Elf Atochem North America, Inc. - Calvert City, KY - Executive Summary |
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EXECUTIVE SUMMARY Introduction A Risk Management Program has been implemented at Elf Atochem North America's Calvert City production facility for the reduction of accidental releases of hazardous materials. This Risk Management Plan (RMP) summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Plan summary is organized to correspond with specific EPA RMP definitions and requirements, including: -Introduction; -Elf Atochem policies to protect health, environment, and safety; -Facility identification and regulated substances covered processes; -Hazard Assessment; -Prevention Program; -Five-Year Accident History; -Emergency Response Plan; and -Planned changes to improve safety. Elf Atochem Policies for Health, Environment, and Safety Elf Atochem's HES programs include policies, procedures, standards, and guidance materials designed to fulfill Elf Atochem's commitme nt to health, environment, and safety. These materials include Risk Management Program guidance to help our facilities prevent and/or reduce the risk of accidents. This commitment to health, environment, and safety (HES) starts with the CEO. Senior management routinely dedicates time to a review of HES matters, including safety. This emphasis on safety is carried through to the facility level, where the Plant Manager, the HES Manager, and the Plant Safety Committee regularly review safety performance, take corrective actions, and strive for continuous improvement. The success of Elf Atochem's HES programs is also reflected by a strong commitment to safety by employees and contractors. Facility Identification and Regulated Substances in Covered Processes The Elf Atochem Calvert City facility is located at 4444 Industrial Parkway, Calvert City, Kentucky. The facility manufactures refrigerants by continuous chemical reaction and purification processes and premium plastic resins th rough a combination of continuous (monomer) and batch (polymerization) processes. Certain substances used and produced within the facility are regulated under 40 CFR Part 68, the EPA Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability. These substances include: Hydrogen fluoride (HF) - 1,734,000 lbs; Chlorine - 194,000 lbs; Vinylidene fluoride - 649,000 lbs. HF and chlorine are used as process reactants. Vinylidene fluoride is both a product for off-site sale and a reactant in a polymerization process. Hazard Assessment - Worst Case Scenarios The worst-case scenario for toxic chemicals is a catastrophic failure of one of the HF storage tanks in the AHF Storage and Handling facility. HF is received as a liquid in pressurized rail cars and unloaded into 3 storage tanks, each of which has nominal capacity of 365,000 pounds; this quantity was assumed to be released over 10 minutes in the worst-case scenario. Ha zard assessment modeling shows that, under worst-case weather conditions, the worst-case release for toxic chemicals could produce an HF plume that could travel more than 25 miles before dispersing enough to no longer pose a hazard to the public or environmental receptors. The worst-case scenario for flammable chemicals is a catastrophic failure of the vinylidene fluoride storage tank (230,000 lb capacity) in the Monomer unit. Hazard assessment modeling results in a distance to a 1 psi overpressure of 0.30 mile. The worst case scenario does not result in a direct offsite impact. It should be noted that the worst-case scenarios are extremely unlikely events due to the extensive safeguards in place. This Risk Management Plan includes information on mitigation and prevention measures implemented by Elf Atochem to reduce the risk of this type of event. Worst-Case Release Mitigation Measures The multiple layers of preventive measures make it very unlikely that a significant release w ill occur. In addition, in the unlikely event that a release occurs, Elf Atochem has an array of mitigation measures to reduce any potential impacts. Passive mitigation systems include diking to limit the spread of HF and, consequently, the release impact. Active mitigation systems cannot be considered in modeling worst-case scenario impacts, but the significant investment that Elf Atochem has made in active mitigation measures should effectively reduce the risk associated with an RMP incident. These include: -HF could be pumped from a damaged tank into another storage tank to reduce the amount potentially released. -Diking system is provided with an open drain to a trench with a pumping system that can be manually activated to contain and collect spilled HF. -HF tanks are under continuous observation to detect any problems, including operator visual inspections (4 to 6 times per day), video camera surveillance, and both local and control room indicators for pressure and tank le vel/alarm. -HF detectors are strategically located to provide early warning of any release. -Extensive firewater system in the event of a fire resulting from a vinylidene fluoride release Hazard Assessment - Alternative Release Scenarios One alternative scenario for each regulated toxic substance and for the one regulated flammable substance was also modeled in the hazard assessment. The alternative release scenario for HF is failure of an unloading hose from a rail car, and the HF plume was estimated to go 2.0 miles before dispersing enough to no longer pose a hazard to the public or environmental receptors. The alternative release scenario for chlorine is failure of a relief valve on a one-ton container, and the chlorine plume is estimated to go 0.6 mile before dispersing enough to no longer pose a hazard to the public or environmental receptors. The alternative release scenario for vinylidene fluoride is the loss of the contents of one tube on a tube trailer; the endpoint use d was the lower flammability limit, which resulted in a distance of 0.10 mile. Like the worst case scenario for vinylidene fluoride, the alternative release scenario does not result in a direct offsite impact. These alternative release scenarios are somewhat more likely than the worst-case scenarios, but are still very unlikely events. This Risk Management Plan includes information on mitigation and prevention measures implemented by Elf Atochem to reduce the risk of these types of events. Alternative Release Scenarios: Mitigation Measures While the alternative release scenarios are, by definition, more likely than the worst-case scenario, they are still very unlikely given the facility's prevention program. If a release should occur, Elf Atochem has an array of mitigation measures to reduce any potential impacts. Examples of mitigation measures that would lessen the impacts of the alternative release scenarios are listed below. HF -HF unloading is conducted intermittently a nd under strict supervision. In the event of a leak, the nitrogen system and HF unloading system can be quickly shut down. -Computerized process controls (including remote valves) and emergency shutdown equipment. -Area detectors and 24-hour surveillance. -Secondary containment around storage tanks, designed for minimum surface area. -Emergency scrubbers. -Deluge water available to "knock down" fumes (HF is very soluble in water). Chlorine -Computerized process controls (including remote valves) and emergency shutdown equipment. -Area detectors and 24-hour surveillance. -Secondary containment around storage tanks, designed for minimum surface area. Vinylidene Fluoride -Computerized process controls (including remote valves) and emergency shutdown equipment. -Area detectors and 24-hour surveillance. Accidental Release Prevention Program A prevention program is in place to minimize the risk of hazardous chemical releases in accordance with the Occupational Health and Safety Administ ration (OSHA) Process Safety Management (PSM) standard (29 CFR 1910.119) and the EPA Risk Management Program. This prevention program covers those processes that handle HF, chlorine, and flammable substances (including vinylidene fluoride) above the threshold quantity of either the PSM or RMP rules. The prevention program provides a structured approach to preventing accidents. Some of the specific activities in the prevention program include: -In-depth process hazards analyses are completed every five years by qualified personnel using techniques approved under the OSHA PSM standards; -Written operating procedures (kept up-to-date) are used for training and directing the work of operators, who receive refresher training every three years; -Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety; -A safety work permit system assures that process work is done safely and properly; -A management system is in place to ensure that changes are managed safely; -Critical equipment is inspected on a planned, periodic basis to assure proper operating condition; -Pre-startup reviews are done to insure that conditions for safe operation have been satisfied prior to starting new or modified equipment; -Incidents are investigated and actions are taken as part of a continuous improvement effort; and -Routine audits are conducted to assure that safe practices are being followed. This systematic approach to process safety involves employees and strives for continuing improvements in accident reduction. The training, qualifications, and safety awareness of our operations, maintenance, and emergency response personnel are a key element in reducing and mitigating accidents. General, yet extensive, measures through equipment and piping design and construction are in place that would prevent the developed scenarios for HF, chlorine, and vinylidene fluoride. These measures include: -Storage tanks are pressure vessels which are designed and constructed in accordance with American Society of Mechanical Engineers (ASME) pressure vessel standards using industry-standard materials of construction. Furthermore, design specifications incorporate Zone 3 earthquake standards. -As part of the Mechanical Integrity program, pressure vessels and atmospheric storage tanks are inspected and tested according to the American Petroleum Institute Standard 510 and Standard 653, respectively. -The risk of overfilling is addressed by the high-level and high-high-level alarms. -The risk of over-pressure is addressed by a system of pressure relief valves and a vent header. -Tanks are generally located in areas where no overhead construction is allowed or equipment is located that could fall and impact a tank. -Access to the facility is restricted through security barriers and trained security personnel, thereby minimizing the risk to the tanks of vehicular dama ge or sabotage. -Rail stops (or wheel chocks) to prevent movement of the car. Also, there are certain chemical-specific measures in addition to these general measures: -Daily hose inspections and tests with annual replacement (HF). -Automatic valve in the pump discharge line that closes automatically when the pump shuts down to prevent backflow from the tanks (HF). -Extra heavy-walled piping and vessels (HF). -Materials of construction designed for specific service; i.e., special steel used (HF). -Chlorine Institute membership with subsequent design requirements (chlorine). Five-Year Accident History There have been no releases of any regulated chemical in the past five years that have had an adverse offsite impact on the community or environment or that meet the RMP reporting requirements with respect to injuries. However, there has been one incident (a vapor cloud explosion on 10/4/94) involving vinylidene fluoride that resulted in significant onsite property damage. Elf A tochem realizes that the community may also be interested in smaller releases of regulated chemicals that do not meet EPA criteria for the Five-Year Accident History. We have been diligent in reporting releases of hazardous materials and in internally investigating and correcting the causes of such releases. Emergency Response Plan A written emergency response plan is maintained at the facility. The plan was developed in cooperation with civil authorities (Local Emergency Planning Committee, Sheriff's Department, police, fire, emergency medical, etc.) and was coordinated with the community emergency response plan developed under 42 U.S.C. 11003. The emergency response plan includes procedures for notifying civil authorities and the public in the event of an incident. The plan also includes documentation of proper first-aid and medical treatment necessary to treat accidental human exposures; procedures for the use of emergency response equipment and for its inspection and testing; a description of the training program for all employees in relevant emergency response procedures; and procedures for review and update, as appropriate, of the emergency response plan to reflect changes at the facility, and to ensure that employees are informed of these changes. Planned Changes to Improve Safety Chemical safety has been a part of the working culture at the facility for many years. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts as well as regulatory requirements. |