DUPONT JAMES RIVER PLANT - Executive Summary
Accidental Release Prevention and Response Policies |
DuPont's James River Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to control and contain the release.
Description of the Stationary Source and Regulated Substances
The James River Plant manufactures and processes specialty chemicals in Chesterfield County, Virginia. Raw material, intermediate and process storage tanks are in use at the site.
The James River Plant was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity established by the U.S. EPA. Based on process knowledge, DuPont identified the regu
lated substances and quantities kept on site. The facility uses oleum, which is the only regulated substances in the process.
Based on worst-case analyses, the distances to endpoints [i.e. Emergency Response Planning Guideline Level 2 (ERPG-2) developed for each substance by the American Industrial Hygiene Association] do not exceed the distances to public receptors (i.e., off-site residences, institutions, industrial and commercial office buildings, parks, or recreational areas inhabited or occupied by the public). In addition, the James River facility has had no accidents with off-site impact over the last five years and has coordinated with the local emergency responders. Therefore, the sulfuric acid process is classified as Program 1 under the Accidental Release Prevention (ARP) Program.
James River is subject to Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) and is classified under a listed SIC Code 2819, and is providing the PSM informati
on in this executive summary, since these practices are already in place at the facility.
Off-Site Consequence Analysis Results
The endpoint for the worst-case release of a flammable substance is 1 psi overpressure (i.e. 15.7 psia) for vapor cloud explosions. DuPont James River Plant does not store any flammable substances listed in the rule in the threshold quantities required by the regulation; therefore, DuPont does not have a worst-case scenario for flammable substances.
Endpoints for toxic substances are based on the ERPG-2. Toxic endpoints are listed in Appendix A to 40 CFR Part 68 (Table of Toxic Endpoints). Oleum is the only regulated toxic substance at the James River Plant.
For the 20% oleum storage vessel, passive mitigation exists and was considered in calculating air emissions. The product from the oleum storage tank will be kept in a containment area which will contain the entire contents of the tank. Ad
ministrative controls are also in place which allow for filling to 90% of the tank capacity. High level alarms are also in place to ensure this control.
The distance to the toxic endpoint resulting from the instantaneous release of the entire contents of the oleum tank remains on-site and does not effect any public receptors. The distance to the toxic endpoint was calculated based on the U.S. EPA lookup tables contained in the Offsite Consequence Analysis (OCA) Guidance Document.
Alternative release scenarios are those that are more likely to occur than the worst-case release scenario. Alternative release scenarios for toxic substances should be those that lead to concentrations above the endpoint beyond the facility's fenceline. Since the James River facility is in Program 1 of the ARP, no alternative release scenarios are provided.
General Accidental Release Prevention Program
Even though the James River facility is considered a Program 1 facility, the following is a summary of the accident prevention program in place at DuPont's James River Plant. Because the process at the plant is subject to the OSHA's PSM standard, the following summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.
DuPont requires employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the J
ames River Plant's accident prevention program. One way that employees can be involved in the accident prevention program is our Safety, Health, and Environmental (SHE) Committee. In addition, James River has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams have members from all areas of the plant, including operations, maintenance, engineering, and plant management.
Process Safety Information
The James River Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information.
ormation, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For the sulfuric acid process area, James River has documented safety-related limits for specific process parameters (e.g., temperature level, composition) as part of the Operating Procedures. The plant ensures that the process is maintained within these limits using state-of-the-art process controls and monitoring instruments, emergency relief systems, redundant power supply and safety systems, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).
The plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construc
tion, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.
Process Hazard Analysis (PHA)
James River has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure the adequate controls are in place to manage these hazards.
James River uses various techniques including Fault Tree Analysis, Checklists, and the Hazard And Operability (HAZOP) Analysis to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of peop
le who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.
The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, James River period
ically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.
James River maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary
to reflect changes made through the management of change process.
This information is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.
To complement the written procedures for process operations, James River has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at a
n acceptable level. This refresher training is conducted at least every 3 years. A "Job Cycle Check" program has also been implemented. This involves a yearly review of specific operating tasks by all operating personnel assigned to those tasks. All of this training is documented for each operator.
James River uses contractors to supplement its workforce. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4)
safe work practices prior to their beginning work. In addition, James River evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor and audit contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Reviews (PSSRs)
James River conducts a PSSR for any facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring
verification that accident prevention program requirements are properly implemented.
James River has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process.
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures help ensure that work is performed in
a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended and to VERIFY that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.
Another integral part of the mechanical integrity program is quality assurance. James River incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.
Safe Work Practices
James River has long-standing safe work practices in place to help ensure worker and process safety. Examples of these i
nclude (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space, and (6) a pre-start-up safety review on each unit. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
Management of Change
James River has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and au
thorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.
James River will promptly investigate all incidents that result in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for
resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidation.
To help ensure that the accident prevention program is functioning properly, James River periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to plant management for resolution. Corrective actions taken in response to the a
udit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
Chemical-Specific Prevention Steps
The process at James River has hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility.
Universal Prevention Activities
The accident prevention program summarized previously is applied to all RMP-covered processes at James River. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.
Specialized Safety Features
James River has safety features on units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the cove
( Release Containment/Control
7 Automatic shut-off devices and relief valves
7 Curbing or diking to contain liquid releases
7 Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)
( Administrative controls to minimize toxic chemical inventories.
( Release Mitigation
7 Trained emergency response personnel
7 Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus)
7 Pressure monitoring of vessels and pipes
7 Audible warning alarms
Five-Year Accident History
DuPont James River Plant has not had any accidental releases during the past five years which meet the criteria for an accidental release per 40 CFR 68.42.
Emergency Response Program Information
James River maintains a written incident response plan, which is in place to protect worker and public safety as well as the environment during an emergency. The plan consists of procedures for responding
to a release of a regulated substance. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures every two years, as necessary, to perform their specific emergency response duties. The incident response plan is updated when necessary based on modifications made to plant processes.
The overall emergency response program for James River is coordinated with the Chesterfield Fire Department. This coordination includes periodic meetings of plant emergency response personn
el and the Chesterfield Fire Chief to discuss needs and concerns in the event of an incident at the plant. The plant has around-the-clock communications capability with the Chesterfield Fire Department who have the ability to communicate to all state, federal and county agencies as to needed equipment (i.e., firefighting equipment, manpower, ambulances, hospitals, law enforcement, and HAZMAT operations). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic meetings with the Chesterfield Fire Chief, the James River Plant conducts periodic emergency drills that involve the Chesterfield Fire Department and emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant.
Planned Changes to Improve Safety
James River has several elements of the management system of the accident p
revention program in place to improve safety throughout the facility. These elements are part of an overall ongoing safety improvement process. The following elements of the management system are present to improve safety.
Process Hazard Analysis
Management of Change