Great Lakes Chemical, Central Plant - Executive Summary
Risk Management Plan Executive Summary for The Great Lakes Chemical El Dorado Plant El Dorado Arkansas |
1. Accidental Release Prevention and Emergency Response Policies
We at Great Lakes Chemical, El Dorado Plant are strongly committed to employee, public and environmental safety. This commitment is demonstrated in a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, our highly trained emergency response personnel are on hand to control and mitigate the effects of the release. We also coordinate with Union County LEPC which provides additional emergency response expertise.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass organic a
nd inorganic chemical synthesis. We have 5 regulated substances present at our facility. These substances include ammonia, bromine, chlorine, phosgene [carbonic dichloride], and sulfur dioxide (anhydrous). The regulated substances at our facility are involved in several uses. Ammonia is used for acid adjustment and neutralization. Bromine is used for chemical synthesis. Chlorine is used for bromine replacement. Phosgene [Carbonic dichloride] is used for chemical synthesis. Sulfur dioxide (anhydrous) is used for bromine recovery and scavenging.
The maximum inventory of bromine at our facility is 2,669,666 lb. while chlorine, ammonia, sulfur dioxide (anhydrous) and phosgene [Carbonic dichloride] are present at our facility in quantities of 360,000 lb., 162,938 lb., 6,000 lb. and 4,000 lb. respectively.
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each repor
To evaluate the worst case scenarios, we have used the look-up tables and equations provided by the EPA in the RMP Off-site Consequence Analysis Guidance as well as Equations from Appendix D of the EPA's Off-site Consequence Analysis Guidance. For alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the RMP Off-site Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from the Bromine Refining process. The scenario involves the release of two tank cars, 360,000 lb., of chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.
One alternative release scenario will be submitted for each toxic substance present in Prog
ram 3 processes.
The alternative release scenario for ammonia involves a release from a pipe leak on the ammonia storage tanks in the Bromine Refining process. The scenario involves the release of 50 lb. of ammonia in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of ammonia is 317 feet (0.06 mile).
The alternative release scenario for bromine involves a release from a pipe leak on the bromine storage tanks in the Bromine Refining process. The scenario involves the release of 10 lb. of bromine. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. Passive mitigation controls such as dikes are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0065 mg/L of bromine is 580 feet (0.11 miles).
tive release scenario for chlorine involves a release from a pipe leak at the rail car unloading area in the Bromine Refining process. The scenario involves the release of 500 lb. of chlorine in a gaseous form over 2 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of chlorine is 1.0 mile.
The alternative release scenario for phosgene [carbonic dichloride] involves a release from a pipe leak on the phosgene cylinders in the TCO Unit process. The scenario involves the release of 600 lb. of phosgene [carbonic dichloride] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.00081 mg/L of phosgene [Carbonic dichloride] is 3.7 miles.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.
This facility was designed and constructed in accordance with State of Arkansas Building Code. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Great Lakes Chemical, El Dorado Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is "what if" checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are reval
idated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting activities within our covered processes, Great Lakes Chemical, El Dorado Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
Great Lakes Chemical, El Dorado Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed.
Great Lakes Chemical, El Dorado Plant carries out
highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at Great Lakes Chemical, El Dorado Plant to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are made aware of and trained (when required) to deal with the modification.
Pre-start up safety revie
ws related to new processes and to modifications in established processes are conducted as a regular practice at Great Lakes Chemical, El Dorado Plant. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Great Lakes Chemical, El Dorado Plant conducts audits on a regular basis to determine whether the provisions established in the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and timely manner.
Great Lakes Chemical, El Dorado Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent
the release from reoccurring. All reports are retained for a minimum of 5 years.
Great Lakes Chemical, El Dorado Plant truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Great Lakes Chemical, El Dorado Plant has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of al
l the procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-year Accident History
Great Lakes Chemical, El Dorado Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, we have had no RMP reportable accidental releases during this period.
6. Emergency Response Plan
Great Lakes Chemical, El Dorado Plant has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. Additionally, annual drills are performed and critiqued.
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any p
ertinent changes within our processes that would require a modified emergency response.
Great Lakes Chemical co-ordinates this emergency plan with the Union County, Arkansas Local Emergency Planning Committee (LEPC). This coordination includes the computer based telephone emergency notification/calling system (Dialogic Communicator) operated by the 9-1-1 center. The system can be used to both notify and advise the public and to call up emergency responders. LEPC emergency plans include the community protection procedures known as "Shelter-In-Place."
7. Planned Changes to Improve Safety
The Great Lakes Chemical El Dorado Plant plans to continuously improve and update operating procedures, replace or maintain equipment to original specifications or design codes and develop and implement safety improvement capital projects. These are some of the major steps we want to take to improve safety at our facility.
8. Certification Statement
The undersigned certifies that to the best of
my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete.
Name: Scott Kempin
Title: Operation Manager