DOW CORNING -- MIDLAND PLANT - Executive Summary |
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EXECUTIVE SUMMARY The Executive Summary provides an overview of the comprehensive Risk Management activities at the Dow Corning Corporation Midland Plant. This summary includes: * Accidental release prevention and emergency response policies, * Company, facility and the regulated substances, * Worst-case and alternative release scenarios, * Accidental Release Prevention Program and chemical-specific prevention steps, * Five-year accident history, * Emergency Planning and Response Program, and * Planned changes to improve safety. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Midland Plant employees operate and maintain the facility in a safe and responsible manner. The Accidental Release Prevention Program and the Emergency Planning and Response Program protect the community, the employees, and the environment. Site- specific safety and environmental standards, and emergency response plans are developed as needed to supplement corporate standards. Corporate Co mmitment Two of Dow Corning's eight Core Values provide a foundation for the protection of the community, the employees, and the environment: "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 commitment to the safe-keeping of the natural environment is founded on our appreciation of it as the basis for the existence of life." Likewise, Dow Corning has developed a Code of Conduct to supplement the Core Values and provide further direction to all employees: "Environmental, Product Stewardship and Social Responsibility "We are committed to the responsible management of chemicals through our support and practice of the principles of Responsible Care(r). "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 a ssure 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, environmental, and health and safety programs." Site Commitment The Management Team at the Midland Plant demonstrates its commitment to the community, the employees, and the environment by publishing the Midland Site Environmental Policy which states: Our commitment to safekeeping of the environment is based on our appreciation of it as the basis for the existence of life. Each employee has the responsibility to ensure that our operations meet or exceed all the applicable government regulations. Midland Site shall provide the tools and training for everyone to conduct their activities consistent with the highest principles of environmental management. We must continue to work toward the elimination of spills, fires, and releases. We must continually reduce our emissions and discharges. We will achieve this first by focusing on source reduction as the preferred approach, followed by internal recovery, recycle, and reuse. Treatment and disposal are employed as a last resort. We will report our progress to our employees, government agencies, our neighbors, and the general public. Corporate and Site Standards Dow Corning's Corporate Safety, Industrial Hygiene, and Loss Prevention Department develops global safety standards for all manufacturing facilities. In particular, SPS-01, "Process Safety Program," requires all sites handling hazardous materials to develop an accident prevention program. Dow Corning's Corporate Environmental Affairs Department has developed a Corporat e Environmental Policy Manual which defines additional requirements. In particular, it 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." Accident Prevention Program Leadership All employees and contractors are involved in the site's Accident Prevention Program. The Process Safety Coordinator ensures that people are aware of their individual responsibilities, that appropriate training is provided, and that the program complies with all applicable regulations and Dow Corning standards. Emergency Planning and Response Program Leadership Many employees are involved in the site's Emergency Planning and Response Program. The Safety and Loss Prevention Team Leader ensures that appropriate training and equipment is provided, and that the program complies with all applicable regulations and Dow corning standards. Individual Performance Objectives All employees are expected to meet safety and environmental objectives as part their normal job requirements, including: * Attending monthly safety meetings to discuss safety-related topics and review findings from incident investigations, * Completing periodic safety training, * Participating on Process Hazard Analysis study teams, and * Completing or participating on miscellaneous safety projects. COMPANY, FACILITY, AND REGULATED SUBSTANCES Dow Corning Corporation 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 Corning's 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 company's products include silicones, related specialty chemicals, semiconductor grade silicon, and specialty health care products. Dow Corning employees are guided by Core Values. The company is a member of the Chemical Manufacturers Association and subscribes to the Responsible Care( Codes of Management Practices. Midland Plant All manufacturing, research, sales and administration activities were initially housed in Dow Corning's first facility, the Midland Plant. Through the years, the Midland Plant has played a pivotal role in Dow Corning's growth from sales of $5 million in 1949 to more than $2 billion in the late-1990's. Today, the Midla nd Plant continues to serve Dow Corning customers as the most diversified manufacturing facility within the company. The mission of the Midland Plant is to: Demonstrate continuous improvement, through team excellence with our customers, community, and employees, by supplying high-quality products and services in a safe, productive, waste-free, and profitable manner. The plant manufactures thousands of high-performance silicone materials for shipment to thousands of customers worldwide. So committed to its customers, the Midland Plant is registered for the International Organization for Standardization (ISO 9002), which meets the most stringent international quality standards. Through the years, Dow Corning has invested millions of dollars annually in the Midland Plant to keep it on the leading edge of silicone technology while exploring innovative ways to improve its environmental performance and developing a worker safety record that is one of the best in all of industry . Approximately 1000 employees work in manufacturing, engineering, or production and maintenance roles. A contractor workforce is used during high periods of activity, such as plant shutdowns or major construction projects. A high level of security is maintained at all times. The site is fully fenced, and photo cells automatically operate lights throughout the facility. Remote cameras are used to monitor all access points. Personnel enter and exit the site using assigned badges. Visitors must sign in and are escorted throughout the site. Vehicle access inside the fence is controlled. All areas maintain radio contact with the Safety and Loss Prevention (S&LP) Department and the Site Supervisor. A core group of emergency responders are always on site. The S&LP Team receive fire, safety shower, and other alarms, and will dispatch immediate assistance as needed. In addition, S&LP receives reports of all accidental spills and releases and will dispatch immediate assistance and/ or notify site personnel and the community as based on the severity of an incident. The Midland Plant fully supports the Chemical Manufacturer's Association Responsible Care(r) program which is committed to recognize and respond to community concerns about chemicals and our operations. Through this support, the plant established a Community Advisory Panel to better develop a relationship with the Midland community. The Midland Plant has received numerous environmental awards. This includes being the only Michigan organization to twice be named a Recycler of the Year by the Michigan Recycling Coalition. The Plant was also the first in mid-Michigan to commit to the Buy Recycled Alliance which pledges our support of buying tens of thousands of dollars annually of recycled products. Regulated Substances The facility manufactures or uses the following RMP regulated substances: Ammonia i-Butylene Dichlorosilane Dimethyldichlorosilane Ethyl Ether Ethylene Ethylenediamine Hy drogen Hydrogen chloride Hydrogen fluoride Methylchloride Methyltrichlorosilane Oleum i-Propylchloride Propylene Trichlorosilane Trimethylchlorosilane WORST-CASE RELEASE SCENARIOS AND ALTERNATIVE RELEASE SCENARIOS The RMP rule requires information about worst-case and alternative release scenarios. The facility uses this information to ensure that emergency response plans address all reasonable process hazards. Computer modeling using TRACE software from SAFER, Inc. was used to determine the potential hazard distances for each scenario. Brief summaries follow, including information about key administrative controls and mitigation measures. Worst-case Release Scenario - Regulated RMP Toxic Chemicals By following the rigid parameters of the regulation, the toxic worst case scenario for Midland Plant is the release of rail car of hydrogen chloride containing 151,450 pounds. The potential exposure distance was determined to be 19.6 miles by using TRACE dispersion modeling so ftware. Weather conditions (established by the regulation) include a wind speed of 1.5 m/s, F-class atmospheric stability and urban topography. Since active mitigation and controls are not permitted for these scenarios, inventory reduction is the major factor for reducing the exposure distance. Within the potential radius of exposure, there is a residential population of approximately 330,000. Public and environmental receptors within this radius include: Schools Residences Hospitals Prisons/Correction facilities Recreation areas Commercial/Industrial areas National/State parks, forests, monuments Wildlife sanctuaries, preserves, refuges Alternative Release Scenarios - Regulated RMP Toxic Chemicals Weather Conditions: The same average weather conditions were used for the following eight toxic release scenarios. The conditions include a wind speed of 4.3 m/s, D-class atmospheric stability and urban topography. Ammonia: By following the guidelines of the regulation, the to xic alternative release scenario for ammonia is the release of 62,770 pounds during an unloading operation. The potential exposure distance was determined to be 0.7 miles by using TRACE dispersion modeling software. Alarms, interlocks, spill containment, water curtains, and emergency response personnel limit the exposure distance for this scenario. Within the potential radius of exposure, there is a residential population of approximately 850. Public and environmental receptors within this radius include commercial/industrial areas. Dimethyldichlorosilane: By following the guidelines of the regulation, the toxic alternative release scenario for dimethyldichlorosilane is the release of 14,650 pounds during an unloading operation. The potential exposure distance was determined to be 0.5 miles by using TRACE dispersion modeling software. Alarms, interlocks, spill containment, water curtains, and emergency response personnel limit the exposure distance for this scenario. With in the potential radius of exposure, there is a residential population of approximately 850. Public and environmental receptors within this radius include commercial/industrial areas. Ethylenediamine: By following the guidelines of the regulation, the toxic alternative release scenario for ethylenediamine is the release of 11,870 pounds during an unloading operation. The potential exposure distance was determined to be 0.01 miles by using TRACE dispersion modeling software. Alarms, interlocks, spill containment, water curtains, and emergency response personnel limit the exposure distance for this scenario. Within the potential radius of exposure, there is no residential population. There are no public nor environmental receptors within this radius. Hydrogen chloride: By following the guidelines of the regulation, the toxic alternative release scenario for hydrogen chloride is the release of 18,370 pounds during an unloading operation. The potential exposure distance wa s determined to be 1.7 miles by using TRACE dispersion modeling software. Alarms, interlocks, spill containment, water curtains, and emergency response personnel limit the exposure distance for this scenario. Within the potential radius of exposure, there is a residential population of approximately 2,500. Public and environmental receptors within this radius include schools, residences, recreational areas and commercial/industrial areas. Methyl chloride: By following the guidelines of the regulation, the toxic alternative release scenario for methyl chloride is the release of 12390 pounds during an unloading operation. The potential exposure distance was determined to be 0.2 miles by using TRACE dispersion modeling software. Alarms, interlocks, spill containment, water curtains, and emergency response personnel limit the exposure distance for this scenario. Within the potential radius of exposure, there is no residential population. There are no public nor environmental receptors within this radius. Methyltrichlorosilane: By following the guidelines of the regulation, the toxic alternative release scenario for methyltrichlorosilane is the release of 14,270 pounds during an unloading operation. The potential exposure distance was determined to be 0.6 miles by using TRACE dispersion modeling software. Alarms, interlocks, spill containment, water curtains, and emergency response personnel limit the exposure distance for this scenario. Within the potential radius of exposure, there is a residential population of approximately 850. Public and environmental receptors within this radius include commercial/industrial areas. Oleum: By following the guidelines of the regulation, the toxic alternative release scenario for oleum is the release of 43,100 pounds during an unloading operation. The potential exposure distance was determined to be 0.1 miles by using TRACE dispersion modeling software. Alarms, interlocks, spill containment, water curtain s, and emergency response personnel limit the exposure distance for this scenario. Within the potential radius of exposure, there is a residential population of approximately 850. There are no public nor environmental receptors within this radius. Trimethylchlorosilane: By following the guidelines of the regulation, the toxic alternative release scenario for trimethylchlorosilane is the release of 13,470 pounds during an unloading operation. The potential exposure distance was determined to be 0.5 miles by using TRACE dispersion modeling software. Alarms, interlocks, spill containment, water curtains, and emergency response personnel limit the exposure distance for this scenario. Within the potential radius of exposure, there is a residential population of approximately 850. Public and environmental receptors within this radius include commercial/industrial areas. Worst-case Release Scenario - Regulated RMP Flammable Chemicals By following the rigid parameters of the regu lation, the flammable worst case scenario for Midland Plant is the release of rail car of ethyl ether containing 118,094 pounds resulting in a vapor cloud explosion. The potential exposure distance was determined to be 0.3 miles by using TRACE dispersion modeling software. Weather conditions (established by the regulation) include a wind speed of 1.5 m/s, F-class atmospheric stability and urban topography. Since active mitigation and controls are not permitted for these scenarios, inventory reduction is the major factor for reducing the exposure distance. Within the potential radius of exposure, there is a residential population of approximately 850. Public and environmental receptors within this radius include commercial/industrial areas. Alternative Release Scenario - Regulated RMP Flammable Chemicals By following the guidelines of the regulation, the flammable alternative release scenario for Midland Plant is the release of 17,185 pounds of ethyl ether during an unlo ading operation resulting in a vapor cloud explosion. The potential exposure distance was determined to be 0.2 miles by using TRACE dispersion modeling software. Average weather conditions were used which include a wind speed of 4.3 m/s, D-class atmospheric stability and urban topography. Alarms, interlocks, spill containment, and emergency response personnel limit the exposure distance for this scenario. Within the potential radius of exposure, there is no residential population. Public and environmental receptors within this radius include commercial/industrial areas. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Accident Prevention The site takes a systematic, proactive approach to prevent accidental chemical releases. With support from all the employees and contractors, the Process Safety Coordinator ensures that the Midland Plant complies with the OSHA "Process Safety Management of Highly Hazardous Chemicals" standard and the EPA " Risk Management Program" rule. The individual elements of the prevention program work together to prevent accidental chemical releases. The site is committed to the standard that these management systems set as the way to do business. Individual accountability and internal audits ensure that the high standards for accident prevention are continuously met. Accident prevention management systems include corporate and site safety standards and practices, an Environmental Manual, an Emergency Manual, a Process Safety Manual, a Mechanical Integrity Manual, corporate and site engineering standards and practices, generally accepted good engineering practices, and industry best practices. The management systems for the Accident Prevention Program include: * Process Safety Information * Process Hazard Analysis * Standard Operating Procedures * Training * Mechanical Integrity * Management of Change * Pre-Startup Safety Review * Compliance Audits * Incident Investigation * Employee Part icipation * Hot Work Permit * Contractors * Trade Secrets * Emergency Planning and Response Examples of how these systems are used at the site include: * Operating teams led by experienced Shift Leaders prevent accidents by monitoring their processes using computer-based process control systems, leak detection systems, remote cameras, routine inspections, and written operating procedures. * All processes have emergency shutdown procedures. Operators are authorized to shut down a process at any time to prevent or mitigate an incident. If a spill or release does occur, however, they attempt to contain it in order to minimize exposure to the community and the environment. * Maintenance employees led by experienced Crew Leaders prevent accidents by performing preventive maintenance and repairs on all safety and environmental critical equipment. The intent is to find and correct problems before they result in a spill or release. * The facility has preventive / predictive maintenan ce programs in place for chemical transfer lines, rotating equipment (pumps, fans, and compressors), pressure vessels, and relief valves in hazardous chemical service. * The site is staffed with qualified engineering personnel to assist with troubleshooting, project work, maintenance, reliability, and operation of the plant. A core group of specialists are always on call to report to the plant if needed. * The site has a strict management of change program, which covers all processes. * The site uses the HAZOP technique for Process Hazard Analyses. Recommendations are ranked according to risk level and managed to resolution using an electronic database. Chemical-Specific Accident Prevention As part of the facility's accident prevention efforts, we have implemented the following chemical-specific prevention steps: * Chlorosilanes react with water to form hydrogen chloride; therefore, chlorosilane processes use nitrogen to keep a positive pressure on the system * Qualified per sonnel design, fabricate and install our equipment to ensure that it meets the specifications for temperature, pressure and harsh chemical demands unique for each chemical. * Methyl chloride analyzers are located in process areas for early warning of accidental releases. Operators automatically receive alarms from these analyzers. * Nitrogen is automatically added to chlorosilane storage tanks to maintain a moisture- free atmosphere. * Tantalum, high performance polymers, glass, or acid-resistant brick linings are used for equipment containing hydrochloric acid. * Fire hydrants can be used to establish water curtains to scrub hydrogen chloride and chlorosilane vapors that have been accidentally released. * Chlorosilanes are shipped in tank trucks rated for high pressure, exceeding Department Of Transportation requirements and reducing overall transportation risk. FIVE-YEAR ACCIDENT HISTORY The site maintains records for all injuries, fires, and releases, no matter how small. Based on the requirements of the RMP regulation, the Midland Plant has four incidents which qualify for reporting: * During a maintenance operation in February 1998, a highline was inadvertently "bumped" with a grinding wheel which resulted in a spill & evaporative release of trichlorosilane. There were no injuries, but approximately 50 nearby residents were advised to shelter in place for 30 minutes. Corrective actions have been implemented which include protective sheaths around adjacent piping when working with grinding wheels in highlines. * In August 1997, the Midland Plant spilled approximately 49,000 pounds of trichlorosilane through a leak in a overhead pipeline. Upon the reaction of this material with moisture, we estimated that up to 5,600 pounds of hydrogen chloride left our site. Approximately 1000 residents were advised to shelter in place for 4 hours. Two residents (with pre-existing respiratory ailments) reported to the hospital for medical treatment. Nearby foliage was temporarily damaged but has since recovered. Approximately $20,000 was spent to clean, restore or replace personal property in our community. Corrective actions include an enhanced pipeline mechanical integrity program, we established procedures to shut down highlines within the plant and we shared in the funding for warning sirens to cover a four-mile radius around the plant. * An employee was exposed to ethylenediamine vapor during a maintenance operation in July 1997. The employee received treatment for chemical exposure. This incident was classified as an OSHA recordable, and the employee recovered fully. Corrective actions included a review of the SOP and refresher training to insist on the adherence to the lock- out/tag-out and safe work permit requirements. * In June of 1996, a pipefitter was replacing a gasket and was exposed to hydrogen chloride vapor. The exposed employee left work for the remainder of the day, therefore the incident was c lassified as an OSHA recordable. The employee has recovered fully. Corrective actions included refresher training to insist on the adherence to the lock- out/tag-out and safe work permit requirements. Throughout our fifty-five year history, we have not had an off-site disabling injury resulting from a chemical release from one of our processes. We investigate incidents to pursue an accident's root cause to help eliminate future releases. We accept the responsibility for our accident history "report card" and are committed to continuously improving our performance. EMERGENCY PLANNING AND RESPONSE PROGRAM Midland Plant maintains an integrated Emergency Response Plan, which consolidates all of the federal, state, and local regulatory requirements for Emergency Planning and Response. The program provides the essential information for effectively protecting the community, the employees, and the environment during emergency situations. The site coordinates it s plan with the Midland County Emergency Response Plan. The site Safety and Loss Prevention Manager is an active member of the Midland County Local Emergency Planning Committee. Midland Plant employees regularly prepare and train for response to a site emergency. Community emergency responders participate with our employees on a regularly scheduled basis to train for emergencies on our site. The Emergency Planning and Response management system is the Emergency Manual. The plant has an Emergency Notification System (tested weekly) to alert employees in the event of an emergency. In addition, the site provides a portion of the funding for a community emergency siren warning system to ensure coverage within a four mile radius of the plant. As part of a voluntary settlement of an enforcement action taken by the Michigan Department of Environmental Quality, Midland Plant funds a toll-free emergency phone line (1-888-TELL-MORE) for community residents. The site uses an Incide nt Command System (ICS) for emergency planning and response operations. All employees receive periodic training to provide awareness of our Emergency Response Communication Protocol (ERCP). Safety and Loss Prevention Officers, Operators and other employees complete annual HAZMAT training. All employees on site participate in hands-on fire extinguisher training. The site uses commercial software and real-time meteorological data to predict potentially affected zones resulting from an accidental release. This allows the site to take the proper actions and make the proper community notifications. The investment in site emergency response resources is substantial. Fixed resources include a 1.5-million gallon (17,000 GPM) fire water supply and grid distribution system, as well as active and passive fire protection systems. Mobile resources include the Incident Command Team, HAZMAT responders, the fire brigade, two fire trucks, a HAZMAT response vehicle, an ambulance, three ro ute trucks, a boat, and local mutual aid agreements. The site is fully prepared with procedures, equipment, and trained personnel to respond to any emergency that could occur. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and / or better respond to accidental chemical releases: * The completion of a Hydrogen Chloride recovery process will continue to reduce the on site inventory of hydrogen chloride. * A fenceline facility developed through a partnership with a supplier will significantly reduce inventories of three RMP chemicals by providing "just in time" pipeline supply. * The introduction and startup of a Recommendation Management System (RMS) is being used to risk rank recommendations to prioritize our resources for addressing recommendations. We feel this system will reduce incidents (injuries, fires, spills and releases) by providing timely corrective action through a risk based analysis. |