The Procter & Gamble Mfg Company-Alexandria Plant - Executive Summary |
|
PREVENTION IS OUR FIRST PRIORITY - POLICY COMMITMENT TO SAFETY AND ENVIRONMENTAL STEWARDSHIP Procter & Gamble (P&G) has a long-standing commitment to maintaining a safe work environment for our employees and minimizing the impact of our operations on the environment. Our safety and environmental programs are managed by highly skilled employees, and are actively supported by the participation of all employees and all management, and a strong corporate staff. The goal of both the safety and environmental programs is prevention. Safety teams which focus on training and special projects have been formed in every department across this site. Although P&G's safety record is already among the best in the business, we are constantly striving for improvement. P&G is very committed to the safety and protection of the local residents. P&G employees are active members of several of the local fire departments, response groups and other community, including Rotary and Keep CENLA Beautiful. P&G has also supported the community in areas such as supplying mitigation materials to aid the city with a transportation incident. P&G is also very committed to the safety and protection of the natural environment. P&G Alexandria site employees have participated in the local Earth Day celebrations, have provided environmental training in schools, and is active in the Partners in Education program with Northwood High School. SOURCE + SUBSTANCES: PREVENTION, CONTROLS + MITIGATION The P&G Alexandria site manufactures laundry detergent. Oleum is one of the key raw materials used to make the detergent. Oleum is delivered to the site by specially designed railcars, and is unloaded into one of two storage tanks. While not required by any regulation, our storage tanks made of extra-thick stainless steel and designed to meet Pressure Vessel code details. Additionally, they are located in a diked area and enclosed in a metal building. The tanks are routinely visually inspected and the metal walls are tested for integrity. The unloading area is also spill protected. The storage and unloading areas are monitored by continuous video cameras placed in critical areas. The storage tanks are heated to the minimum level in order to keep the oleum in a liquid state for use in our process. Slight wisps or vapors which may occur when opening the railcar for unloading and during maintenance are collected in a mist vacuum and scrubber system. Oleum is completely consumed in the reactions in the processes. RELEASE SCENARIOS: Minimizing the potential for accidental releases A "Worst Case Release" is defined by EPA as an instantaneous release of the single largest vessel (one storage tank), outdoors, during a time of light winds and stable weather conditions. An instantaneous release of this kind could be caused by, for example, an earthquake or by an airplane hitting the tank. The worst case release assumes that no emergency response would occur, even though both site p ersonnel and the local Haz Mat team are trained to respond to this type of spill. The spilled liquid contents of an entire storage tank would be confined to an existing diked area. The Alternative Release Scenario is defined by the EPA as a 15 minute release from a leaking unloading line at more normal weather conditions. If necessary, the foam suppression systems and/or shutting valves to shut down the operation could be activated within 15 minutes. The facility has also modeled its Alternative Release Scenario. This scenario can also be located in the RMPlan. SAFETY, RELEASE PREVENTION, AND EMERGENCY RESPONSE The first line of defense at our plant is accident prevention. A detailed hazard study was conducted to identify potential points from which oleum may be spilled or leaked from the process. These points have received special consideration during the process design, the training of operators and maintenance personnel, and in the development of our accident prevention a nd response systems. The studies are updated routinely by a team of specially trained employees and engineers. Training, maintenance, controls, operating practices, and purchasing requirements are updated based on the results of these hazard studies. The entire oleum system has numerous and redundant process controls, detection and alarm systems, and an emergency shut-down system. When operating, highly skilled operators monitor the process from the control rooms equipped with cameras and computers that monitor important data on the liquid levels in the tanks, the temperature and pressure of the tank contents, and the tank's volume. Oleum is only unloaded into a tank when there is enough space to allow unloading all the contents of the railcar. This procedure of hookup-unload- disconnect only once per railcar minimizes the risk of accidental spills. In the event of an accident, the site has systems to react to the spill or leak quickly. Spills or leaks of oleum can be quickly com municated by personnel on the scene from phones located in the control rooms. The Police and Fire departments have procedures to manage communications and instructions to the public by means of TV and radio broadcasts, and by direct communications in the streets of affected neighborhoods. HISTORY OF SAFE OPERATIONS The P&G Alexandria site has an excellent history of oleum system safety. We have had zero RMP 68 incidents within the past five years. EMERGENCY RESPONSE PROGRAM Technicians handling oleum have been qualified in all of our standard operating procedures. The operating procedures include both routine and non-routine operations. Thirty employees are trained as part of an onsite Team to handle emergencies; with each shift having trained members. All employees participate in annual Emergency Response drills. The results of both hazard assessments and the emergency response drills are communicated to the operating and unloading teams. An Emergency Response Plan has be en developed and coordinated with the LEPC, including the fire department, hospitals, and police. The drills allow the opportunity to train new responders, to refresh the skills of the experienced responders, and to improve the communications and response systems. Equipment that may be used to respond during a real emergency, such as a foam system, may be activated during these drills. The local Fire department(s) and police agencies are toured through the site on a regular basis to reinforce their awareness of what is on site and where critical materials are stored. |