................................................. 
..............    44 
1. Process Safety Information    ..............................................................................................44 
2. Process hazard Analysis    ...............................................................................................    48 
3. Operating Procedures    ......................................................................................................    49 
4. Training    ............................................................................................................................    49 
5. Mechanical Integrity    ......................................................................................................    49 
6. Management of Change    .....................................................................................................50 
7. Pre-startup Review    ............................................................................................................51 
8. Compliance Audits    ............................................... 
.............................................................51 
9. Incident Investigation    ......................................................................................................    52 
10. Employee Participation    .....................................................................................................52 
11. Hot Work Permit    .............................................................................................................    53 
12. Contractors    .....................................................................................................................    53 
 
   2D.  EMERGENCY RESPONSE    ................................................................................................    53 
1. Applicability    ....................................................................................................................53 
2. Emergency Response Program    .......................................................................................54 
 
 
FOREWORD 
This Risk  
Management Plan has been prepared for submission to the United States Environmental 
Protection Agency (EPA). It summarizes ongoing activities at the Millennium Inorganic Chemicals, Inc. Hawkins Point plant located in Baltimore, Maryland.  These activities comprise the facility's Risk Management Program. 
I 
The Millennium Inorganic Chemicals, Inc. Hawkins Point Plant Risk Management Program has been authorized by the Company's executive management at the facility.  Its primary purposes are: 
 
1.    to prevent serious accidental releases of hazardous substances at the facility, and 
2.    to ensure effective means are available to respond to any accidental release that may occur so that potential impacts to the public or environment in the vicinity of the facility are minimized. 
 
The Hawkins Point Plant's Risk Management Program is maintained and managed in compliance with federal requirements under 40 CFR Part 68 (Risk Management Program) and in accordance with Millennium Inorganic Chemical's co 
rporate and facility environmental, health, and safety policies. 
 
Further details concerning risk management activities at the Millennium Inorganic Chemicals Inc., Hawkins Point facility are available to interested parties upon request. 
 
Information contained within this Risk Management Plan is presented in two sections.  Section 1 describes the Risk Management Plan Information.  Section 1 is a copy of RMP Submit and reflects the information required under federal guidelines.  Section 2 presents the Support Detail. This section provides supplemental information in support of the hazard assessment, prevention program, and emergency response materials included in Section 1. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SECTION  1 
 
 
 
RISK MANAGEMENT PLAN INFORMATION 
 
Date Prepared:  June 3, 1999 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXECUTIVE SUMMARY 
The Millennium Inorganic Chemicals, Inc. Commitment to Safety and Environment provides the foundation for all risk management programs and activities within the Hawkins Poi 
nt Plant.  In keeping with this commitment, the Hawkins Point Plant has established a comprehensive Safety Management System that strives to identify and eliminate all potential exposures. The Safety Management System and Philosophy embodies and employs the spirit and intent of the concepts found in the CMA Responsible Care Initiative, the OSHA Process Safety Management Standard, all other applicable regulatory standards, and Millennium Inorganic Chemicals, Inc. Corporate Safety and Health Standards. The Plant Safety Management System strives to control all potential exposures that include, but are not limited to, personal injury/illness, property damage, fires, process incidents and breaches of security. The Hawkins Point Plant Safety Management System includes the following Safety, Health, and Environmental Policy statement. 
 
"There is no activity or job at the Hawkins Point Plant that is so important or urgent that it must be done at the jeopardy of the safety or health of any emplo 
yee or contractor, or at the risk of damaging the environment... An employee has the responsibility to stop any activity or job that they feel may jeopardize the safety or health of any employee or contractor, or that may risk damaging the environment." 
 
Management at the Millennium Inorganic Chemicals Inc. Hawkins Point facility has authorized specific risk management programs and activities in compliance with EPA's "Risk Management Program" ruling (40 CFR Part 68) that:  
 
* assess the hazards of processes which handle or store more than the threshold quantity of substances regulated by the EPA, 
* prevent accidental releases of these hazardous substances, and 
* effectively respond to emergencies if a release occurs. 
 
Description of Hawkins Point Plant  
The Millennium Inorganic Chemicals Inc. Hawkins Point Plant produces titanium dioxide for shipment to external users. The covered process is the "Rutile Production Process". This  process handles two chemicals included on the EPA regula 
ted list, namely chlorine (CAS Number 7782-50-5) and titanium tetrachloride (CAS Number 7550-45-0).  
 
Worst Case Release Scenario 
RMP regulations require performing a consequence analysis for one worst case release scenario, estimated to present the greatest distance in any direction to a toxic endpoint.  The worst case release scenario is presented in the Hawkins Point Plant's RMP-Submit submission. 
 
 
Alternative Release Scenarios 
RMP regulations require that at least one alternative release scenario be identified and analyzed for each regulated toxic chemical present. The regulations require that a scenario that is more realistic than the worst case scenario is selected as the alternative release.  
 
In performing these analyses, alternative scenarios were considered for each of the two regulated substances present, chlorine and titanium tetrachloride. The scenarios selected involve the release of chlorine from a transfer line on a chlorine railcar, and a release of titanium tetrachlo 
ride due to overfilling of a storage vessel.  
 
The chlorine transfer line rupture is assumed to release 2500 pounds of chlorine during a 5 minute period at a rate of 500 pounds per minute.  The release quantity is assumed not to be limited by the excess flow valves located on the railcar.  The 5 minute duration is based on a conservative estimate of operator response times needed to control the release established through previous incidents and training drills.  The estimated distance to the toxic endpoint (ERPG-2) was found to be 0.4 miles. The residential population estimated for the area as obtained from census data and confirmed by area survey is 0.  
 
The titanium tetrachloride overfill of a storage vessel is assumed to release 2,000 pounds of titanium tetrachloride during a 5 minute period at a rate of 400 pounds per minute. The release quantity is limited by the rate of production at the facility. The 5 minute duration is based on a conservative estimate of response times needed  
to control the release established through previous incidents and training drills.  The estimated distance to the toxic endpoint (ERPG-2) was found to be 0.2 miles. The residential population estimated for the area as obtained from census and confirmed by area survey data is 0.  
 
Five Year Accident History  
During the five years immediately prior to the date of this report, there were no releases of chlorine or titanium dioxide that caused an offsite impact. However, the following accidental releases were experienced at the Hawkins Point Plant that caused employee injury.  
 
Date    Chemical Released           Amount             Source                 Weather         Damages 
3/13/9    titanium tetrachloride           less than 1lb.      process vessel      unknown     none 
6/4/96    titanium tetrachloride           less than 1lb.      process vessel      unknown     none 
12/5/96    chlorine                      less than 1lb.      piping failure      Class E            none 
 
Emergency Response Program  
The Millennium Inorganic Chemic 
als, Inc. Hawkins Point Plant emergency response policy involves the preparation of an emergency response plan tailored to the process and emergency response services that are available in the nearby community. These plans comply with EPA "Emergency Response Program" requirements stipulated in 40 CFR Part 68. The emergency response program consists of an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up to date.  
 
 
 
 
 
 
 
 
 
 
 
 
7.    CERTIFICATION 
The undersigned certifies that, to the best of the signer's knowledge, information and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete. 
Signed: 
 
___________________________________________ 
John L. Davis 
Director of Manufacturing 
Hawkins Point Plant 
Millennium Inorganic Chemicals 
 
 
 
 
 
 
END  OF  SECTION  1 
 
 
 
 
 
 
 
 
 
SECTION  2 
 
 
 
RISK MANAGEMENT PLAN  
 
SUPPORT DETAIL 
 
Date Prepared:  June 3, 1999 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M 
illennium Inorganic Chemicals, Inc. 
Hawkins Point Plant Risk Management Plan  
Section 2 -  Supporting Information 
 
2A.        INTRODUCTION 
 
Millennium Inorganic Chemicals Inc. Commitment to Safety and Environment 
 
The Millennium Inorganic Chemicals Inc. Hawkins Point Plant Safety and Health Policy provides the foundation for all risk management programs and activities within the Hawkins Point facility.  This policy states that the management of Millennium Inorganic Chemicals' Hawkins Point Plant is dedicated to providing a safe and healthy work environment for all employees, contractors, and visitors to the site. The well being of all personnel, physical assets, and the surrounding community will be given the highest consideration in our business operations and planning. 
 
In keeping with this commitment, the Hawkins Point Plant has established a comprehensive Safety Management System that strives to identify and eliminate all potential loss exposures.  Our Safety Management System and Philos 
ophy embodies and employs the spirit and intent of the concepts found in the CMA Responsible Care Initiative, the OSHA Process Safety Management Standard, all other applicable regulatory standards, and Millennium Inorganic Chemicals' Corporate Safety and Health Standards.  The Plant Safety Management System strives to control all potential loss exposures that include, but are not limited to, personal injury/illness, property damage, fires, process incidents, and breaches of security. 
 
The Hawkins Point Plant recognizes the dynamic nature of our business and, therefore, is dedicated to continually improve our Safety Management System, through maintaining knowledge of regulatory requirements and best industry practices, and incorporating employee participation into all the Safety Program elements. 
 
Although the ultimate responsibility for safety and loss prevention at this location rests with the Plant Manager, specific safety responsibilities are assigned to all levels of management.  A 
ll employees are expected to perform their work safely and to recognize that working safely is a condition of employment.  The operating philosophy of this site is that all injuries, occupational illnesses, and incidents are preventable. 
 
Employee Responsibilities 
 
All employees are required to: 
1. Work in such a manner that will safeguard themselves and other individuals from injury/illness; 
2. Report to supervision and seek first aid immediately for all injuries, regardless of severity; 
3. Report to supervision immediately, any unsafe conditions or occurrences that could result in injury to people, or loss to property or the process; 
4. Understand the potential hazards, operating procedures and safe work practices that apply to their job(s) and abide by these established work controls; 
5. Stop any activity or job that they feel may jeopardize the safety or health of any employee or contractor, or that may risk damaging the environment. 
6. Participate in Safety Management programs as  
detailed in applicable Process Safety Management and Responsible Care program elements. 
 
 
Management Responsibilities 
 
The Hawkins Point Plant Safety Philosophy is predicated on safety being a line management function.  The responsibilities for management representatives listed below will be practiced according to the level in the organization and the function (line or staff) which the individual holds.  Generally, front line management representatives will oversee the implementation of safety initiatives while more senior managers provide the leadership and necessary resources to ensure effective implementation of safety system initiatives. 
 
All Management Representatives are required to: 
 
1. Monitor and evaluate the work area and its support elements to insure that all work can be accomplished in a safe and healthful manner; 
2. Investigate and follow through on deficiencies identified as a result of accidents, incidents or reports of unsafe occurrences; 
3. Insure that all employees i 
n their charge are educated on the hazards, operating procedures and safe work practices that apply to their job(s); 
4. Actively support and participate in safety program initiatives and solicit the input of all employees in the safety program. 
 
Introduction 
 
The Millennium Inorganic Chemicals Inc. Hawkins Point Plant is designed, built, and operated for the purpose of producing titanium dioxide pigment for shipment to external customers. To ensure adherence to its Safety and Health Policy, management at the Hawkins Point Plant has authorized specific risk management programs and activities to address hazards associated with processes and products at this facility.  The purposes of these programs are to: 
 
* assess the hazards of processes which handle or store hazardous substances, 
* prevent accidental releases of these hazardous substances, and 
* effectively respond to emergencies if a release occurs. 
 
These programs have been modified to become compliant with EPA's "Risk Management P 
rogram" ruling (40 CFR Part 68) and are described within the "Risk Management Plan" for the facility.  
 
The Risk Management Plan for the Hawkins Point facility includes two sections.  Section 1 provides data related to the risk management program.  Section 2 provides information supporting the data presented in Section 1 and additional information to describe the risk management program and activities at the facility, and validates compliance with EPA regulations. 
 
 
 
 
Contents 
This Section provides information about risk management programs and activities at the Millennium Inorganic Chemicals Inc. Hawkins Point Plant.  This information supports data presented in Section 1 of the Risk Management Plan for the facility, and validates compliance with the EPA Risk Management Program regulation. 
 
This Section includes the following sub-sections: 
 
2B/    Hazard Assessments  
2C/    Prevention Program 
2D/    Emergency Response Program 
 
Description of Hawkins Point Plant 
 
The Hawkins Point Plant produces 
titanium dioxide for shipment to external users. The RMP covered process is the "Rutile Production Process".  This process operates on a continuous basis and comprises 2 steps involving two chemicals included on the EPA regulated list, chlorine (CAS Number 7782-50-5) and titanium tetrachloride (CAS Number 7550-45-0).  The process is described briefly below. 
 
Step 1 -   Titanium ore is reacted with chlorine gas (Cl2) to produce titanium tetrachloride                      (TiCl4). 
 
Step 2 -  Titanium tetrachloride (from step 1) is reacted with oxygen (O2) to produce titanium dioxide (TiO2). 
 
2B.        HAZARD ASSESSMENTS 
 
The hazard assessments examined worst case release and alternative release scenarios at the Hawkins Point Plant.  
 
1.    APPLICABILITY 
 
The Hawkins Point Plant handles chlorine and titanium tetrachloride, both of which are EPA-regulated toxic substances, in quantities exceeding their regulatory threshold (2,500 pounds for each).  The "Rutile Production Process" at this plant is 
also subject to OSHA "Process Safety Management" regulations (29 CFR 1910.119).  In addition, public receptors are present in the toxic endpoint zone for the regulated chemicals present.  For these reasons, the "Rutile Production Process" at this plant is deemed to be subject to Program 3 requirements of 40 CFR Part 68. 
 
2.    OFFSITE CONSEQUENCE ANALYSIS PARAMETERS 
 
The following parameters were used in determining offsite consequences for the Rutile Production Process at the plant handling the regulated toxic chemicals chlorine and titanium tetrachloride. Worst case and alternate case release scenarios were examined using the RMPCompTM Version 1.06 software developed by EPA for this purpose. The calculations performed by the software are equivalent to those in the EPA RMP Offsite Consequences Analysis Guidance.  
 
Endpoints 
 
As required by EPA, the toxic endpoint of chlorine is 0.0087 mg/L and the toxic endpoint of titanium tetrachloride is 0.020 mg/L. These endpoints were used in defin 
ing offsite consequences in worst case scenarios and alternative release scenarios. 
 
 
Wind Speed, Atmospheric Stability Class 
 
As required by EPA, a wind speed of 1.5 meters per second (m/s) and an atmospheric stability class F were used in performing the offsite consequence analysis for the worst case release scenario for each regulated substance present. For alternative release scenarios, the EPA default parameters were used. They are a wind speed of 3.0 m/s and an atmospheric stability class of D.  
 
Ambient Temperature/Humidity 
 
Default values for ambient temperature and humidity are incorporated in the RMPCompTM software developed by EPA. The default temperature of 25 degrees C (77 degrees F) and default humidity value of 50 percent were used as inputs for all scenarios.  
 
Height of Release 
 
The RMP regulation requires that, for the worst case release analysis, the release should be assumed to occur at ground level (0 feet).  This is a conservative approach to effect the release he 
ight on the modeled scenario.  Our worst case and alternate release scenarios were performed for this level. 
 
Surface Roughness 
 
RMP regulations require that either urban or rural topography should be used in performing air dispersion analysis for unidentified release scenarios.  These topographies are characterized in air dispersion models in terms of surface roughness.  A rural condition, defined by EPA (68.22(e)) as "no buildings in the immediate area and the terrain is generally flat and unobstructed in the immediate area", whereas an urban condition is characterized by "many obstacles in the immediate area (EPA RMP Comp Guidance). Urban conditions were used in both the worst case release and alternative case release scenarios.  
 
Dense or Neutrally Buoyant Gases 
 
RMP regulations require that the models used for dispersion analysis should appropriately account for the density of the released gas. Default values for gas density are incorporated in the RMP CompTM software developed by 
EPA for chlorine and titanium tetrachloride.  The default values were used in all release scenarios.  
 
 
Temperature of Released Substance 
 
The chlorine storage temperature coincides with the ambient temperature.  Therefore, the temperature for a chlorine release is the same as the ambient temperature. For titanium tetrachloride, the process storage temperature of 85 degrees F was used. 
 
 
3.        WORST CASE RELEASE SCENARIO ANALYSIS   
 
RMP regulations require that a worst case release scenario be performed in compliance with specified conditions, as detailed below. 
 
Number of Release Scenarios 
 
RMP regulations for Program 3 processes require performing a consequence analysis for one worst case release scenario, estimated to present the greatest distance in any direction to a toxic endpoint.   
 
 
 
Dispersion Modeling Results 
 
The dispersion modeling results of the worst case analysis are presented in the Hawkins Point Plant's submission of RMP Submit. 
 
4.        ALTERNATIVE RELEASE SCENARIO ANALYS 
IS  
 
Number of Scenarios 
 
RMP regulations require that at least one alternative release scenario be identified and analyzed for each regulated toxic chemical present. The regulations require that a scenario that is more realistic than the worst case scenario is selected as the alternative release. The rationale for the selected scenarios, which are more credible than the worst case scenario discussed above, was the identification of possible failure scenarios. 
 
 
 
In performing these analyses, alternative scenarios were considered for each of the two regulated substances present, chlorine and titanium tetrachloride. The scenarios selected for chlorine, involves the release from a transfer line on a chlorine railcar. The scenario selected for titanium tetrachloride involved a storage vessel overflow due to overfilling the vessel. Summaries of the scenarios and the modeled output are included as Appendix A. 
 
The chlorine transfer line rupture is assumed to release 2500 pounds of chlorine  
during a 5 minute period at a rate of 500 pounds per minute.  The release quantity is assumed not to be limited by the excess flow valves located on the railcar.  The 5 minute duration is based on known operator response times needed to control the release established through previous incidents and training drills.  The estimated distance to the toxic endpoint (ERPG-2) was found to be 0.4 miles.  
 
The titanium tetrachloride storage vessel overflow scenario is assumed to release 2,000 pounds of titanium tetrachloride during a 5 minute period at a rate of 400 pounds per minute. The release quantity is assumed to be limited by the rate of production at the facility. The 5 minute duration is based on known operator response times needed to control the release established through previous incidents and training drills.  The estimated distance to the toxic endpoint (ERPG-2) was found to be 0.2 miles.  
 
Consideration of Mitigation 
The release of chlorine from a transfer line on a chlorine rai 
lcar included no passive mitigation. The active mitigation measures available include chlorine sensors located in the vicinity of the railcar, automatic shutoff valves, and operator actuated shut-off valves. The release of titanium tetrachloride  included passive mitigation using a dike situated around the vessel. The active mitigation measures available include operator actuated emergency shutdown controls, and a permanent foam application system mounted in the diked area used to blanket any release to prevent vaporization through air contact.  
 
5.    OFFSITE IMPACTS - POPULATION 
 
The EPA RMP regulations require determination of the potentially affected residential population within a circle with its center at the point of the release and a radius determined by the distance to the endpoint, estimated to two significant digits. The data source used for this estimate was the 1990 census data provided in the Landview III software package. The census tracts involved present residential popul 
ations.   
 
The population potentially affected by the worst case release scenario for the Hawkins Point Plant is pesented in the submission of RMP Submit. 
 
The population  potentially affected by an alternative release was determined by area survey. The chlorine transfer line rupture has an estimated distance to the toxic endpoint (ERPG-2) of 0.4 mile. The residential population estimated for this area is 0.  The titanium tetrachloride storage vessel overfill has an estimated distance to the toxic endpoint (ERPG-2) of 0.2 miles. The residential population estimated for the area is 0. A graphic representation of the potentially affected areas is provided in Figure 2. 
 
6.    OFFSITE IMPACTS - ENVIRONMENT  
 
Environmental receptors to be identified include natural areas such as national or state parks, forests or monuments, officially designated wildlife sanctuaries, preserves, refuges or areas and Federal wilderness areas. Local US Geological Survey maps were consulted. Categories of environ 
mental receptors identified on the USGS maps within the endpoint area were presented in Section 1. 
 
 
7.    REVIEW AND UPDATE  
 
The offsite consequence analyses described within this document will be reviewed and updated at least once every five years. Changes in the process, quantities stored or handled, or any other aspect of the facility that may alter the current RMP assessment will be evaluated. Update of the RMP has been included in the plant's Management of Change procedures. If it is determined that the change increases or decreases the toxic endpoint distance by a factor of two or more, a complete revised analysis will be performed and a revised risk management plan will be submitted within six months of the change. 
 
 
 
 
8.    DOCUMENTATION  
 
The required records for the offsite consequence analysis are provided in Section 1 and the Appendix to this report.  
 
9.    FIVE YEAR ACCIDENT HISTORY  
 
During the five years immediately prior to the date of this report there were no environmental  
releases of chlorine or titanium tetrachloride that caused an offsite consequence. However, there were three accidental releases experienced at the Hawkins Point Plant that involved an injury to an employee.  
 
Date            Chemical Released        Amount           Source        Weather   Damages 
3/13/96        titanium tetrachloride        < 1 lb.        process vessel    unknown    none 
6/4/96            titanium tetrachloride        < 1 lb.        process vessel    unknown    none 
12/5/96        chlorine                    < 1 lb.            piping failure    Class E        none 
 
2C.        PREVENTION PROGRAMS 
 
Prevention of accidental releases of hazardous substances at the Millennium Inorganic Chemicals, Inc. Hawkins Point Plant involves a unified approach that integrates technologies, procedures, and management practices.  These prevention programs comply with all applicable requirements of OSHA "Process Safety Management" (PSM) regulations, as stipulated in 29 CFR 1910.119 and all applicable EPA "Risk Management Program" (RMP) requirements, as stipulated in 40 CFR Part 68.  The natu 
re of the covered process and the types and quantities of hazardous substances present require that the Rutile Production Process be considered as "Program Level 3" process for EPA RMP regulations. 
 
The following information describes the prevention programs, responsibilities, and activities carried out by Millennium Inorganic Chemicals Inc. at the Hawkins Point facility. 
 
1.        Process Safety Information 
 
Written safety information is available to describe the hazards inherent in products, processes, and equipment used at the Hawkins Point Plant.  This information includes Material Safety Data Sheets, Process Control Plans, safety procedures, operating procedures, and equipment manuals and design files. Responsibility for maintaining this information is detailed in the Plant Quality System Instruction for control of Process Safety Information. 
 
1a)    Product Safety  
 
Two RMP-covered hazardous substances are handled and stored at the Hawkins Point Plant.  These are chlorine (chemical formu 
la: Cl2, CAS #7782-50-5) and titanium tetrachloride (chemical formula: TiCl4, CAS #7550-45-0).  Material Safety Data Sheets (MSDS) are maintained in operating areas where these substances are processed. MSDS are reviewed in Process Hazard Analysis, and are maintained current and complete by the Process Safety Management System. 
 
The primary hazards of these two substances are summarized briefly below. 
 
 
 
 
 
 
Chlorine 
Titanium Tetrachloride 
Information Source 
MSDS (Dow Chemical Company) 
(1998) 
MSDS (Millennium Inorganic Chemicals Inc.)   (1998) 
Toxicity 
Potential vision impairment through eye contact. 
Potential lung injury, death from inhalation 
Highly toxic by inhalation. Excessive inhalation can result in chemical bronchitis, pneumoitis and diffuse endobronchial polyposis. 
Permissible Exposure Limits 
OSHA 0.5 ppm (TWA)  
None established by OSHA or ACGIH (0.5 mg/m3 Millennium Standard) 
 
 
Physical Data 
boiling Point 29oF 
vapor Pressure 82 psig 
vapor Density 2.49 @ 32oF 
water solubility = 
0.73 gm/100gm @20oC 
specific gravity = 1.47 @32oF and  53psia 
amber appearance, pungent odor 
 
Boiling Point 278F (1 atmos.) 
Vapor Pressure 12.4 mm @25oC 
Vapor Density 4.9 (air = 1) 
water solubility = not applicable 
specific gravity = 1.73 @20oC 
colorless or light yellow liquid 
Reactivity Data 
may react explosively with some organics under confinement 
reacts violently with water to release hydrochloric acid 
Corrosivity Data 
None 
Highly corrosive 
Thermal / Chemical Stability 
May react to cause fire/explosion upon contact with certain organic compounds and metals. 
Incompatible with water, heat, reactive metals, alcohols, bases and organics. 
Hazards of Inadvertent Mixing 
May react explosively with some organics under confinement.  
Reacts with water to produce hydrochloric acid. 
 
Written safety information about regulated substances handled or stored at the Hawkins Point Plant is provided in Material Safety Data Sheets (MSDS), Process Control Plans, and other sources such as handbooks, jou 
rnals and supplier product data sheets.  This information is maintained as part of the Process Safety Management program.  Copies of pertinent MSDS and other product safety information are available in the production areas.  
 
1b)    Process Technology 
 
The production of titanium dioxide at the Hawkins Point Plant follows simple chemistry whereby titanium (present in the ore) is reacted with chlorine in a reducing atmosphere to produce titanium tetrachloride which is subsequently oxidized (by reaction with oxygen) to produce titanium dioxide. Chlorine produced during the oxidation step is recycled and again reacted with titanium bearing ore.  This general process chemistry is outlined below: 
 
 
 
 
 
 
   TiO2 + 2Cl2    -->    TiCl4  +  2[O] 
 
   2C  +  3[O]      -->    CO  +  CO2     
 
TiCl4  +  O2      -->    TiO2 + 2Cl2         
 
The chemistry shown above is used at the Hawkins Point Plant to produce titanium dioxide using the process referred to as the "Rutile Production Process". This process is subject to OSHA Process Saf 
ety Management regulations, and therefore is a Program 3 process for compliance with the RMP requirements.  
 
The Rutile Production Process is a linked contiuous process that is accomplished in 2 steps: 
 
Step 1: Titanium (introduced in ore form) is reacted with chlorine gas to produce titanium  tetrachloride.  
 
Step 2: Titanium tetrachloride is reacted with oxygen to produce titanium dioxide and chlorine.  The chlorine produced is recycled to process step 1.  Titanium dioxide produced is subsequently cleaned and packaged for shipment to customers. 
 
The simplified process flow diagram for this process is shown below: 
 
                                                    
                
             
Titanium Ore    r     
Coke  r                                             
Chlorine    r             Tn                      r  Titanium Tetrachloride   
                                                         ( 
                            (            (                            (  Oxygen     
                                 Waste        Recycle ( 
                                   Chlorine                             
                                                       ( 
                                               Titanium Dioxide       r    Shipment  
 
 
 
 
 
 
 
The Rutile Production Process at the Hawkins Point Pl 
ant is operated under controlled temperature and pressure conditions (as defined in Process Control Plans). Exceeding high temperature or pressure limits could cause a release of regulated substance(s).   
 
To ensure safe operation, the process has been designed, built, and operated with numerous process controls. Inherent in the operation of the process are relief vents, relief valves, check valves, emission control devices, manual and automatic shutoffs, interlocks, alarms, redundant controls and equipment, detailed procedures, emergency air supply, emergency backup power, excess flow devices, rupture disks, and a fail safe system.  In the event of an accidental release, mitigation systems within the process include dikes, a foam system, and a neutralization system.  Monitoring devices separate from the process include area chemical detectors and television monitors. 
 
Documented safety information for the above covered process is maintained as part of the plant Process Safety Manageme 
nt system and is accessible to employees through the Engineering Department.  This information includes simplified flow diagrams, process chemistry (including reaction, thermodynamic and kinetic data), safe upper and lower limits for temperature, pressure, flow and composition. Consequences of deviation from these limits, and maximum intended inventory of regulated substances.   
 
Written information on safety systems is also maintained as part of the Process Safety Management documentation. This includes interlock and alarm schedules, design basis for foam and fire suppression systems, fire water system design, power source description, process controls database, and emergency shutdown program record.  Material and energy balances are available for processes built after May 26, 1992. 
 
Written procedures for operating the Rutile Production Process are maintained in the site Quality Assurance Manual. Copies are also kept in the Control Room for the process. Each operating procedure is re 
viewed at least annually to ensure it is correct and up to date. Changes in operating procedures are approved by the Operations Manager and Process Engineering Manager prior to implementation.  Process Hazard Analyses are used to ensure that best available technology and operating practices are used within the covered process. 
 
1c)    Equipment Safety 
 
The Hawkins Point Plant was designed and built in conformance with the following codes and standards: 
 
 
   Electrical Equipment - Class 2, Division 1 
   Relief System Design - Chlorine Institute Standards 
   All Other Equipment  - American Society of Mechanical Engineers (ASME) standards  
 
 
Certain special materials and safety equipment are used at the Hawkins Point Plant for added protection, including Inconel materials, foam suppression systems, and hard-wired dual system interlocks. 
 
Written safety information for equipment used in the covered process at the Hawkins Point Plant is maintained by the Engineering and Maintenance Departments.  Thi 
s includes specification sheets for materials of construction, piping and instrument diagrams, electrical classifications, relief system design and design basis, ventilation system design with codes and standards employed, process and engineering design files, equipment specifications, and piping and instrumentation drawings (P&ID). 
 
The Director of Manufacturing is the final authority for verifying that equipment has been installed in accordance with recognized and accepted good engineering practices.  This authority has been delegated to the Reliability/Engineering Department Manager.  Specific responsibilities have also been assigned to the Quality/Technical Engineering Manager (for equipment and process design).  It is the responsibility of the Manufacturing Manager to ensure that installed equipment is safe for operation and that employees have been properly trained prior to equipment startup. 
 
 
 
 
2.        Process Hazard Analysis 
 
Process hazard analyses (PHA) are performed at the Hawk 
ins Point Plant to ensure that existing, new, or changed processes have been designed and installed such that risk of injury, property damage, and environmental losses are minimized.     
 
The Quality/Technical Manager (individual with primary responsibility for the process safety management system, as assigned by the Manufacturing Director) is responsible for determining the need and priority order for Process Hazard Analyses to be performed, the method(s) to be used, and the makeup of the team that will perform each PHA.  The makeup of each PHA Team includes at least one person who is familiar with the area being evaluated, one with knowledge of the method of evaluation, and one with expertise in the process.   
 
A process hazard analysis is performed at least every five years on each process covered by the EPA Risk Management Program and/or OSHA Process Safety Management standard, and prior to startup of new or modified processes if required.  In conducting these PHAs, consideration i 
s given to process safety information, process hazards, previous incidents, facility siting, and human factors. 
 
The results of each PHA are documented in a PHA Report.  The report, written and issued by the PHA Team, identifies recommendations for any corrective and/or preventive actions deemed necessary and a priority ranking for these actions.  The final PHA Report is issued to site and corporate management personnel, including Department Managers.  Recommended actions are assigned to appropriate Department Managers for resolution and completion. The Process Engineering Superintendent is responsible for administering the corrective actions noted on the PHA Report by using the Corrective Action Tracking System.  Individual Department Managers are responsible for ensuring that progress towards completion of PHA recommendations is timely and consistent with PHA findings.  
 
The most recent "PHA" for each covered process within the Hawkins Point Plant was performed on January 1999.  The  
PHAs address major hazards, process controls, mitigation systems, monitoring and detection systems, and identified specific actions to be taken.  Actions recommended by this PHA are scheduled to be completed by June 2000.  
 
Records of all PHAs performed are maintained within the facility's electronic record keeping database. 
 
 
 
 
3.        Operating Procedures 
 
Written operating procedures are used in the Rutile Production Process at the Hawkins Point Plant.  These procedures are provided in the Hawkins Point Plant Quality Assurance Manual.  They are available in the operations control room and at additional locations specified in the Quality Assurance Manual.  These procedures address initial startup, normal, temporary, and emergency operations, normal and emergency shutdown, and startup following shutdown.  In addition, written quality system procedures and/or work instructions are available in the Quality Assurance Manual for reviewing and approving operating procedures, ensuring that the  
correct version is used and that obsolete versions are removed from unintended use, maintaining records and for quality control of raw materials. 
 
Additional procedures are documented in the Safety Manual covering hot work permit activities and other safe work practices. 
 
Each operating procedure is reviewed at least annually by the end of each calendar year. The most recent review of operating procedures at the Hawkins Point Plant was conducted in May, 1999. 
 
4.        Training 
 
Prior to operating any process equipment at the Hawkins Point Plant, employees must complete a formal training program that addresses job procedures within covered processes and other applicable OSHA training requirements.  This training is repeated at least every three years or pursuant to change for all operators by reviewing the operating procedures for the process to which they are assigned.  Understanding and competence in the training material(s) presented is confirmed by on the job supervision.  Training reco 
rds are maintained within the facility's electronic tracking system.  
 
In addition, each employee is trained in process safety management policies and procedures that will affect his/her job.  This training is conducted prior to commencing work, with refresher training at least every three years. 
 
By issuing and signing the Risk Management Plan for the Hawkins Point Plant, the manufacturing Director certifies that employees of Millennium Inorganic Chemicals, Inc. operating processes on June 21, 1999 have the necessary knowledge, skills, and abilities to safely carry out the duties and responsibilities specified in the operating procedures for the Rutile Production Process. 
 
5.        Mechanical Integrity 
 
The Hawkins Point Plant Mechanical Integrity Program is developed and revised by the Reliability /Engineering Manager and administered by the facility Reliability Group.  This program is designed to verify that processes and newly fabricated and in-use equipment and instrumentation are suit 
able for their intended use, and designed, fabricated, installed and retired in a manner to prevent releases of hazardous substances, and comply with OSHA and EPA regulations.  Related policies, practices and procedures in use at the facility are documented in the Mechanical Integrity Manual.  
 
 
Elements of the Mechanical Integrity Program apply to pressure vessels, storage tanks, piping systems, relief devices, vent systems, emergency shutdown systems, controls, and pumps within specific processes including the Rutile Production Process.  It includes written procedures, training for process maintenance activities, inspection and testing, documentation of equipment deficiencies, and quality assurance of fabricated equipment. 
 
The mechanical integrity of pressure vessels, storage tanks, pumps, piping systems and components, emergency shutdown systems, and controls (including monitoring devices, sensors, alarms and interlocks) in the Rutile Production Process are maintained by visual ins 
pection and non-destructive testing (per API recommendations).  All equipment in the process is visually inspected monthly.  All rotating equipment is tested monthly for vibration.  Relief and vent systems are replaced or retested at least annually (or more frequently, if required as a result of a Process Hazard Analysis). 
 
Inspection and testing includes specific inspections and tests to be performed, procedures that follow good engineering practices, and the frequency of testing consistent with manufacturer's recommendations or operating experience.  Equipment deficiencies identified by these inspections and tests are corrected through the facility's work order procedures.  Records of inspection and tests performed are maintained by the facility Reliability Superintendent.  
 
Quality assurance elements within the Mechanical Integrity Program ensure that equipment and maintenance materials and parts are purchased from approved vendors and are in conformance with Millennium Inorganic Ch 
emicals, Inc. specifications  
 
6.        Management of Change 
 
The management of change (MOC) system at the Hawkins Point Plant is a review and approval system that defines administrative controls, including steps and actions taken, whenever process equipment, procedures, chemicals or processing conditions are substituted, added or modified, or a plant trial is to occur.  MOC ensures that process hazards and risks are evaluated and measures are taken to eliminate or minimize any adverse impact on product quality, process safety, personnel health or the environment.  This system consists of three procedures, Management of Change, Design Changes, and Plant Trials.  
 
Prior to implementing any change the originator of the change identifies the technical basis for the proposed change, benefits to be derived, and impacts on safety, health, and the environment on a "Request for Change" (RFC) form.  Information provided on the form by  Operations, Maintenance, and Project Engineering details actions 
necessary before implementing the change and any training required.  Additional details concerning prestartup safety review and a technical review checklist are completed before startup authorization is granted.  Before the change can be implemented, authorizations to proceed are required from the Manufacturing, Process Engineering, and other appropriate Departments.  
 
Once approved, the completed "Request for Change" forms are posted in Control Rooms and the  intended change is communicated to employees. Training programs are conducted as deemed necessary by the Production Superintendent.  If a change requires modification of an operating procedure, responsibility for making and approving such a change is identified on the Request for Change form.  The change cannot be implemented until all necessary approvals have been obtained. 
 
7.        Prestartup Safety Review 
 
A prestartup safety review is performed before beginning a new process or one which has been sufficiently modified to require 
a change in its process safety information, operating procedures, or emergency response plan.  Such a review is also performed after any prolonged shutdown.  The purpose of this review is to ensure that the new or modified process or equipment meets all safety requirements and has been designed and built according to the intended standard or code.  The need for a prestartup safety review is defined on Request for Change forms or by the Project Engineer in charge of the project (as assigned by the Manufacturing Director, or designee) and the Process Engineer assisting.  
 
Prestartup safety reviews confirm that required activities have been acceptably completed relating to safety rules, permits and procedures, operating procedures, emergency procedures, environmental impact(s), electrical classifications, PHA "A" priority recommendations, piping and instrument drawings, mechanical integrity procedures, employee training, spare parts inventory, documentation of process safety information, 
verification of use of good engineering practices, filing of pre-commissioning records, and verification that construction is in accordance with design. 
 
A Review Committee assigned by the Manufacturing Director, or designee performs prestartup safety reviews.  The results of this Committee's review are documented and sent to the Production Superintendent to authorize startup of the unit or to other appropriate persons to cause additional recommended actions to take place before (or after) startup.  The completed prestartup safety review is maintained as part of the records for the project. 
 
The new or modified process cannot be operated until the required prestartup review has been completed.  Startup of the new or modified process must be authorized by the Manufacturing Manager (or designee) based on the results of the prestartup review . 
 
8.        Compliance Audits 
 
It is Millennium Inorganic Chemicals, Inc. policy that operations at the Hawkins Point Plant shall comply with all applica 
ble provisions of the EPA "Risk Management Program" and OSHA "Process Safety Management" regulations.  The Vice-president of Safety, Health, and the Environment has the corporate responsibility for ensuring that compliance is evaluated in all appropriate processes at least every three years.  The most recent compliance evaluation for the entire facility was performed in October, 1997 and February, 1998.  Actions required as a result of this audit are scheduled to be completed by July, 1999. 
 
Compliance audits are performed by a team of individuals approved by the Vice-president of Safety, Health, and the Environment, who ensures that the team includes at least one person who is knowledgeable in the process being audited.  Results of these audits are reported in writing to the Manufacturing Director, with recommendations for corrective action (if any).  The Manufacturing Director determines actions to be taken, including responsibility and timing, to resolve the actions recommended on c 
ompliance audit reports. The results of compliance audits are retained on the computerized data base at the facility. 
 
 
9.        Incident Investigation 
 
An investigation is performed whenever an incident at the Hawkins Point Plant involves death, injury, significant property damage, hospitalization or other offsite medical treatment, shelter-in-place, evacuation, or significant environmental damage. Additionally an accident investigation is performed if an incident could have caused any of the afore mentioned conditions but did not. The purpose of such an incident investigation is to identify factors that contributed to the incident and determine its root cause. 
 
Incident investigations are conducted by a team of employees assigned to the investigation and approved by the Manager of the Department conducting the investigation. These investigations occur within 48 hours of the incident, as specified in the site Safety and Health Guidelines, corporate policies and procedures and in procedures 
identified in the facility Safety and Health Manual.  
 
Upon completing its investigation, the investigation team recommends actions to be taken to prevent a recurrence of the incident.  These recommendations, including specific actions and a timeline, are communicated to the functional manager for review and assignment of responsibility for completing each action. The findings of an incident investigation are reported in writing, posted openly for review by all employees, and reviewed during Safety Meetings. These reports are retained for at least five years. 
 
10.        Employee Participation 
 
Millennium Inorganic Chemicals, Inc. encourages the involvement of its employees in all matters related to safety, process safety, and release prevention at the Hawkins Point Plant.  Employees are encouraged to raise specific concerns and/or suggestions by contacting their immediate supervisor.   Through line management, employees are consulted, informed and trained on safety and process activities.  
 
 
Unions active at the facility have fully subscribed and support the intent of the facility's Safety and Health Policy and have appointed employee representatives to participate on the site Safety, Health, and Environmental Team.  Additionally, a Union/Management Committee promotes employee participation in the elements of the Hawkins Point Plant safety and health program, and reviews employee concerns or suggestions regarding safety. 
 
All employees and their representatives have access to process safety information and process hazard analysis reports, subject to company confidentiality policies.  Access to safety information is made available through Material Safety Data Sheets, process descriptions, defined safe operating limits, operating instructions, and other process safety information. 
 
The facility's "Employee Participation" program includes provisions for employee participation in developing the facility's process safety management program, procedures addressed within this pr 
ogram, and participation in process hazard analyses, prestartup reviews and incident investigations. 
 
Employees are made aware of the requirements of the facility's Process Safety Management program through training programs and communication of committee minutes.  Reports concerning the facility's Process Safety Management Program are available to any employee upon request. 
 
11.        Hot Work Permits 
 
The Hawkins Point Plant uses specific procedures for ensuring that hot work is performed safely.  These procedures are documented in the Hawkins Point Plant Safety Manual.  These procedures require that all hot work be permitted.  Permits describe the work to be done, authorized date, and fire prevention requirements.  Hot work permits are maintained in the operating area until the hot work is completed. 
 
12.        Contractors 
 
Millennium Inorganic Chemicals, Inc. recognizes the importance of contractors safely performing activities at the Hawkins Point Plant.  For this reason, specific procedure 
s that are documented in the Contractor Selection and Monitoring Action Plan are followed for evaluating and reviewing the safety performance of contractors.  The Contractor Subcommittee, under the direction of the Hawkins Point Plant Safety, Health, and Environmental Team, generates and revises all aspects of this plan. 
 
Contractors are pre-qualified by the Purchasing Department before working on site.  This qualification includes a review of the contractor's safety  programs and performance. If necessary, an audit is conducted to ensure that the contractor's employees are trained in safe work practices and understand the hazards pertaining to their job.  Qualified contractors are eligible to become "approved" for specific tasks at the facility. 
 
Each approved contractor must have their respective employees satisfy the requirements of the Hawkins Point Plant Contractor Orientation Program prior to access into the plant.  The extent of the orientation depends on the type of work perfor 
med by the contractor. 
 
The project supervisor, or designee, is responsible for defining the work area for the contractor and for controlling the entrance, presence, and exit of the contractor's personnel, equipment, and materials in that area.   
 
Project supervisors, or designees, are responsible for evaluating the performance of contractors working within their area of responsibility, and for ensuring their compliance with Hawkins Point Plant safety requirements.  Safety and health performance is included, as appropriate, in meetings with contractors. 
 
2D.        EMERGENCY RESPONSE 
 
The Millennium Inorganic Chemicals, Inc. Hawkins Point Plant emergency response policy involves the preparation of an emergency response plan tailored to the process and emergency response services that are available in the nearby community. These plans comply with EPA "Emergency Response Program" requirements stipulated in 40 CFR Part 68. 
 
1.    APPLICABILITY  
 
Under the requirements of 40 CFR Part 68 the Millenn 
ium Inorganic Chemicals, Inc.  Hawkins Point Plant has been designated a Program 3 facility.  Therefore, an emergency response program consisting of an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up to date must be in place.  
 
2.    EMERGENCY RESPONSE PROGRAM 
 
The Hawkins Point Plant routinely updates the emergency response plan every 2 years or as dictated by a recognized need for updates.  The plan is approved by site management. Copies of the plan are maintained at locations throughout the plant, and have been provided to, and coordinated with, the City of Baltimore Fire Department.  Close interaction with the fire department is maintained.  Millennium Chemicals sponsors training for fire department personnel and conducts annual plant tours.  The fire department is the primary responder for site emergencies.  No additional onsite fire fighting capability (beyond normal safety equipment) is maintained.  
 
Th 
e Hawkins Point Emergency Response Plan was last updated November 1998.  It includes specific actions to be taken in response to an accidental release of a regulated substance and procedures for informing the public and local agencies responsible for responding to a release. If a release should occur, the fire department would be contacted. If the emergency exceeds the capabilities of the fire department, additional resources could be brought to bear under the South Baltimore Industrial Mutual Aid Plan (SBIMAP), a cooperative agreement among local businesses.  Emergency health care is the responsibility of onsite individuals trained for this purpose.  Upon arrival of the fire department, the fire and rescue personnel take on this responsibility.  
 
Training on emergency response procedures is performed annually.  The most recent full scale drill was completed in April 1999, with succeeding drills scheduled quarterly throughout the year. Emergency equipment is maintained as a part of the 
plant's routine preventive maintenance program.
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