Dow Corning Corporation Carrollton Site - Executive Summary
A Risk Management Plan has been implemented at the Dow Corning Corporation Carrollton, Kentucky manufacturing facility. The purpose of this plan is to reduce accidental releases of hazardous materials in order to protect the community, on-site personnel, and the environment.
The Executive Summary provides an overview of the site's comprehensive risk management activities, including:
7 Company overview
7 Facility overview
7 Accidental release prevention and emergency response policies
7 Regulated substances
7 Worst-case release scenarios
7 Alternative release scenarios
7 Accidental Release Prevention Program
7 Accident prevention measures
7 Five-year accident history
7 Emergency Planning and Response Program
7 Planned changes to improve safety
Dow Corning Corporation was founded in 1943 as a joint venture of the Dow Chemical Company and Corning Glass Works. Dow Corning is the world leader in the development and manufacture of silicone based products,
including fluids, emulsions, rubbers, solids, and greases.
Dow Cornings first commercial product was DC4 Compound, a paste applied to the electrical systems of World War II aircraft to prevent corona discharge during high altitude flight. Today, the companys products include silicones, related specialty chemicals, semiconductor grade silicon, and specialty health care products.
Dow Corning is a member of the Chemical Manufacturers Association and subscribes to the Responsible Care. Codes of Management Practices.
The Carrollton, Kentucky site manufactures chlorosilanes, methyl chloride, and silicone products in a series of batch and continuous processing steps. These steps include grinding, chemical reaction, purification, and polymerization. The site has two manufacturing units, Carrollton 1 and 2. Carrollton I began operating in December 1966 and has undergone a series of expansions, and Carrollton II started up in 1991. It is now the largest silicone producti
on facility in the world. Certain substances used at the site are regulated under 401 KAR 68 / 40 CFR 68, Risk Management Program.
The site resides on 125 developed acres of a 1600-acre facility. It is located at 4770 U.S. Highway 42 East, Carrollton, Kentucky on the Ohio River three miles east of Carrollton, 50 miles northeast of Louisville, and 50 miles southwest of Cincinnati.
The site mission is "to be a high volume, operationally excellent, world-class site that produces the highest quality methyl silicone products and intermediates in a safe, efficient, cost effective and environmentally acceptable manner; serves as an appropriate demonstration facility for the commercialization of new technology; and values people in every endeavor."
The site has received the Governors Safety and Health Award, the Kentucky Labor Cabinet Certificate of Recognition, and Voluntary Protection Partnership Star status in recognition of its excellent safety and health programs. The site is ISO 9002
certified by DNV Certification, Inc., allowing it to meet the most stringent international quality standards.
The site voluntarily committed to the Early Reduction Program. Both the EPA and the Kentucky Environmental Protection Cabinet approved the sites efforts to reduce air emissions to one tenth of its 1988 level, and the site continues to reduce air emissions. The site has received its draft Title V Permit and awaits final approval of its Title V Permit application.
Approximately 500 employees work at the site, and a select contractor workforce is utilized during planned maintenance shutdowns and major construction projects. All employees and contractors participate in job-specific training programs.
The site maintains a high level of security at all times. It is fully fenced, and Safety and Loss Prevention Technicians use video cameras to monitor all access points. Personnel enter and exit the site through turnstiles. Visitors must sign in and are escorted, and vehicle access
All areas maintain radio contact with the Safety and Loss Prevention Department and the Site Supervisor. Safety and Loss Prevention Technicians will provide immediate assistance if needed. If an accidental release occurs, the Site Supervisor acts as the Incident Commander and will also dispatch immediate assistance. Using established guidelines, the Site Supervisor will notify the site, community, and proper authorities based upon the severity of the incident.
The site received the Carroll County Chamber of Commerce Special Recognition Award for Community Support in 1998 and the Carroll County Chamber of Commerce Industry of the Year Award in 1991 and 1994. Site employees are active in many community outreach activities, including:
7 ORSANCO Ohio River Sweep
7 Kentucky Special Olympics
7 Christmas for the Needy
7 Cancer Relay for Life
7 March Of Dimes WalkAmerica
7 Four Mile Creek Outdoor Environmental Classroom
7 Community Advisory Panel
7 Compass Neighborhood Newsl
7 Carroll County Good Neighbor Night
7 Risk Management Project Steering Committee
7 Carroll County Industrial Training Consortium
7 Jefferson Community College and Kentucky Tech School-to-Work Program
7 High School and College Co-op Program
7 HAZMAT 7, a northern Kentucky Hazardous Materials Response Team
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
Dow Cornings Accidental Release Prevention Program and the Emergency Planning and Response Program include policies, procedures, and standards to fulfill the companys commitment to health, environment, and safety. This commitment begins with the Office of the CEO and extends through all levels of the organization. Dow Corning employees are guided by Core Values and a Code of Conduct.
Two Core Values provide a necessary foundation:
"Safety. Our attention to safety is based on our full-time commitment to injury-free work, individual self-worth and a consideration for the well-being of others.
"Environment. Our c
ommitment to the safe-keeping of the natural environment is founded on our appreciation of it as the basis for the existence of life."
The Code of Conduct provides additional guidance:
"We are committed to the responsible management of chemicals through our support and practice of the principles of Responsible Care..
"Environmental consideration will be integrated into all appropriate business decisions and will be guided by Dow Corning's Principles of Environmental Management.
"We will continually strive to assure that our products and services are safe, efficacious and accurately represented for their intended uses. We will fully represent the nature and characteristics of our raw materials, intermediates and products including toxicity and other potential hazards to our employees, suppliers, transporters and customers.
"We will build and maintain positive relationships with communities where we have a presence. Our efforts will focus on education, civic, cultural, environm
ental, and health and safety programs."
Internal standards require all Dow Corning facilities with hazardous materials to develop a site-specific accident prevention program. In particular, the Corporate Environmental Policy Manual states:
"Each site that handles or processes toxic or hazardous materials must have a formal program designed to minimize the possibility of accidental spills or releases of those materials to the environment. This program will also include an emergency plan which addresses how the site will respond and report spills and releases which could affect the site or community.
"Emergency plans must be appropriately linked to community emergency services and comply with applicable regulations and Dow Corning Corporate Safety, Health and Loss Prevention Standard ADM-12."
Senior site management demonstrates its commitment by revising and publishing an annual policy which states:
"We, the Management Team of the Carrollton Site, remain committed to make Safety, In
dustrial Hygiene, and safe-guarding the Environment an integral part of our daily activities. While the sites overall performance in 1998 improved from the year prior, we will remain relentless in our pursuit of continuous improvement in all aspects of daily operations. We will provide the necessary resources to maintain compliance with PSM and become fully compliant to all aspects of the RMP regulations as well as pending Title V permit considerations. Our employees, our customers, and the public will be a priority in the manufacture of our products and in the management of our processes. Simply stated our objectives are injury-free work, protection from occupational hazards, and preservation of the environment.
"To this end:
"** The Management Team will provide the resources and support to actively pursue compliance with all legislative and corporate standards.
"** The Safety, Industrial Hygiene, and Loss Prevention Team will protect employee health and safety by anticipating, re
cognizing, evaluating, and controlling potential workplace hazards.
"** The Environmental Team will facilitate plant wide adherence to all applicable environmental regulations and will assist in prevention of pollution at the source.
"** All Site Employees will demonstrate their individual responsibility and full commitment to safety, health, and the environment by conducting all activities in a responsible manner."
Carrollton site employees operate and maintain the facility in a safe and responsible manner. All employees and contractors are involved in the Accidental Release Prevention Program, which is led by the Process Safety Coordinator. Likewise, all on-site personnel participate in the Emergency Planning and Response Program, and the Safety and Loss Prevention Team Leader leads the program implementation. These programs meet or exceed all internal and external requirements.
All employees are individually accountable to meet safety and environmental objectives which include:
7 Participation in monthly team safety meetings to discuss environmental and safety-related topics
7 Attending quarterly site safety and environmental awareness meetings
7 Completing periodic safety and environmental training
7 Involvement in safety and environmental projects
The site uses the following RMP regulated substances:
7 Aqueous hydrochloric acid in varying strengths up to 42 % is manufactured and used as an intermediate.
7 Anhydrous hydrogen chloride is an intermediate manufactured on-site and purchased as a raw material.
7 Methyl chloride is an intermediate manufactured on-site and purchased as a raw material.
7 Methyltrichlorosilane and trimethylchlorosilane are chlorosilane intermediates manufactured on-site. The majority of these substances is shipped to customers or other Dow Corning facilities.
7 Dimethyldichlorosilane is the primary chlorosilane intermediate manufactured on-site. The majority of this substance is used to manufacture silicone
7 Tetramethylsilane and trichlorosilane are silane intermediates manufactured and used on-site. These substances exist in mixtures only.
7 Hydrogen and chlorine are purchased and used on-site; however, the quantities are below the RMP threshold quantities.
Non RMP regulated substances used on-site include silicon, methanol, sulfuric acid, heptane, catalysts, and processing aids. In addition, the site manufactures other silane intermediates and silicone based products. Although these substances are not regulated by RMP, they are included in the site's Accidental Release Prevention and Emergency Planning and Response Programs.
WORST-CASE RELEASE SCENARIOS
The RMP rule requires information about worst-case release scenarios. As required, a toxic and a flammable worst-case scenario were developed.
The CMA Responsible Care. Process Safety Code requires that members "develop and put into place sufficient layers of protection to prevent escalation from a single failure to a
catastrophic event." With the sites comprehensive safety programs in place, these scenarios are considered to be extremely unlikely. Nonetheless, worst-case scenarios provide more opportunities for dialogue regarding accident prevention and emergency response.
EPAs Look-up Tables and rural topography were used to determine potential hazard distances for each scenario. Brief summaries follow, including information about key administrative controls and mitigation measures.
7 The worst-case release scenario for dimethyldichlorosilane, an RMP toxic substance, is the failure of a full storage tank. The containment area and a spill pond were assumed to withstand the scenario; however, no other mitigation measures were considered. This scenario (with a 4.9 ppm endpoint) potentially impacts off-site public and environmental receptors. However, the tank is typically less than half full, significantly reducing the hazard distance.
7 The worst-case release scenario for a flammable mixture co
ntaining tetramethylsilane, an RMP flammable substance, is the failure of a full storage tank. No mitigation measures were considered, and it was assumed that a vapor cloud explosion resulted. This scenario (with a 1 psi overpressure endpoint) potentially impacts off-site public and environmental receptors. However, the tank is typically less than half full, significantly reducing the hazard distance.
ALTERNATIVE RELEASE SCENARIOS
Likewise, the RMP rule requires information about alternative release scenarios. As required, an alternative release scenario was developed for each RMP toxic substance, and one alternative release scenario was developed to represent all RMP flammable substances. The site uses information from these scenarios to ensure that the Emergency Planning and Response Program addresses all reasonable process hazards.
EPAs Look-up Tables and rural topography were used to determine potential hazard distances for each scenario. Brief summaries follow, including info
rmation about key administrative controls and mitigation measures.
7 The alternative release scenario for 42 % hydrochloric acid, an RMP toxic substance, is the failure of a bottom nozzle on a separator tank. It was assumed that 3450 pounds of material were released from a half-inch hole over a period of 30 minutes. Use of emergency shutdown procedures, containment, a deluge system, and a water curtain were all assumed to be 25 % effective in reducing the severity of the release. The hazard distance (with a 20 ppm endpoint) was estimated to be 0.42 miles, potentially impacting off-site public and environmental receptors.
7 The alternative release scenario for anhydrous hydrogen chloride, an RMP toxic substance, is the failure of a flexible hose on a compressor oil system. It was assumed that 1490 pounds of material were released over a period of 15 minutes. Shutdown of the equipment, containment, and a water curtain were assumed to be 25 % effective in reducing the severity of the rel
ease. The hazard distance (with a 20 ppm endpoint) was estimated to be 0.57 miles, potentially impacting off-site public and environmental receptors.
7 The alternative release scenario for methyl chloride, an RMP toxic substance, is the failure of a section of reactor piping. It was assumed that 3700 pounds of material were released over a period of 2 hours and 55 minutes. Use of emergency shutdown procedures, containment, and the addition of water into the reactor system were assumed to reduce the severity of the release. The hazard distance (with a 400 ppm endpoint) was estimated to be 0.06 miles, or 317 feet.
7 The alternative release scenario for methyltrichlorosilane, an RMP toxic substance, is the failure of a gasket under the dome of a rail road tank car. This scenario was selected because the site routinely ships this material by rail. It was assumed that 400 pounds of material were released over a period of 90 minutes. Use of aqueous film forming foam and a water curtain were
assumed to be 25 % effective in reducing the severity of the release. The hazard distance (with a 2.9 ppm endpoint) was estimated to be 0.13 miles, or 672 feet.
7 The alternative release scenario for dimethyldichlorosilane, an RMP toxic substance, is the failure of a rupture disk on a reactor. It was assumed that 19,600 pounds of material were released over a period of 60 minutes. Use of emergency shutdown procedures, containment, and a water curtain were assumed to be 25 % effective in reducing the severity of the release. The hazard distance (with a 4.9 ppm endpoint) was estimated to be 1.3 miles, potentially impacting off-site public and environmental receptors.
7 The alternative release scenario for trimethylchlorosilane, an RMP toxic substance, is the failure of a gasket under the dome of a rail road tank car. This scenario was selected because the site routinely ships this material by rail. It was assumed that 326 pounds of material were released over a period of 90 minutes. Use
of aqueous film forming foam and a water curtain were assumed to be 25 % effective in reducing the severity of the release. The hazard distance (with an 11 ppm endpoint) was estimated to be 0.067 miles, or 354 feet.
7 The alternative release scenario for a flammable mixture containing tetramethylsilane, an RMP flammable substance, is the failure of a distillation column bottom nozzle. It was assumed that 72,000 pounds of material were released over a period of 10 minutes, resulting in a pool fire. Use of emergency shutdown procedures, containment, a deluge system, aqueous film forming foam, and a water curtain were assumed to be 25 % effective in reducing the severity of the release. The hazard distance (with a 5 kW per square meter for 40 seconds endpoint) was estimated to be 0.28 miles, or 1470 feet.
ACCIDENTAL RELEASE PREVENTION PROGRAM
The site takes a systematic approach to prevent or minimize the effects of accidental chemical releases. The Accidental Release Prevention Progra
m complies with 29 CFR 1910.119, Process Safety Management, and 401 KAR 68 / 40 CFR 68, Risk Management Program. The program elements include:
7 Employee and contractor participation in all aspects of accident prevention
7 Sharing safety-related trade secret information with all on-site personnel
7 Maintaining process safety information
7 Conducting process hazard analysis studies
7 Developing written standard operating procedures
7 Completing required training programs
7 Implementation of a preventive maintenance and reliability program for all safety and environmental critical equipment
7 A management of change system to control and document all process changes
7 Pre-startup safety reviews for new projects
7 Internal compliance audits and follow up on corrective actions for continuous improvement
7 Internal incident investigations and follow up on corrective actions
7 Safe work permit system for all work conducted in process areas
7 Contractor safety programs
7 An Emergency Plannin
g and Response Program
ACCIDENT PREVENTION MEASURES
The site has implemented numerous accident prevention measures, including:
7 Operating teams led by experienced Shift Leaders monitor and operate processes using written operating procedures, distributed control systems, methyl chloride leak detection systems, video cameras, and routine inspection.
7 Technicians continually monitor loading and unloading operations. Rail stops or wheel chocks prevent unintentional movement of rail cars and tank trucks, and these operations can be shut down at any time using remotely actuated valves.
7 All processes have automated emergency shutdown systems. In addition, Technicians will shut down a process at any time to prevent or mitigate an incident.
7 Material in a leaking vessel can sometimes be transferred to another vessel to reduce the amount of the release. Likewise, a leaking pipe line will be isolated and temporarily patched to reduce the amount of the release. (Equipment is properly re
paired and inspected before being returned to service.)
7 Containment areas will collect liquid materials that have been accidentally released for proper disposal or recovery.
7 Trained and experienced Crew Leaders lead a maintenance force that performs planned and scheduled preventative maintenance on all safety and environmental critical instrumentation and equipment.
7 Qualified engineering personnel assist with plant operation and maintenance. Specialists will be called to the site at any time.
7 Storage tanks and pressure vessels are designed and constructed in accordance with American Society of Mechanical Engineers standards. Inspections and tests are conducted per American Petroleum Institute standards.
7 Process controls, alarms, and pressure relief valves prevent equipment over-pressurization. Processes are designed for total containment if utilities fail.
7 Critical pumps are backed up by in-line spares.
7 Lighting and radio communication systems have battery backup power.
Process areas have water deluge fire protection systems that can be manually or automatically activated. These systems have backup power sources and can operate if electrical power fails.
7 Fire hydrants are located on the perimeter of each process area. Special nozzles can be used to create water curtains or direct high volumes of water to specific areas. In addition, dry chemical fire extinguishers are located throughout each process.
7 Process designers, site planners, and operating teams work together to minimize hazardous chemical inventories.
7 Safety and environmental recommendations are risk ranked and tracked using a Recommendations Management System. This database allows the site to effectively prioritize resources and provide timely follow up.
7 All employees are subject to random drug testing.
In addition, the site has implemented the numerous chemical-specific accident prevention measures, including:
7 Methyl chloride analyzers are located in process areas for early war
ning of accidental releases. Operating Technicians and Safety and Loss Prevention Technicians automatically receive alarms from these analyzers.
7 Methyl chloride reactors have an emergency cooling systems to halt production during an emergency.
7 Emergency hydrogen chloride vent scrubbers are designed into siloxane manufacturing processes.
7 Nitrogen is automatically added to chlorosilane storage tanks to maintain a moisture-free atmosphere.
7 Tantalum, high performance polymers, glass, or acid-resistant brick linings are used for equipment containing hydrochloric acid to provide corrosion resistance.
7 Fire hydrants can be used to establish water curtains to scrub hydrogen chloride and chlorosilane vapors that have been accidentally released.
7 Chlorosilanes are shipped in tank trucks rated for high pressure, exceeding Department of Transportation requirements and reducing overall transportation risk.
7 Tank trucks used to transport a silicone intermediate were redesigned to carry a
10 % larger payload, reducing the number of truck shipments, saving fuel, and reducing overall transportation risk. In addition, built-in overflow protection prevents spillage during loading.
FIVE-YEAR ACCIDENT HISTORY
The site records all incidents, no matter how small. Each incident is investigated to identify root causes and corrective actions. Dow Corning accepts responsibility for its accident history and is committed to continuous improvement. Based on RMP requirements, the site has had five incidents in the previous five years which qualify for reporting:
7 An employee received a drop of hydrochloric acid in his eye while removing his chemical protective goggles in August 1998. His eye was flushed with water, and he received medical treatment. This incident was classified as an OSHA recordable injury, and the employee fully recovered. Corrective actions included improving process area lighting and providing "anti-fog" goggles.
7 An employees neck was sprayed with a mixture
of chlorosilanes during a maintenance activity in September 1997. The mixture was primarily composed of dimethyldichlorosilane. The affected area was flushed with water, and the employee received medical treatment. This incident was classified as an OSHA recordable injury, and the employee fully recovered. Corrective actions included providing awareness training for hospital personnel, hiring an on-site nurse, reviewing safety shower use, and re-evaluating the maintenance activity.
7 An employee was exposed to hydrogen chloride vapor during a process upset in April 1995. Oxygen was administered to the employee following the incident, and two days later he experienced some congestion. The employee received antibiotics from the company doctor and was placed on a temporary work restriction. This incident was classified as an OSHA recordable illness, and the employee fully recovered. Corrective actions included evaluating process design improvements.
7 On two occasions in the past five ye
ars, an informational call was made to a company located on the sites fenceline to report an accidental release with potential off-site consequences. It was unlikely that either release would have affected that company due to the prevailing wind direction. As a precaution, however, that company invoked their emergency procedures and elected to shelter-in-place. That company has 40 people on-site during the day and 30 people at night. No actual off-site consequences and no injuries resulted from either of these accidental releases.
EMERGENCY PLANNING AND RESPONSE PROGRAM
The site maintains an integrated Emergency Planning and Response Program, which consolidates federal, state, and local regulatory requirements. This program provides information to protect the community, on-site personnel, and the environment during emergency situations. The site is fully prepared with procedures, equipment, and trained personnel to respond to any foreseeable emergency.
The site coordinates its pla
n with the Carroll County Emergency Response Plan. The Safety and Loss Prevention Team Leader and a Site Supervisor actively participate on the Carroll County Local Emergency Planning Committee. A mutual aid agreement exists between the site and the county ambulance service.
The site uses an Incident Command System for emergency planning and response activities. All employees receive periodic awareness training, and they participate in either site or county-wide drills. The site conducts quarterly emergency drills. Safety and Loss Prevention Technicians, Operating Technicians, and other employees complete annual HAZMAT and Fire Brigade training. All employees complete hands-on fire extinguisher training as part of their required job-specific training.
The site uses commercially available release modeling software and real-time meteorological data to identify potentially affected areas during an emergency. This information allows the Incident Commander to take proper actions and make
appropriate community notifications.
The site has an Emergency Notification System, tested weekly, to telephone neighbors within a two-mile radius of the site during an emergency. In addition, the site operates a Federal Alert Alarm System, tested daily, to transmit various alarms and messages.
A member of management supports the Incident Commander during emergency response activities to ensure that appropriate notifications are made, to support recovery planning, and to restore operations.
Dow Cornings investment in site emergency response resources includes:
7 A trained Incident Command Team, HAZMAT responders, and Fire Brigade
7 2,500,000 gallon fire water storage and grid distribution system, with 17,000 gallon per minute available delivery. Up to 11,900 gallons per minute can be delivered by diesel-driven pumps which remain operational during a power failure.
7 Two fire trucks
7 HAZMAT response vehicle with equipment for personal protection, rescue, leak suppression, and comm
7 State-certified ambulance
7 Three route trucks
7 A boat
PLANNED CHANGES TO IMPROVE SAFETY
It is a site goal to eliminate accidental releases. The site strives to meet this goal through continuous improvement efforts, such as:
7 Environmental Management System Improvements
7 Reliability Program
7 Environmental Project Construction Improvements
7 Infrastructure Improvements
Specific improvement efforts include:
7 Installing additional remote actuators on temperature shut-off valves
7 Evaluating process pipe lines for thermal expansion potential
7 Updating equipment preventive maintenance schedules
7 Upgrading process control system alarms
7 Source Leak Identification Program