Dow Chemical Midland Michigan Operations - Executive Summary |
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General Executive Summary For The Dow Chemical Company Michigan Operations Site Midland, Michigan 1. Accidental Release Prevention and Emergency Response Policies We at Dow Chemical Michigan Operations are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program 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 at hand to control and mitigate the effects of the release. We are also coordinated with City of Midland Fire Department which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass chemical manufacturing, including agricultural and specialty chemicals and plastics. We have 30 regulated substances and 19 covered processes present at our facility. These substances and their maximum inventory at an individual process are located in Table 1. Table 1: Regulated substances and maximum inventory at an individual process at Midland, Michigan Operations Site. Material Inventory Quantity Acrylonitrile 520,000 lbs. Allyl alcohol 145,000 lbs. Ammonia 105,000 lbs. Bromine 80,000 lbs. 1,3-Butadiene 1,500,000 lbs. Chlorine 175,000 lbs. Chloromethyl methyl ether 110,000 lbs. Dimethylamine 106,000 lbs. Dimethyldichlorosilane 44,000 lbs. Ethyl chloride 270,000 lbs. Ethyl ether 103,000 lbs. Ethylene oxide 785,000 lbs. Hydrogen chloride/Hydrochloric acid 252,000 lbs. Aqueous Hydrochloric acid (37%) 150,000 lbs. Isopropyl chloroformate 46,000 lbs. Isopropylamine 67,000 lbs. Methacrylonitrile 183,100 lbs. Methyl chloride 175,000 lbs Methylamine 78,000 lbs. Oleum 210,00 0 lbs. Phosphorus oxychloride 130,000 lbs Phosphorus trichloride 120,000 lbs Propylene oxide 1,800,000 lbs. Silane 186,000 lbs. Sulfur dioxide 30,000 lbs. Trichlorosilane 175,000 lbs. Trimethylamine 81,000 lbs. Trimethylchlorosilane 30,000 lbs. Vinyl chloride 245,000 lbs. Vinylidene chloride 920,000 lbs. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures. To evaluate the worst case scenarios, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance and PHAST 5.11 computer aided modeling program. For alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as PHAST 5.11 computer aided modeling program. The following paragraphs provide details of the chosen scenarios. Passive mitigation systems where applicable were taken into consideration when modeling each worst and alternate case toxic and flammable scenario. Mitigation systems in place at each covered process are outlined in the program prevention elements section of the remainder of this RMP submittal. Effect populations are described in the data elements portion of this RMP submission. These populations are overstated in relationship to the potential release distance calculated from the individual covered process to the fenceline of Midland Operations. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from a chlorine railcar. The scenario involves the release of 175000 lbs. of Chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of greater than 25 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The toxic endpoint for all toxic substances is the concentration at which individuals maybe potentially exposed for up to one hour without irreversible health effects. This will be consistent for all toxic substances identified in this executive summary. One alternative release scenario is included for each toxic substance for Program 3 processes. All processes at this site are Program 3. The alternative release scenario for Isopropyl chloroformate [Carbonochloridic acid, 1-methylethyl ester] involves a release from an Isopropyl chloroformate storage vessel. The scenario involves the release of 675 lbs. of Isopropyl chloroformate [Carbonochloridic acid, 1-methylethyl ester] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.10 mg/L of Isopropyl chloroformate [Carbonochloridic acid, 1-methylethyl ester] is 0.06 miles. The alternative release scenario for Allyl alcohol [2-Propen-1-ol] involves a release from an Allyl Alcohol s torage vessel. The scenario involves the release of 30,500 lbs. of Allyl alcohol [2-Propen-1-ol] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.036 mg/L of Allyl alcohol [2-Propen-1-ol] is 0.07 miles. The alternative release scenario for Trimethylchlorosilane [Silane, chlorotrimethyl-] involves a release from a waste tank truck. The scenario involves the release of 10,000 lbs. of Trimethylchlorosilane [Silane, chlorotrimethyl-] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.050 mg/L of Trimethylchlorosilane [Silane, chlorotrimethyl-] is 0.1 miles. The alternative release scenario for Propylene oxide [Oxirane, methyl-] involves a release from a Propylene Oxide tank. The scenario involves the release of 15,200 lbs. 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 0.13 miles. The alternative release scenario for Acrylonitrile [2-Propenenitrile] involves a release from Acrylonitrile storage vessel. The scenario involves the release of 28,524 lbs. of Acrylonitrile [2-Propenenitrile] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.076 mg/L of Acrylonitrile [2-Propenenitrile] is 0.18 miles. The alternative release scenario for aqueous Hydrochloric Acid (concentration of 37% or greater) involves a release of 22,410 lbs of aqueous Hydrochloric Acid from a storage vessel. Liquid is assumed to be immediately released to form a pool of height 1 cm within a diked area, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.030 mg/L of aqueous Hydrochloric Acid (concentration of 37% or greater) is 0.2 miles. The alternative release scenario for Methyl chloride [Methane, chloro-] involves a release from a Methyl chloride tank. The scenario involves the release of 16,870 lbs. of Methyl chloride [Methane, chloro-] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.82 mg/L of Methyl chloride [Methane, chloro-] is 0.25 miles. The alternative release scenario for Ethylene oxide [Oxirane] involves a release from an Ethylene Oxide Sphere. The scenario involves the release of 42,390 lbs. of Ethylene oxide [Oxirane] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.090 mg/L of Ethylene oxide [Oxirane] is 0.42 miles. The alternative release scenario for Phosphorus trichloride [Phosphorous trichloride] involves a release from a Phosphorus trichloride tank. The scenario involves the release of 18,657 lbs. of Phosphorus trichloride [Phosphorous trichloride] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.028 mg/L of Phosphorus trichloride [Phosphorous trichloride] is 0.5 miles. The alternative release scenario for Dimethyldichlorosilane [Silane, dichlorodimethyl-] involves a release from a waste tank truck. The scenario involves the release of 5000 lbs. of Dimethyldichlorosilane [Silane, dichlorodimethyl-] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.026 mg/L of Dimethyldichlorosilane [Silane, dichlorodimethyl-] is 0.51 miles. The alternative release scenario for Ammonia involves a release from an Ammonia railcar. The scenario involves the release of 104,804 lbs. 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 0.76 miles. The alternative release scenario for Phosphorus oxychlorid e [Phosphoryl chloride] involves a release from a Phosphorus Oxychloride storage tank. The scenario involves the release of 10,818 lbs. of Phosphorus oxychloride [Phosphoryl chloride] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0030 mg/L of Phosphorus oxychloride [Phosphoryl chloride] is 0.97 miles. The alternative release scenario for Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide] involves a release from an Oleum storage tank. The scenario involves the release of 42,940 lbs. of Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]. Liquid is assumed to be immediately released to form a pool of height 1 cm within a diked area, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.01000 mg/L of Oleum (Fuming Sulfuric acid) [Sulfuric a cid, mixture with sulfur trioxide] is 1.24 miles. The alternative release scenario for Methacrylonitrile [2-Propenenitrile, 2-methyl-] involves a release from a Methacrylonitrile tank. The scenario involves the release of 15,386 lbs. of Methacrylonitrile [2-Propenenitrile, 2-methyl-] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0027 mg/L of Methacrylonitrile [2-Propenenitrile, 2-methyl-] is 1.27 miles. The alternative release scenario for Hydrogen chloride (anhydrous) [Hydrochloric acid] involves a release from an anhydrous Hydrogen chloride storage vessel. The scenario involves the release of 7,829 lbs. of Hydrogen chloride (anhydrous) [Hydrochloric acid] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.030 mg/L of Hydrogen chloride (anhydrous) [Hydrochloric acid] is 1.36 miles. The alternative release scenario for Chloromethyl methyl ether [ Methane, chloromethoxy-] involves a release from a Chloromethyl methyl ether reactor. The scenario involves the release of 37,000 lbs. of Chloromethyl methyl ether [Methane, chloromethoxy-] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0018 mg/L of Chloromethyl methyl ether [Methane, chloromethoxy-] is 1.52 miles. The alternative release scenario for Chlorine involves a release from a Chlorine railcar. The scenario involves the release of 13,790 lbs. of Chlorine in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 1.65 miles. The alternative release scenario for Bromine involves a release from a Bromine tank truck. The scenario involves the release of 40,000 lbs. of Bromine in a gaseous form over 6 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0065 mg/L of Bromine is 2.53 miles. The alternative release scenario for Sulfur dioxide (anhydrous) involves a release from a Sulfur Dioxide tank. The scenario involves the release of 15,000 lbs. of Sulfur dioxide (anhydrous) in a gaseous form 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 0.0078 mg/L of Sulfur dioxide (anhydrous) is 2.57 miles. The worst case release scenario submitted for all Program 3 flammable substances as a class involves a catastrophic release from 1,3-Butadiene Sphere. The scenario involves the release of 1,502,530 lbs. of 1,3-Butadiene. 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. Under worst case weather conditions, the maximum distance of 1.1 miles is obtained corresponding to an endpoint of 1 psi overpressure. Th e alternative release scenario submitted for all Program 3 flammable substances involves a release from a Vinyl Chloride railcar. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 16,150 lbs. of Vinyl chloride [Ethene, chloro-] in 10 minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.06 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all 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 applicable company and governing agency requirements of the time of construction. Modifications to existing structures are done to comply with applicable company standards and governing agency requirements. Ten additional processes at our facility are subject to the OSHA Process Safety Management 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 Dow Chemical Michigan Operations maintains detailed records of safety information that among other things describe the chemical hazards, operating parameters and equipment designs associated with all covered processes. Numerous types of information are available to supplement safety information. Some of these would include, Material Safety Data Sheets for materials used on site, equipment and engineering design specifications and applicable reactive chemicals testing. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. For initial screening and risk evaluation the Dow Chemical Fi re and Explosion Index, The Dow Chemical, Chemical Exposure Index and a Reactive Chemical and Process Hazard Analysis are conducted. These listed methodologies are supplemented when needed with analyses that may include some of the following: What if Analysis, Hazard and Operability Study (HAZOP), Failure Mode and Effects Analysis (FMEA), and Fault Tree Analysis. A team of qualified personnel undertakes the studies with expertise in engineering and process operations. 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, Dow Chemical Michigan Operations 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 accessibl e to operators involved in the processes. Training Dow Chemical Michigan Operations 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. Mechanical Integrity Dow Chemical Michigan Operations carries out 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 training in maintenance practices. Furthermore, these personnel receive specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written proc edures are in place at Dow Chemical Michigan Operations 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 promptly made aware of and receive training to 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 Dow Chemical Michigan Operations. 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 Dow Chemical Michigan Operations conducts audits on a regular basis to determine whether the provisions set out under the RMP rule and other applicable regulatory requirements are being followed and are implemented. Audits are conducted using an establish sched ule for the site. Corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Dow Chemical Michigan Operations promptly investigates any incident that has resulted in, or could reasonably result in a 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. Employee Participation Dow Chemical Michigan Operations operates on the premise that process safety management and accident prevention is a team effort. Company employees are encouraged to express their views concerning accident prevention issues and to recommend improvements. Improvements are solicited and implemented as appropriate. 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. Contractors On occasion, our company hires contractors to conduct specialized maintenance, construction and various other activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Dow Chemical Michigan Operations has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also required to inform the Dow Chemical Company of any hazards they may introduce at the site. 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 There have been 2 accidental releases as defined by the RMP rule of regulated substances from our facility within the last 5 years. The first release took place on 01/09/1997 and involved 42 lbs. of Allyl alcohol [2-Propen-1-ol]. The incident was a result of equipment failure. There were no offsite impacts . No deaths or injuries occurred offsite as a result of this accident. Onsite there was 1 injury. Another release, of 980 lbs. of Chloromethyl methyl ether [Methane, chloromethoxy-], occurred on 03/19/1997 due to human error. There were no known impacts either onsite or offsite. However sheltering in place was issued as a precautionary measure. 6. Emergency Response Plan Dow Chemical Michigan Operations maintains 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. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is updated to reflect any pertinent changes taking place within our processes that would require a modified emerge ncy response. The company works with the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Development of the Environmental Health and Safety Work Process, a concentrated Behavior Based Safety effort along with our Environmental Health & Safety 2005 company wide goals are some of the major steps we have take to improve safety at our facility. |