DuPont Spruance Plant - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The DuPont Richmond Spruance plant adheres to Corporate, OSHA and EPA policies and standards which are summarized as follows: - All Safety, Ergonomic, Occupational Health and Environmental incidents are preventable. - All injuries and illnesses, both on the job and off, are preventable. - All employees and contractors are responsible for their own safety. - DuPont's philosophy to safety involving contractors is the same as with its' employees - that all injuries are preventable. The Corporate policies are embodied in the numerous Safety, Health, Environmental and Engineering standards which apply globally. At the Richmond Spruance plant, the policies are implemented through the site Safety and Health manual and the site Environmental Spill manual. These manuals and standards are available to all employees through hard copies, and in most cases on the Corporate and site intranet pages. Each area has area Process Safety Manuals that apply the OSHA 1910.119 principles. Emergency Response plans exist for the entire location and are described in hard copy and electronic formats. In addition, each of the areas has their own Emergency Response Plan. FACILITY DESCRIPTION The DuPont Spruance plant encompasses just under 500 acres, and is located between Route 1/301 (Jefferson Davis Highway) on the West and Interstate Route 95 and the James River on the East. It is just south of the Richmond city boundary line in Chesterfield county, Virginia. The primary products produced at this site include synthetic fibers, sheets and resins. The products made at this site are used in finished product applications such as: bullet proof vests for police and the military; fire retardant clothing for fire fighters; hygienic food packaging; light weight molded parts for cars and trucks and vapor barriers/wraps used in housing construction. The following regulated materials are used on the site: - Chlorofo rm - Oleum - Flammable substance WORST CASE TOXIC RELEASE SCENARIO The worst case release scenario for a toxic chemical is for chloroform. Since chloroform is used in two processes located at opposite ends of the site (north and south), two worst cases are reported. Each processes' off-site impact distance is very similar but due to the separation of the processes, slightly different off-site populations would be affected. The north chloroform process worst case is a failure of a process vessel with its' maximum capacity spilled. The spill is contained by existing concrete diking, limiting release rate to 536 pounds per minute. The release would have an off-site impact, as determined by the use of EPA RMP OFFSITE CONSEQUENCE ANALYSIS GUIDANCE tables. This release is unlikely due to the materials of construction used and the monitoring and inspection procedures continuously applied. The south chloroform worst case is a failure at the top of a process vessel with the releas e of a vapor at the rate of 2100 pounds per minute for a 10 minute period. The release would have an off-site impact, as determined by the use of EPA RMP OFFSITE CONSEQUENCE ANALYSIS GUIDANCE tables. This release is unlikely due to the materials of construction used and the monitoring and inspection procedures continuously applied. WORST CASE FLAMMABLE RELEASE SCENARIO The worst case release for a flammable chemical is the failure of the largest Flammable Substance storage tank with its' maximum capacity spilled. This release, if ignited, would have an off-site impact as determined by the use of EPA RMP OFFSITE CONSEQUENCE ANALYSIS GUIDANCE tables. The ignition of this release is unlikely because the spilled contents would be contained in a diked area draining away towards separate collection tanks. ALTERNATIVE TOXIC RELEASE SCENARIOS Since both the north and south chloroform processes are very similar, the same alternate scenario is used for both areas. A large spill occu rs from the failure of a piece of pipe, or a flange break. The resulting spill fills the entire concrete dike area - which is in place to collect spills. The dike areas are designed to hold the maximum amount of spill from the largest vessel, so the release rate from the spill pool is limited by the area of the diking to 948 pounds/minute for the North process and 790 pounds/ minute for the south process. Off-site impact was determined by use of the "Safer Systems Trace" computer model using a release duration of 60 minutes. ALTERNATE FLAMMABLE SCENARIO The alternate scenario release for a flammable chemical is the failure of the largest Flammable Substance storage tank, the same as the worst case. This release, if ignited, would have an off-site impact as determined by the use of EPA RMP OFFSITE CONSEQUENCE ANALYSIS GUIDANCE tables (using alternate scenario conditions). The ignition of this release is unlikely, again, because the spilled contents would be contained in a dike d area draining away towards separate collection tanks. FIVE YEAR ACCIDENT HISTORY: There have been no off-site deaths, injuries or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage or environmental damage from a release of any of the regulated substances in the past 5 years. EMERGENCY RESPONSE PROGRAM: Plant personnel are trained and equipped to respond to, and correct, many of the potential releases of regulated chemicals. These trained personnel include a site Fire Brigade, a site Rescue team, a Medical EMT team and a Hazmat team on all shifts. The program can be summarized as follows: A. Training and Preparation - Plant Emergency Response teams on all shifts receive all required OSHA training and in some cases exceed those requirements. - Plant personnel not involved in the above teams receive emergency training. - Emergency response plans for the site and individual areas are maintained in curren t condition. - The Plant conducts several drills annually and OSHA 1910.119 areas conduct area drills. - Critiques and followup actions are performed on all drills and any actual response event. - The Plant is a member of the Chesterfield County Local Emergency Planning Committee. - The Plant has routine meetings with community and local business representatives and openly discusses Emergency Response activities. B. If a Major release occurs - Plant site and area alarms are activated. - Sheltering in safe havens occurs if required. - Site Primary and Secondary Control Centers are activated. - 911 is notified which in turn, notifies surrounding localities as required by wind direction, quantity, etc. - The Plant Incident Commander, site leadership and the emergency groups (site and local community) respond as needed or as appropriate. PLANNED CHANGES TO IMPROVE SAFETY: - Continued work in improvement to sheltering areas. - Elimination of liquid/gas chlorine for water tea tment. - Increasing Site and Area emergency drills to continuously improve. - Continued focus on "0" injury philosophy, Inherently safer technology, operating discipline through operating excellence concepts and moving the OSHA 1910.119 concepts to all areas regardless of hazard classification. MISCELLANEOUS: This is a special note concerning data entry in this RMP Submit vs. program "bugs". First, in the "Toxics: Worst Case ID" section, the material Oleum is listed for two processes. Oleum, because of its' very low vapor pressure (due to the very low concentration of sulfur trioxide in our Oleum) is a Program 1 chemical. A worst case does not have off-site impact. The release rate (item 2.6) is entered as 0.2 lbs/ minute. The calculated rate is ACTUALLY LESS THAN 0.1. The RMP Submit program, however, will not allow a number less than 0.2 as input in this data field. This program "bug" was confirmed by Ms. Karen Shanahan of the EPA. Secondly, there is another program "bu g" related to some of the data entered under the Flammable category. This submission has used the designation of "CBI Flammable Substance" for the one RMP flammable material covered under this RMP. Even though all appropriate sections to the Flammable substance are entered (The Process, the Worst case and an Alternate case) RMP Submit gives a validity check error on this data. This program "bug" was confirmed by Mr. Menish Patnak through the RMP Submit help line. This submission is COMPLETE, even though the validity check gives an error message on the Flammable Worst and Alternate scenario data - The data IS INCLUDED. |