Rohm and Haas Philadelphia Plant - Executive Summary

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Rohm and Haas Company - Philadelphia Plant 
Risk Management Plan 
Executive Summary 
1.0  Introduction 
The Rohm and Haas Company Philadelphia Plant is committed to operating and maintaining all of our processes safely and responsibly.  Our continuing work to prevent accidents and releases from occurring, as well as our preparations to respond to accidents if they should occur, help to ensure the safety of our employees and the public as well as protection of the environment.  This summary provides an overview of the many risk management activities at the site, and a discussion of our response to the EPAs Risk Management Program.  This summary includes: 
1.0  Introduction 
2.0  General Facility Information 
3.0  Regulated Substances 
4.0  Accidental Release Prevention and Emergency Response Policy 
5.0  The General Accident Prevention Program and Chemical Specific Prevention Steps   
6.0  Five Year Accident History 
7.0  Emergency Response Program  
8.0  Worst Case and Alternative Case Release 
9.0  Planned Changes to Improve Safety  
The EPAs Risk Management Program 
In a series of rules promulgated between 1994 and 1998, the U.S. Environmental Protection Agency established the Risk Management Program (RMP) under Clean Air Act 112(r).  The RMP contains a list of toxic and flammable chemicals.  Facilities that manage more than a threshold amount of a listed chemical may be subject to the RMP.  Covered facilities must assess the risks associated with their management of the listed chemicals and produce a plan to prevent releases and accidents.  In order to assist in emergency planning, covered facilities must evaluate "worst case" and "alternate case" scenarios that would result from the release of a listed chemical.  Finally, the covered facility must make their risk management program available to the public.  This document is part of Rohm and Haas Philadelphias RMP communication effort.   
2.0  General Facility Information 
The Rohm and Haas Company Philadelph 
ia Plant is a manufacturing facility located in the Bridesburg section of Philadelphia, Pennsylvania. The Rohm and Haas Philadelphia manufactures specialty chemicals for industry, water treatment, and pest control.  The facility occupies 55 fenced acres bordered by Bridge Street, the Frankford Creek and the Delaware River.  Facility operations include chemical loading/unloading by truck and rail; material storage; chemical processing, waste collection, storage and treatment; and steam generation. In all phases of its operation, the Plant stresses safety and protection of the environment. 
The plant is currently composed of the following three operating areas: 
  Separations Area - Production of ion exchange resins used in water treatment and purification, sugar refining, food and beverage processing, and pharmaceutical manufacturing. 
  GOAL(TM) Area - Production of GOAL(TM) Herbicide for use on ornamental plantings, turf plantings, and tree fruit. 
  Facilities Area - Includes steam  
generation and waste water pre-treatment.  
We are pleased to provide information on our safety and emergency preparedness plans, as well as the systems and training to prevent accidental releases. 
3.0  Regulated Substances 
Our plant uses two chemicals which are on the RMP list:  
7 Oleum (20% SO3), an RMP toxic used in the production of Ion Exchange Resins and 
7 Nitric Acid (HNO3 90%),  an RMP toxic used in the production of GoalR herbicide.  
The total quantity of Oleum, rather than only the 20% SO3 contained in the Oleum, is used for RMP calculations.  RMP calculations for Nitric Acid have been adjusted to account for the actual concentration of HNO3 in the mixture.  
4.0  Accidental Release Prevention and Emergency Response Policy        
Rohm and Haas Philadelphia has a long standing commitment to provide a safe workplace and to prevent accidental releases.  This commitment is set forth in Rohm and Haas environmental, health and safety policies. 
-  We will ensure our worldwi 
de operations and products are free from significant risks to the health and safety of our employees, customers, carriers, distributors, the general public, and to the environment. 
-  We will meet or exceed all applicable laws and regulations, participate in voluntary initiatives such as Responsible Care. and strive for continual improvement in our Environmental, Health, and Safety performance. 
-  We will provide our employees with a safe workplace and support their efforts to work safely. 
-  We will strive to eliminate or reduce emissions, discharges, and wastes from every stage of our operations. 
-  We will communicate, listen and be responsive to our employees, customers, neighbors, and governments, and we will share information concerning potential hazards resulting from our operations or our products. 
A consistently strong safety performance earned the plant STAR status in the OSHA Voluntary Protection Program (VPP) in 1994. The plant was successfully re-audited by OSHA  
in March 1998 and has continued as a VPP STAR site.  Additionally, Rohm and Haas Philadelphia has supported the growth of VPP with other companies in our region.  
The types of risk management programs required by the RMP have long been in place at Rohm and Haas Philadelphia.  Safe operation is a plant and company priority, and is reflected in policies as well as everyday activities. We welcome the EPAs RMP initiative and see it as an opportunity to expand dialog with our community and to help us improve our safety performance.  
5.0  The Rohm and Haas Philadelphia Accident Prevention Program and Chemical Specific Prevention Steps   
Rohm and Haas Philadelphia maintains a number of accident prevention programs in order to ensure safe operation of all processes.  For example, the plant complies with OSHAs Process Safety Management (PSM) rule, which is nearly identical to EPAs Risk Management Program (RMP) rule. Additionally, the Plant follows corporate and plant-specific safety stan 
dards, which in some cases are more stringent than the OSHA general safety standards.  The following items are part of our ongoing program to prevent releases and incidents:   
1)  Employee Participation  Employees are involved in many activities to continuously improve plant safety.  Employees participate in safety committees, job safety analysis, audits, design and pre-startup safety reviews, process hazard analysis, training, procedure development and monthly safety meetings. 
2)  Process Hazard Analysis - Various process hazard analysis techniques are used to identify and analyze the potential hazards associated with the chemicals and processes we use. Corrective action plans are developed and implemented as part of the analyses and updated a minimum of every five years. Safety systems are designed into the processes.  These are designed to create several layers of protection, so that if one system fails other systems will maintain the process in a safe state.  Examples include: 
-  Redundant safety systems and instrumentation 
-  Automatic shutdown devices that are triggered if critical safety equipment malfunctions 
-  Secondary containment for storage tanks 
-  Alarm systems and automatic shutdown devices for critical control parameters 
-  Pressure relief devices to prevent overpressurization 
-  Fire protection systems 
-  Operator surveillance of unloading operations 
-  Permit system to control work in hazardous areas 
-  Work preplanning and safety reviews 
3)  Operating Procedures  Operating procedures have been developed for all processes to ensure safe operation.  Employees that operate the manufacturing process are included in the development, training and periodic review of these procedures.  Our processes are ISO  9002 certified.  
4)  Employee Training  Training programs have been developed and implemented  to ensure that all affected employees understand the hazards of the chemicals and the required safe handling procedures.  Employees involved in o 
perating the manufacturing processes are trained, tested, and qualified. 
5)  Mechanical Integrity  This program was established to ensure the integrity of process equipment.  Elements of this program include: 
7 Identification and categorization of equipment and instrumentation 
7 Inspections and tests 
7 Establishment of inspection frequencies 
7 Development and application of maintenance procedures 
7 Training of maintenance personnel 
7 Documentation of tests and inspection results 
6)  Pre-Startup Safety Reviews  Safety reviews of new processes, major projects, and new chemicals are conducted to ensure safe transition into the manufacturing process.   
7)  Hot Work Permit  This system manages welding, cutting, brazing and other ignition sources throughout the plant to prevent fires and explosions. 
8)  Management of Change  This procedure is in place to properly manage the changes involving processes, chemicals, technology, equipment, personnel or facilities.  
9)  Contractor Tra 
ining and Safety Reviews  Contractors are evaluated to ensure they have the appropriate job skills, knowledge, training and certification to perform their assigned work safely.  The safety performance of contractors is periodically reviewed. 
10)  Incident Investigation  Any incidents or near misses involving the release of hazardous material are investigated by a team of skilled and knowledgeable plant personnel.  These investigations determine root cause and identify corrective actions, evaluate our management systems and are documented and communicated throughout the Plant in a narrative report. Any required corrective actions are tracked for timely completion. 
11)  Compliance Audits  Audits of our Process Safety Management System are conducted  every three years.  These audits review accident prevention activities to ensure the requirements of the programs are being met.  
6.0  Five Year Accident History 
The RMP rule requires each company to include a description of all accid 
ental releases from covered processes that result in deaths, injuries, or significant property damage on-site, or known off-site deaths, injury, evacuation, sheltering in place, property damage, or environmental damage.  The Rohm and Haas Philadelphia plant has had no events meeting this criteria during the last five years. 
7.0  Emergency Response Program  
The facility maintains an up-to-date emergency response plan which is coordinated with the Philadelphia Fire Department and the Philadelphia Local Emergency Planning Committee (PLEPC). The plan has been designed to meet the requirements of all relevant regulations requiring emergency response plans, and is intended to prevent and mitigate the consequences of a hazardous material spill, protect the well-being of Rohm and Haas employees, the surrounding community, and the environment, and serve as a reference to responders in the event of an emergency.  Copies of the plant response plan have been provided to the Philadelphia Fire De 
partment, the local hospital, the PLEPC, and the State and Federal Environmental Protection Agencies.   
A trained on-site incident commander is assigned the responsibility of coordinating the Plant response to any incident which may occur.  An incident commander is on duty at the Plant 24 hours per day.   Additionally, a trained Communication Coordinator is assigned the responsibility of setting up the emergency operations center, communicating response needs with outside responders, contacting outside agencies, and activating both the Community Sirens and the Community Alert Network (CAN System) to alert and inform residents.  Plant and Community Sirens are tested monthly, and plant evacuation drills are held annually.  All plant employees are trained on the relevant aspects of the emergency response plan.   
8.0  Worst Case and Alternative Case Release Scenarios 
The RMP rule provides detailed requirements that define a worst case scenario (WCS), namely a release of the entire cont 
ents of the largest storage vessel occurring under very stable weather conditions and at a low wind speed.  EPA notes that the worst case scenario is designed principally to support a dialogue between the source and the community on release prevention, and not to serve as the sole or primary basis for emergency planning. Based on previous history, in addition to the several layers of protection in place, these worse-case scenarios are highly unlikely to actually occur. 
The RMP rule also defines the alternate release scenario (ARS). Unlike worst case scenarios, the ARS can be limited by active mitigation safeguards, such as alarms, automatic shutdowns, and operator interventions.   According to EPA, an ARS is a more useful communication tool for the public and first responders and for emergency response preparedness and planning.  
Worst Case Scenarios:  Rohm and Haas Philadelphia has identified one WCS based on the RMP definition.  
RMP Defined Worst Case Scenario 
This scenario invol 
ves Oleum, which is considered a toxic material under the RMP rule.   It assumes the loss of the entire inventory of a 187,500 pound railcar inside the Containment Shed over a ten minute period.  This scenario takes the following passive mitigation systems into account:  the containment shed as an enclosure, a below-grade sump which will contain 75% of the railcar, natural berms outside of the shed and drains to the chemical sewer outside of the shed.  These passive mitigation systems would all act to reduce aspill pool area such that the vaporization rate to the atmosphere would be significantly reduced.  The PHAST dispersion model was used to determine the toxic endpoint of this release, and such a release could have a significant off-site impact.  Because of the plant controls, procedures and training, this worse case event is considered extremely unlikely.  
Alternate Release Scenario - Rohm and Haas Philadelphia has identified two Alternate Release Scenarios: one for each toxic m 
aterial.  These scenarios were chosen after reviewing process hazard analysis, the plant spill history, and discussing alternatives with knowledgeable and experienced unit personnel.  The scenarios we have identified are more credible than those described in the worst case, but are still very unlikely given the multiple levels of protection and extensive employee training.  The following provide descriptions of our alternate case scenarios.   
Alternate Release Scenario (ARS) - Oleum (Toxic Liquid) 
If a rupture occurred in the 2" transfer line from the railcar to the process reactor, 3,800 pounds of Oleum would be released inside the production building.  It is assumed that the release would be either physically detected by an operator (there is a continuous operator presence in the production building) or detected by the control system, and stopped within 10 minutes.   The PHAST model was used to determine the toxic endpoint.  This release could affect plant employees, and the employ 
ees of the Frankford Arsenal to the north, depending on the weather conditions and the wind direction. There are no residences or environmental receptors within the alternate release toxic endpoint circle.   
Alternate Release Scenario (ARS) - Nitric Acid (Toxic Liquid) 
If a rupture occurred in the 1-1/2" transfer line from the tank truck to the storage tank, 6,300 lbs of 90% Nitric Acid would be released outside.  The tank truck unloading operation is constantly attended by an operator per DOT regulations.  It is assumed that the release would be physically detected by the operator and stopped within 10 minutes.  The release would be contained in a sloped and diked area as the tank truck, storage tank and piping are all within a diked area.  This containment would reduce the pool area, thereby reducing the nitric acid vaporization rate.  The unloading area is equipped with a deluge system and a remote fire monitor nozzle to assist with mitigation. The PHAST model was used to determin 
e the toxic endpoint.  This release could affect plant employees, and the employees of the Frankford Arsenal to the north, depending on the weather conditions and the wind direction. There are no residences or environmental receptors within the alternate release toxic endpoint circle.   
9.0  Planned Changes to Improve Safety  
The plant focus on safety is strong throughout the Rohm and Haas Company.  Rohm and Haas continuously looks for ways to reduce risks and to improve safety performance.  Our safety program is integrated into all parts of plant operation and involves the identification and implementation of ways to improve safety performance.   In the immediate future, improvements are planned as an outcome of our recently revalidated Process Hazard Analysis on the Oleum covered process.
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