Elf Atochem North America, Inc. Carrollton Plant - Executive Summary |
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, including: - 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 o 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 rous 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 condition; - 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 release. 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 releases. 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. |