Great Lakes Chemical, South Plant - Executive Summary |
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Risk Management Plan Executive Summary for The Great Lakes Chemical South Plant El Dorado Arkansas 1. Accidental Release Prevention and Emergency Response Policies We at Great Lakes Chemical, South 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 and inorga nic chemical synthesis. We have 10 regulated substances present at our facility. These substances include ammonia, bromine, chlorine, ethylene [ethene], hydrogen fluoride/hydrofluoric acid [hydrofluoric acid], oleum (fuming sulfuric acid) [sulfuric acid, mixture with sulfur trioxide], propylene oxide [oxirane, methyl-], sulfur dioxide (anhydrous), and sulfur trioxide. 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. Ethylene [Ethene] is used for chemical synthesis. Hydrogen fluoride/hydrofluoric acid [hydrofluoric acid] is used for chemical synthesis. Oleum (fuming sulfuric acid) [sulfuric acid, mixture with sulfur trioxide] is used for chemical synthesis. Propylene oxide [oxirane, methyl-] is used for chemical synthesis. Sulfur dioxide (anhydrous) is used for chemical synthesis. Sulfur trioxide is used for chemical s ynthesis. The maximum inventory of bromine at our facility is 1,371,400 lb. while ammonia, sulfur trioxide, chlorine, hydrogen fluoride/hydrofluoric acid, propylene oxide [oxirane, methyl-], oleum (fuming sulfuric acid) [sulfuric acid, mixture with sulfur trioxide], sulfur dioxide (anhydrous) and ethylene [ethene] are present at our facility in quantities of 471,758 lb., 400,946 lb., 360,000 lb., 278,139 lb., 91,740 lb., 75,000 lb., 71,957 lb. and 17,178 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 reported scenario 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 equ ations 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. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from the ethylene storage tank in the Fluorine Chemical Unit. The scenario involves the release of 17,178 lb. of ethylene [ethene]. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. U nder worst case weather conditions, the maximum distance of 0.21 mile is obtained corresponding to an endpoint of 1 psi over pressure. One alternative release scenario will be submitted for each toxic substance present in Program 3 processes. The alternative release scenario for ammonia involves a release from a pipe leak at the ammonia rail car storage area 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 mile). The alternative release scenario for chlorine involves a release from a pipe leak on the chlorine rail cars 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 hydrogen fluoride/hydrofluoric acid [hydrofluoric acid] involves a release from a pipe leak on the hydrogen fluoride storage tank in the Fluorine Chemical unit process. The scenario involves the release of 20 lb. of hydrogen fluoride/hydrofluoric acid in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of hy drogen fluoride/hydrofluoric acid is 1000 feet (0.19 mile). The alternative release scenario for oleum (fuming sulfuric acid) [sulfuric acid, mixture with sulfur trioxide] involves a release from a pipe leak on the oleum storage in the PHT-4 process. The scenario involves the release of 50 lb. of oleum (fuming sulfuric acid) [sulfuric acid, mixture with sulfur trioxide]. 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 200 minutes. Passive mitigation controls such as enclosures are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.01 mg/L of oleum (fuming sulfuric acid) [sulfuric acid, mixture with sulfur trioxide] is 475 feet (0.09 mile). The alternative release scenario for propylene oxide [oxirane, methyl-] involves a release from a pipe leak on the proplyene oxide storage in the PHT-4 process. The scenario involves the release of 100 lb. of propylene oxide [oxirane, methyl-] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.59 mg/L of propylene oxide [oxirane, methyl-] is <0.06 mile. The alternative release scenario for sulfur dioxide (anhydrous) involves a release from a pipe leak on the sulfuric dioxide tank in the PHT-4 process. The scenario involves the release of 100 lb. of sulfur dioxide (anhydrous) in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of sulfur dioxide (anhydrous) is 2270 feet (0.43 mile). The alternative release scenario for sulfur trioxide involves a release from a pipe leak on the sulfur trioxide storage tank in the PHT-4 process. The scenario involves the release of 100 lb. of sulfur trioxide. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which e vaporation takes place. The entire pool is estimated to have evaporated over 218 minutes. Passive mitigation controls such as enclosures are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.010 mg/L of sulfur trioxide is 475 feet (0.09 mile). The alternative release scenario submitted for Program 3 flammable substances involves a release from a pipe leak on the ethylene storage tank in the Fluorine Chemical unit . The release is assumed to result in a pool fire. The scenario involves the release of 100 lb. of ethylene [ethene] in 10 minutes. The release is also controlled by active mitigation measures that include sprinkler system(s). Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 for 40 seconds is 50 feet (0.01 mile). 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken the necessary st eps 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 Building Codes. 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, South 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 te am of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Great Lakes Chemical, South 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. Training Great Lakes Chemical, South 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 frequentl y as needed. Mechanical Integrity Great Lakes Chemical, South 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, South 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) t o deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Great Lakes Chemical, South 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. Compliance Audits Great Lakes Chemical, South 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. Incident Investigation Great Lakes Chemical, South 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 le ading 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. Employee Participation Great Lakes Chemical, South 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. A Behavior Based Safety observation process is in place to encourage worker participation in safety and work practices. Contractors 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 Che mical, South 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 all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Great Lakes Chemical, South Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no RMP reportable accidental releases during this period. 6. Emergency Response Plan Great Lakes Chemical, South 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 a nd critiqued. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent 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 South 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 p rojects. These are some of the major steps we are taking to improve the safety of 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: Eugene Woodby Signature: Title: Plant Manager Date signed: |