FMC Corporation - Nitro, WV plant - Executive Summary |
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>>Accidental Release Prevention and Emergency Response Policies The FMC Nitro Plant is committed to protecting the environment and the health and safety of its employees, their families and the public. We are dedicated to being a leading company in health, safety and environmental issues by continuously improving our performance to benefit employees, customers, neighbors and shareholders. It is our policy: * To conduct business in a manner that protects public and occupational health, the environment and employees safety * To comply with all laws and regulations, and to go beyond compliance as appropriate to protect employees, the public and the environment * To manage our health, safety and environment risk intelligently, so as to protect and enhance our economic future * To make health, safety and environment considerations a leading priority in manufacturing existing products and planning for new products, facilities and processes * To cooperate with other parties to resolve issue s created by past handling of wastes * To support objective scientific research into health, safety and environmental issues * To encourage constructive communication with our key stockholders on managing health, safety and environmental issues * To involve employees in assuming responsibility for understanding and complying with the content and spirit of FMC's worldwide policy. >>Facility Description The Nitro plant is a manufacturing facility that produces a range of phosphorus-based specialty chemicals. The Nitro plant is ISO-9002 registered and is ranked Class 'A' for MRPII (Planning and Control) by Oliver Wight. Plant Products The chemicals produced are phosphorus chlorides and phosphate esters. The phosphorus chlorides are intermediates, which are used to manufacture, among many others, products in the fields of pharmaceuticals, cosmetics, agricultural products and water treatment. In addition to some particular physical properties that are used in the floor finishing busi ness, phosphate esters are used extensively in areas of fire risk due to their outstanding flame retardant capabilities. They are incorporated into a variety of polymers which are used to make construction components, TV casings, flooring, computer housing and the like. Phosphate esters are also to be found in fluid and hydraulic systems where their flame retardant properties provide safe systems in high temperature and high-risk applications such as steel mills, ships and aircraft. Regulated Chemicals Five chemicals on site are regulated under RMP. Chlorine, phosphorus trichloride and phosphorus oxychloride are classed by EPA as RMP toxic substances. Propylene and 2-methyl propene are classed by EPA as RMP flammable substances. Regulated Processes * Chlorine and phosphorus are reacted to form phosphorus trichloride, which is purified by distillation. This is Process ID 1, Phosphorus Trichloride, and is Program Level 3. * Phosphorus trichloride is oxidized to form phosphorus o xychloride. This is Process ID 2, Phosphorus Oxychloride, and is Program Level 3. * Propylene and 2-methyl propene are reacted with phenol to make an alkylated phenol (which is then used as a raw material in the manufacture of phosphate esters). This is Process ID 3, Alkylate, and is Program Level 3. >>Release Scenarios Worst Case Scenarios * The worst case scenario for an RMP toxic chemical involves a full tank car of phosphorus trichloride and assumes that the entire contents of the car, 170,000 pounds, is released within 10 minutes. This worst case scenario also assumes that none of the available mitigation measures are used. Modeling was done using EPA's RMP*Comp software, which estimated the endpoint of the plume to be 15 miles. * The worst case scenario for an RMP flammable chemical involves a full tank car of propylene and assumes that the entire contents of the car, 120,000 pounds, is released within 10 minutes. This worst case scenario also assumes that none of the ava ilable mitigation measures are used. Modeling was done using EPA's RMP*Comp software, which estimated the endpoint distance for the vapor cloud explosion to be 0.4 miles. Alternative Case Scenarios * Note that for the two flammable RMP chemicals, propylene and 2-methylpropene, there were no credible alternative case scenarios that extended offsite. However, since the RMP*Submit software's completeness check routine requires that there must be an entry in Section 5. Flammables: Alternative Release, this scenario is included, even though it does not have an offsite impact. A piping leak from a flange gasket releases 90 pounds of propylene during the five-minute release period. Modeling using EPA's RMP*Comp software estimated the endpoint distance for the vapor cloud explosion to be 0.02 miles. * For phosphorus trichloride, the alternative release scenario assumes that a piping leak occurs during loading when a flange gasket fails. Although a person continually monitors the loadin g, a period of five minutes is allowed to identify the problem and to operate the switches that remotely shut off the pump and close the block valves, thereby stopping the release at 750 pounds. This scenario assumes that the leak occurs at a point where there is no dike or other containment and that that none of the other available mitigation measures are used to stop or suppress the release or to clean up the spill. Modeling was done using EPA's RMP*Comp software, which estimated the endpoint of the plume to be 0.2 miles. * The alternative release scenario for phosphorus oxychloride is essentially the same as for phosphorus trichloride, and also assumes that the leak occurs where there is no dike or other containment and that none of the other available mitigation measures are used to stop or suppress the release or to clean up the spill. Modeling was done using EPA's RMP*Comp software, which estimated the endpoint of the plume to be 0.3 miles. * The alternative release scenar io for chlorine assumes a piping leak on top of a rail car just before the automatic block valve that the plant installs on top of each rail car as part of the hookup. In this scenario, the leak can't be stopped quickly by remotely operated valves and the assumed leak rate is too low to activate the car's excess flow valve (internal shutoff). A period of twenty minutes is allowed for plant personnel to don the appropriate personal protective equipment and to set up the proper incident command, communication and other activities required to safely go on top of the car and stop the leak. A total of 3020 pounds of chlorine would be released during the twenty-minute period. Modeling was done using EPA's RMP*Comp software, which estimated the endpoint of the plume to be 0.2 miles. >>The General Accidental Release Prevention Program and Chemical-specific Prevention Steps The Nitro plant's commitment to the Chemical Manufacturers Association's Responsible Care initiative and its applic ation to our business by the plant's Responsible Care Steering Committee by its very nature causes compliance with certain regulatory requirements covered under OSHA PSM, EPA RMP, etc. Areas such as Employee Involvement, Management of Change, Safety Reviews, Mechanical Integrity and Emergency Response as well as others are all dealt with in the Nitro plant policies, procedures and programs. These policies, programs and procedures are in place for all affected processes in the plant including the specific chemicals regulated under RMP. Safety, prevention and emergency response steps are also in place to further reduce the likelihood of any effect on the community in the event of a release. These prevention systems for the specific processes are described more fully in Section 7 of this document. >>Five Year Accident History In the last five years, there was one accidental release reportable under the RMP guidelines. The chemical released from the site was not itself an RMP chem ical at the site, but the offsite release did result from an RMP chemical in an onsite RMP process. Phosphorus trichloride was released into a dike and was contained there. However, intermittent rain, which was occurring at the time, reacted with the liquid phosphorus trichloride and generated hydrogen chloride, some of which then vaporized and left the site. The maximum quantity of hydrogen chloride that theoretically could have been generated from the phosphorus trichloride would have been 8000 pounds but the actual release from the site was much smaller because the majority of the phosphorus trichloride and hydrogen chloride were retained and/or neutralized onsite. The actual amount of hydrogen chloride released from the site was calculated to be 1470 pounds. A precautionary shelter-in-place was called but was lifted when air monitoring tests surrounding the plant were completed. FMC does not know the exact number of persons who sheltered-in-place. No injuries or damage eit her on or off site were reported to FMC at the time. Later, litigation was brought regarding the incident and is still in progress. >>The Emergency Response Program Nitro plant management, through the Responsible Care Steering Committee, recognize that preparedness and planning for emergencies are essential parts of our operation and are equally important as meeting our production schedules and other responsibilities. In dealing with incidents and accidents the following principles will apply: * Minor incidents will be dealt with by the on-site emergency response team. * Significant incidents will be contained by the on-site team until local area emergency service arrive at the scene. The objectives of this program are: * Prevention of injury and loss of life of our employees and people in neighboring plants and the surrounding community. * Prevention and minimization of environmental impact of releases. * Minimization of property damage. * Release of accurate information to the public. * Cooperation with local emergency organizations. * Provision for safe resumption of operations. The following program elements are achieved through the Nitro plant's involvement with the city of Nitro Fire and Police Departments, the plant's participation in the Kanawha-Putnam Emergency Planning Committee (KPEPC), and other activities: * Coordination with local emergency responders and also with other chemical plants is insured through monthly meetings with both the KPEPC and the Nitro Community Advisory Forum. * Emergency responder training for plant personnel is received through both in-house and off-site training programs. * An active Drill Planning committee at the Nitro plant plans and executes drills for our emergency responders. Some drills are held with plant responders only and others with external involvement from fire, ambulance, local hospitals, etc. * Public notification and alert systems include the KPEPC, county area sirens, local television and radio emergen cy broadcast and warning systems and telephone ring-down systems. >>Planned Changes to Improve Safety The Nitro Plant is committed to the Chemical Manufacturers Association's Responsible Care Initiative. Continuously improving our performance in health, safety, and environmental issues provides benefit to employees, customers, neighbors and shareholders. We review equipment and procedures to stay current with both technology and regulations. Production involves both people and equipment: emphasis is currently being placed on a behavior-based safety approach to raise employee awareness and involvement. |