Elf Atochem North America, Inc. Carrollton Plant - Executive Summary

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Executive Summary 
A Risk Management Plan has been implemented at Elf Atochem's Carrollton production facility 
for the reduction of accidental releases of hazardous materials.  This Risk Management Plan 
summarizes the management, administrative, procedural, and technological controls that work 
together to minimize the risk to the community of hazardous chemical releases.  The Plan 
summary is organized to correspond with specific EPA RMP definitions and requirements, 
-    Introduction; 
-    Elf Atochem policies to protect health, environment, and safety; 
-    Facility identification and regulated substances covered processes; 
-    Hazard Assessment; 
-    Prevention Program;                      
-    Five year accident history; 
-    Emergency Response Plan; 
-    Planned changes to improve safety. 
Risk management and safety have been important concerns at Elf Atochem for many years; this 
RMP formalizes and documents these activities.  Elf Atochem is committed to conducting its 

perations in a safe, responsible manner and to reducing risks to health and the environment.   
This commitment to health, environment, and safety (HES) starts with the CEO.  Senior 
management routinely dedicates time to a review of HES matters, including safety.  This 
emphasis on safety is carried through to the facility level, where plant personnel regularly review 
safety performance, take corrective actions, and strive for continuous improvement.  The success 
of Elf Atochem's HES programs is also reflected by a strong commitment to safety by 
employees and contractors.   
Elf Atochem's HES programs include policies, procedures, standards, and guidance materials 
designed to fulfill Elf Atochem's commitment to health, environment, and safety.  These 
materials include Risk Management Program guidance to help our facilities prevent and or 
reduce the risk of accidents.   
The Elf Atochem Carrollton facility is located at 2316 Highland Ave., Carrollton, Kentucky.  
The facility is a specialty  
chemical manufacturer.  Certain substances used within 
the facility are regulated under 40 CFR Part 68, the EPA Risk Management Program (RMP) 
Rule.  These substances are present at or above the minimum threshold for RMP applicability.  
These substances are present in the covered processes at the following levels: 
                                       Chlorine (Cl2)                          180,000 pounds 
                                  Phosphorous Trichloride (PCL3)     80,000 pounds 
                                       Methyl Chloride (MeCl)                  292,000 pounds   
Chlorine, phosphorous trichloride and methyl chloride are used as process feedstocks.   
The worst-case accidental release scenario is a catastrophic failure of a liquid chlorine rail car.  
Chlorine is received as a liquid in pressurized rail cars and fed directly into the process.  The 
capacity of a rail car is 90 tons, and this quantity was assumed to be released over 10 minutes in 
the worst case scenario 
Hazard assessment modeling shows that, under worst case weather conditions, the worst case 
release could produce a chlorine plume that could travel more than 25 miles before dispersing 
enough to no longer pose a hazard to the public or environmental receptors.  It should be noted 
that regulatory agencies and Elf Atochem believe that the worst case scenario is an extremely 
unlikely event.  This Risk Management Plan includes information on mitigation and prevention 
measures implemented by Elf Atochem to reduce the risk of this type of event.   
The multiple layers of preventative measures make it very unlikely that a significant chlorine 
release will occur.  Chlorine rail cars are built with extreme integrity and safety precautions.  The rail cars are rigorously designed and tested according to the procedures and schedules 
recommended by the Chlorine Institute. 
In addition, in the unlikely event that a release occurs, Elf Atochem has an array of mitigation 
measures to reduce any poten 
tial impacts.   These include: 
-    Site emergency action plan; 
-    Chlorine detectors; 
-    Alarm system initiated by chlorine detectors; 
-    Plant emergency alarm system; 
-    Operators trained to make an initial response; 
-    On-site emergency response team for each shift trained at the Hazardous Materials (Haz-Mat) technician level; 
-    Medical department on-site;  
-    Notification to LEPC to activate Community Response Plan 
One alternative scenario for each regulated toxic substance was also developed in the hazard 
assessment.   A description of each of these scenarios and the estimated distance of the potential 
impacts is as follows.  The Alternative release scenario for chlorine is the failure of the valve 
packing on a railcar, and the chlorine plume was estimated to go 2.2 miles before dispersing 
enough to no longer pose a hazard to the public or environmental receptors.  The Alternative 
release scenario for phosphorous trichloride was overfilling a vessel, and the phospho 
trichloride plume was estimated to go 0.43 miles before dispersing enough to no longer pose a 
hazard to the public.  The Alternative release scenario for methyl chloride was a release from a 
pipe leak, and the methyl chloride plume was estimated to go 0.3 miles before dispersing enough 
to no longer pose a hazard to the public or environmental receptors.  These Alternative Release 
Scenarios are somewhat more likely than the Worst-Case Scenario, but are still very unlikely 
events.  This Risk Management Plan includes information on mitigation and prevention measures implemented by Elf Atochem to reduce the risk of these type of events.   
While the Alternative Release Scenarios are, by definition, more likely than the Worst-Case 
Scenario, they are still very unlikely given the facility's prevention program.  If a release should 
occur, Elf Atochem has an array of mitigation measures to reduce any potential impacts.  The 
mitigation measures identified for the Worst-case scenario would a 
lso apply to the Alternative 
Release Scenarios. 
A prevention program is in place to minimize the risk of hazardous chemical releases in 
accordance with the Occupational Health and Safety Administration (OSHA) Process Safety 
Management (PSM) Standard (29 CFR 1910.119) and the EPA Risk Management Program.  
This prevention program covers those processes that handle chlorine, phosphorous trichloride 
and methyl chloride above the threshold quantity of either PSM or RMP rules. 
The prevention program provides a structured approach to preventing accidents.  Some of the 
specific activities in the prevention program include: 
-    In-depth process hazard analyses are completed every five years by qualified personnel 
    using techniques approved under OSHA PSM standards; 
-    Written operating procedures (kept up to date) are used for training and directing the 
    work of operators, who receive refresher training every three years; 
-    Operators, mechanics, and contractor personnel are qualif 
ied, trained in the general 
    hazards in the facility, and informed of any temporary situations affecting safety;   
-    A safety work permit system assures that work is done safely and properly;  
-    A management system is in place to ensure that changes are managed safely; 
-    Critical equipment is inspected on a planned, periodic basis to assure proper operating 
-    Pre-startup reviews are done to insure that conditions for safe operation have been 
    satisfied prior to starting new or modified equipment; 
-    Incidents are investigated and actions are taken as part of a continuous improvement 
    effort; and  
-    Routine audits are conducted to assure that safe practices are being followed. 
This systematic approach to process safety involves employees and strives for continuing 
improvements in accident reduction.  The training, qualifications, and safety awareness of our 
operations, maintenance, and emergency response personnel are a key element in reducin 
g and 
mitigating accidents.   
Measures that would prevent the worst-case scenario primarily consist of chemical handling 
policies and standard operating procedures to ensure care in moving rail cars near and within the 
facility.  Delivery and on-site rail car handling personnel are highly trained and skilled, and rail 
cars are moved at very low speeds.  The integrity of the vessels themselves is maintained through the mechanical integrity program via the aforementioned vessel inspections and tests.  The rail cars are also protected from over pressurization with a pressure relief system. 
Potential hazards that could produce a catastrophic release are strictly controlled.  Rail cars are 
spotted and moved only in areas with no overhead construction or equipment that could fall and 
impact a car.  Access to the facility is restricted through security barriers and trained security 
personnel, thereby minimizing the risk of sabotage.  Construction throughout the facility is non-combustible, an 
d fire hazards are strictly controlled.  The risk of fire induced vessel failure is extremely low.   
The alternative release scenario for chlorine was selected as a valve packing failure.  Prevention 
steps for this scenario include preventative maintenance and standard operating procedures for 
connecting the rail cars to the process.  An excess flow valve is present on the liquid connection 
within all chlorine rail cars.  The valves are designed to limit the rate of release to no more than 
15,000 pounds per hour.  Remote operated valves which can be closed from the control room 
should a problem occur.  This would serve to limit the release size and therefore, reduce the 
potential for off-site impact in the unlikely event of a release.   
The alternative release scenario for phosphorous trichloride was selected as a release from 
overfilling a vessel.  Prevention steps for this scenario include standard operating procedures and 
tank level alarms.  The chemical processes are batch processe 
s; therefore, chemical transfers are 
performed intermittently, under manual control, and under close supervision.  Pumps can be 
stopped remotely from the area control room should a problem occur.  This would serve to limit 
the release size and therefore, reduce the potential for off-site impact in the unlikely event of a 
The alternative release scenario for methyl chloride is the release from a pipe leak.    Piping 
release scenarios could result from failures of flanges or fittings, or from a hole in the transfer 
piping.  Primarily, all transfer lines utilize welded connections, and the use of fittings and flanges is minimized.  Prevention steps for this scenario include strict adherence to piping and pipe support design standards, proper maintenance, inspections and tests under the mechanical 
integrity program.  Maintenance work practices are controlled to prevent mechanical impact or 
other piping stresses. 
From the beginning of 1994 to the present, there have been no accid 
ents/releases of regulated 
substances from covered processes that meet the criteria for the Five Year Accident History, 
which are focused on serious accidents with either onsite deaths, injuries, or significant damage; 
or known offsite deaths, injuries, property damage, or environmental damage.  Elf Atochem 
realizes that the community may also be interested in smaller releases of regulated chemicals that 
do not meet EPA criteria for the Five-Year accident History.  We have been diligent in reporting 
releases of hazardous materials and in internally investigating and correcting the causes of such 
A written emergency response plan is maintained at the facility.  The plan was developed in 
cooperation with local officials from the Carroll County Department of Public Safety and was 
coordinated with the community emergency response plan. 
The emergency response plan includes procedures for notifying civil authorities and the public in the event of an incident.  The plan also includ 
es documentation of proper first-aid and medical 
treatment necessary to treat accidental human exposures; procedures for the use of emergency 
response equipment and for its inspection and testing; a description of the training program for 
all employees in relevant emergency response procedures; and procedures to review and update, 
as appropriate, the emergency response plan to reflect changes at the facility, and to ensure that 
employees are informed of these changes.
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