DuPont Johnsonville Plant - Executive Summary |
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At DuPont White Pigment and Mineral Products in New Johnsonville, TN, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: A description of our facility and use of substances regulated by EPA's RMP regulation A summary of results from our assessment of the potential offsite consequences from accidental chemical releases An overview of our accidental release prevention programs A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule An overview of our emergency response program The Dupont New Johnsonville plant consist of 1500 acres located on the west border of Humphreys County, bordering the Tennessee River, and approximately 2 miles North of Hwy. 70 and the City of New Johnsonville Tennessee. The Plant utilizes approximately 200 acres for it's manufacturing needs. The remainder of the property is set aside as a wildlife habitat and location of the Employees Recreation area. Our facility produces titanium dioxide (TiO2) via the chloride process. Titanium dioxide pigment is used to add whiteness and brightness to paint, paper, plastics, and other products. In our process, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics Use at Facility Chlorine Produce Titanium Tetrachloride (TiCl4 ) Titanium Tetrachloride Intermediate for TiO2 Our accidental release prevention programs and our contingency plann ing efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. KEY OFF-SITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worstcase release scenario(s) and alternative case scenario(s) for our facility. The following are brief summaries of these scenarios. Worstcase Release Scenario(s) - Regulated Toxic Chemicals The worstcase release scenarios for the Johnsonville site involve the failure of a chlorine barge storage tank released over a 10 minute time interval. With the weather conditions stipulated by the EPA, and no administrative controls or mitigation measures considered, public and environmental receptors could potenitally be impacted. Determinations were made using EPA off-site consequence Analysis guidance. Alternative Release Scenario(s) - Regulated Toxic Chemicals The Alternate release scenarios involve the release of 300 pounds of c hlorine and 4000 pounds of Titanium Tetrachloride from an oxidation reactor over a 10 minute time interval. Average meteorological conditions provided by the National Climatic Data Center (NCDC) for Nashville, Tennessee were used for New Johnsonville, TN. Determinations were made using SAFER (TM) Trace 8.0 (b) atmospheric dispersion modeling software. Impacted environmental receptors include wildlife sanctuaries and a state park. Public receptors include industrial areas and the Tennessee River as a public recreational area. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful accident prevention programs including: Process Safety Technology Process hazard analysis Operating Procedures & Safe Work Practices Training & Performance Mechanical integrity Quality Assurance Management of change Personnel Pre-startup review Auditing Incident investigation & Reporting Management of Change tecnology Management of Subtle Change Contractor Safety and Performance Emergency Planning and Response These individual elements of our accident prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases as well as all safety incidents that occur at our facility. The following is a brief summary of the only accidental chemical release involving materials covered under EPA's RMP rule during the past five years: Our plant had a release of liquid titanium tetrachloride in 1997, while maintenance men were breaking lines for process repairs, which involved 25 pounds of the substance. No offsite consequences occurred, but 2 injuries occurred onsite. Appropriate emergency response measures were taken during this event. For each of our safety incidents, we have conducted formal incident investigations to identify and correct the root causes of the events. EMERGENCY RESPONSE PROGRAM We maintain an emergency response plan, which meets all of the requirements as stated in the RMP rule. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan, and conduct annual community wide emergency drills. |