Vulcan Chemicals, Wichita Plant - Executive Summary |
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1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Vulcan-Wichita plant has a long-standing commitment to worker and public safety and to the protection of the environment. We are committed to operating and maintaining all of our processes in a safe and responsible manner, as demonstrated by the resources we invest to prevent accidents. As a member of the Chemical Manufacturers Association, we adhere to the principles of Responsible Care. In addition to ensuring that our employees have the best possible training in the operation of our processes, we demand that safety be the first priority in the design, installation, operation, and maintenance of our processes. Our process equipment is designed, constructed and maintained using sound engineering practices and conforms to applicable industry codes and standards including those of the Chlorine Institute for equipment used in manufacturing and handling chlorine. We have implemented maintenance and inspection pro grams that ensure site integrity. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. Examples of such controls include 1) installation of pressure safety valves to prevent rupture of vessels due to overpressurization, 2) routine visual inspection and thickness checks to ensure vessels and piping are in good condition, 3) limiting inventory in storage tanks to eighty percent of the maximum capacity, 4) using materials of construction that are compatible with process chemistry, 5) monitoring vessel pressure and temperature continuously, 6) using a nitrogen pad inside certain tanks to prevent a fire from starting inside a tank, 7) installation of barriers around process vessels and storage tanks to prevent contact with moving vehicles, and others. However, if a release does occur, trained personnel will respond to control and contain the release. Mitigation measures that have been included in our design include installation of isola tion valves, installation of excess flow valves which limit the amount of chemical released, fire suppression systems in areas where flammable chemicals are present and fire fighting equipment in all process areas, fully implemented emergency response plan, appropriate personal protective equipment (PPE) in control rooms, and an alarm system for early notification of a release. If a release occurs, we will use a dispersion model Systematic Approach For Emergency Response (SAFER), and meteorological data from our weather tower, to predict the plume direction and size, downwind ground level chemical concentrations, and the estimated time at which the plume will reach offsite areas. This information will be communicated to 911, in case any actions need to be taken by emergency response agencies. In addition, our Community Alert Network (CAN) system provides us the means to alert approximately 950 residents within a 25 square mile area around the plant in case of a release that may impa ct offsite areas. 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES The Vulcan-Wichita plant is primarily involved in manufacturing various inorganic and chlorinated organic chemicals. Our products are distributed to customers via rail cars, tank trucks, and in containers. As a part of this manufacturing process, we use and produce several substances that are covered by the risk management program (RMP) rule (40 CFR 68). These include chlorine, sulfur dioxide, chloroform, methyl chloride, vinyl chloride and vinylidene chloride. The maximum quantities of these regulated substances that could be present in plant processes are 2.2 million pounds of chlorine, 60,000 pounds of sulfur dioxide, about 460,000 pounds of methyl chloride, approximately 15 million pounds of chloroform, 18,000 pounds of vinyl chloride, and about 250,000 pounds of vinylidene chloride. The RMP regulated processes are our chlorine plant, chlorine rail car loading, membrane cell room, chloromethanes plant, VFS pla nt, and R&D pilot plant. All of these plants fall under the RMP Program Level 3 category. Vulcan's products serve a multitude of vital needs throughout American and global economies, playing a role in nearly every modern industry and in thousands of products that consumers use every day. Chlorine is sold as a product and is also used as feedstock in the chlorinated organics manufacturing process. Common end uses of chlorine include treatment of municipal water supplies, sewage and wastewaters, and manufacture of bleach. Sulfur dioxide is used in our membrane cell room to remove residual free chlorine from brine. Chloroform and methyl chloride are sold as products; methyl chloride is also used in our chlorinated organics manufacturing process as feedstock. Our customers use chloroform to manufacture refrigerant R-22, pharmaceuticals, plastics, dyes, resins and fire extinguishing agents. Chloroform is also used as an extraction solvent in recovery of penicillin, vitamins and esse ntial oils. End uses for methyl chloride include manufacture of silicone products, synthetic rubber products, and agricultural chemicals. Vinyl chloride and vinylidene chloride are used to produce specialized hydrochlorocarbons that will be used by our customers as feedstocks in manufacturing third generation refrigerants. Besides process equipment, the plant has a number of tanks for storage of raw materials and products, rail car and truck loading/unloading facilities, a laboratory, and a research and development facility. Because we handle large quantities of chemicals, we use a combination of good design practices, an accidental release prevention program, and an emergency response program to ensure the safety of our employees, the public, and the environment. Information on these programs is provided in other sections of this executive summary. We are committed to operating our facility in a safe and responsible manner. 3.0 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule (40 CFR 68) requires that we provide information about two types of offsite consequence analysis scenarios: worst-case scenarios and alternative release scenarios. There are strict requirements for choosing and modeling worst-case release scenarios; as a result, these scenarios are often exceedingly conservative. The purpose of the alternative release scenarios is to provide emergency planners with more information about the chemicals we handle and about their relative hazards. The alternative release scenarios are more realistic than worst-case release scenarios but are still unlikely to happen. Following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures that limit exposure distances. Information on the number and type of public and environmental receptors is also provided. Estimates of the impacted population are based on U.S. Census Bureau data. Information on environmental receptors was obta ined from USGS topographic maps. 3.1 Worst-Case Toxic Release Scenario The worst-case release scenario representing the toxic substances handled by Vulcan is a catastrophic rupture of a storage tank containing chlorine. Vulcan administratively limits the quantity stored in the tank to 900,000 pounds. Although we have several mitigation features on the storage tank that would limit the release rate, we assume that the entire quantity in the storage tank will release over a 10-minute period. The chlorine released to the atmosphere travels more than 25 miles before dispersing below the toxic endpoint of 3 ppm. Approximately 300,000 people live within 25 miles of the storage tank. The public and environmental receptors that are located within this distance are schools, residences, hospitals, public recreational areas, prisons, commercial/industrial areas, and state and county parks. The toxic endpoint of 3 ppm is defined by EPA as the maximum concentration below which individual s could be exposed for up to 1 hour without developing serious health effects that could impair their ability to take protective action. 3.2 Worst-Case Flammable Release Scenario The worst-case release scenario representing the flammable substances handled by Vulcan is a catastrophic rupture of a storage tank containing vinylidene chloride. In this scenario, the entire quantity of vinylidene chloride, 250,000 pounds, is released to the atmosphere, where it ignites and explodes. Although we have several features which help to prevent this scenario, or which mitigate the consequences of such a release, no credit is taken for these measures in this scenario. The resulting vapor cloud explosion reaches the 1-psi endpoint about 0.31 miles (1,600 feet) from the storage tank. The only public receptor is an industrial plant located adjacent to the Vulcan-Wichita plant. No environmental receptors are impacted. Overpressure is defined as the peak pressure resulting from an explosion tha t is in excess of normal atmospheric pressure. Effects of 1-psi overpressure may include shattering of windows. 3.3 Alternative Toxic Release Scenarios The alternative release scenario for chlorine is a break in a 3-inch chlorine transfer pipe between our chlorine and chloromethanes plants at the Wichita facility. The automatic shutoff valve on the transfer line restricts the amount released to about 5,000 pounds. The release lasts for 10 minutes. The chlorine cloud travels 3.3 miles before dispersing below the toxic endpoint of 3 ppm. Approximately 3,300 people live within this distance from the transfer pipe. The public receptors that are located within this distance are industrial plants, residences, a school and a recreational area. No environmental receptors are impacted. The alternative release scenario for sulfur dioxide is a break in a 1-inch sulfur dioxide storage tank vapor line during unloading of sulfur dioxide from a tank truck into our process. The release las ts for 2 minutes, which is an estimate of the time required for a Vulcan employee to stop the release. A total of 160 pounds of sulfur dioxide is released. The maximum rate of vapor release into ambient air is approximately 80 pounds per minute (lbs/min). The sulfur dioxide cloud travels about 1.2 miles before dispersing below the toxic endpoint of 3 ppm. Approximately 80 people live within this distance from the storage tank. The public receptors that are located within this distance are one industrial plant and residences. No environmental receptors are impacted. The alternative release scenario for chloroform is an inadvertent overfilling of one of the chloroform storage tanks. The chloroform is pumped into the diked area at a rate of 1,560 lbs/min. Although a Vulcan employee is likely to notice the spill quickly, we assume that it continues for 3 hours without intervention for a total of 281,000 pounds of chloroform released into the diked area. The chloroform forms a liq uid pool inside the containment dike and evaporates at a maximum rate of 1,560 lbs/min. The resulting cloud travels about 0.7 miles (3,700 feet) before dispersing below the toxic endpoint of 100 ppm. Three industrial plants are located within this distance from the storage tank. No environmental receptors are impacted. The alternative release scenario for methyl chloride is a rupture in the 3-inch loading hose to a railcar resulting in the release of 28,000 pounds of methyl chloride to the atmosphere. The flow rate from the process of 1,760 lb/min is stopped by a Vulcan employee 10 minutes after the release begins. The 10 minute period is a conservative estimate of the time required for a Vulcan employee to notice and stop the release. The flow from the railcar is limited by an excess flow valve to 1,045 lb/min. This flow is also stopped after 10 minutes when an operator climbs to the top of the railcar and closes the valve. The maximum rate of vapor release into the ambient a ir is 2,800 lbs/min. The methyl chloride cloud travels 0.8 mile before dispersing below the toxic endpoint of 400 ppm. Approximately 15 people live within this distance from the railcar. The public receptors located within this distance are industrial plants and residences. No environmental receptors are impacted. 3.4 Alternative Flammable Release Scenario The alternative release scenario for flammables is a rupture of a railcar containing 18,000 pounds of vinyl chloride. This is a conservative scenario since a catastrophic failure of a railcar is an extremely unlikely event. The entire quantity of vinyl chloride is assumed to be involved in an explosion of the subsequent vapor cloud. The resulting overpressure from the explosion falls below the overpressure limit of 1 psi at approximately 0.1 mile (530 feet) from the railcar. The only public receptor impacted within this distance is an industrial plant adjacent to Vulcan's Wichita plant. No environmental receptors are imp acted. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. We are in compliance with OSHA's Process Safety Management (PSM) rule and this RMP rule. Our management system addresses each of the key features of a successful prevention program, as described below in Sections 4.1 through 4.12. 4.1 Process Safety Information The Vulcan-Wichita plant maintains a variety of technical documents that describe the chemicals and processes at our facility. These documents are kept up to date and are available to all employees and address important process parameters such as 1) operating limits for the equipment, 2) design basis and configuration of the equipment, and 3) physical properties and hazards of the chemicals used in our processes. Plant personnel rely on these documents to perform their job functions properly, consistently and in a safe manner. Chemical information is usually docume nted in material safety data sheets (MSDSs). MSDSs contain information concerning both the physical properties and the hazards associated with each chemical. This information typically includes 1) toxicity information, 2) physical data, 3) reactivity and corrosivity data, 4) thermal and chemical stability data, and 5) hazards of mixing substances together. MSDSs are available to all employees, as well as the emergency responders in our community. Important process parameters are also documented and maintained. Engineering design documents include 1) safe operating limits, 2) block flow or simplified process flow diagrams, 3) process chemistry, 4) maximum intended inventories, 5) process equipment and pressure relief system design basis and configuration, 6) safety systems such as interlocks and suppression systems, 7) piping and instrumentation diagrams, 8) documentation on design codes and standards employed, and 9) other information that is important for understanding the design intent, operating limits, and hazards of each process. 4.2 Process Hazard Analysis The Vulcan-Wichita plant has a comprehensive program for ensuring that the hazards associated with our processes are identified and controlled. Each process is examined in detail to ensure that all hazards are identified and that appropriate controls are in place to manage those hazards. Our hazard assessments focus on preventing incidents, accidents, and injuries to plant personnel and community, and on preventing adverse impacts to the environment. A hazard and operability (HAZOP) analysis is typically used for our process hazard analyses. A team comprising personnel with engineering, process and operations experience systematically examines each hazard in each section of the process including looking at previous incidents with catastrophic potential, and identifies potential causes and a range of possible consequences, including possible health and safety effects. The team then compares the h azard to the existing set of engineering and administrative prevention and mitigation measures designed to contain that hazard, making further recommendations when deemed necessary. These recommendations are resolved by management and are tracked until they are implemented. We update and revalidate each process hazard analysis every five years. The results and findings from these revalidation studies are documented and retained, and recommendations are tracked until resolved by management. 4.3 Operating Procedures Our engineers, operators, and supervisors work together to develop and maintain technically accurate operating procedures that provide clear instructions to our operators to ensure the safe operation of our facility. These procedures cover all modes of operation, such as 1) initial startup of a new or improved process, 2) normal operations, 3) temporary operations, 4) emergency shutdown due to loss of utilities or feed, 5) normal shutdown, and 6) emergency operations. Operating procedures are used as a reference by experienced employees and provide a consistent basis for training new employees. In addition to describing the steps for safely conducting operations, the procedures also contain valuable information about safe upper and lower limits for operating parameters such as temperature, pressure, flows and compositions, consequences of deviating from the safe limits, applicable safety and health information, procedures for preparing equipment for maintenance, and list safety systems such as pressure relief devices, rupture discs, scrubbers, and fire protection systems. Operating procedures are annually certified as accurate to ensure that they are updated following process changes. 4.4 Training The Vulcan-Wichita plant trains workers to safely and effectively perform their tasks. Both class-room and on-the-job training is provided. Employees who are new to a process are given basic training that includes 1) a general overview of the proce ss, 2) the properties of the substances used in the process and their associated safety and health hazards, 3) safe work practices, and 4) a detailed review of the operating procedures for that process. Once they have demonstrated their understanding of this initial training, they are paired with an experienced operator to learn their specific job functions and tasks. After they demonstrate their competence in performing these tasks, they are allowed to work independently. Through oral reviews, written tests, and on-the-job demonstration, we ensure that our employees understand the training given to them. The frequency of refresher training is decided, in part, by our employees but is performed at least every three years. All training given to an employee is documented, along with the means used to verify that the training is understood. 4.5 Mechanical Training The Vulcan-Wichita plant maintains the mechanical integrity of our equipment to prevent equipment failures that could endanger workers, the public, or the environment. Preventive and predictive maintenance practices keep equipment in good working condition and warn operators and maintenance personnel of problems, allowing proactive repairs to be completed. Preventive measures taken include proper materials of construction (e.g., to prevent corrosion, much of the piping in certain sections of our plant is monel, Teflon-lined or fiberglass rather than carbon steel), use of double-seal pumps in organic chemical service, and use of water treatment chemicals that will minimize corrosion of process equipment such as heat exchangers. Predictive maintenance technologies employed include vibration analysis, thermography, ultrasonic and oil analysis. Vibration analysis is used for early detection of bearing problems on pumps, compressors, fans and motors. Thermography is used to locate problems on electrical equipment. Ultrasonic technology uses sound waves to determine the thickness of tank walls and pip ing. Oil analysis is a chemical evaluation of oil samples that help determine the condition of mechanical and electrical equipment. Our inspection and testing program helps identify equipment damage or deterioration before the equipment fails. When a defciency is found, maintenance personnel correct the problem and try to identify the root causes of the deficiency so that future problems are avoided. Our quality assurance system ensures that new or replacement equipment meets the strict design standards required for service in our facility. The mechanical integrity system includes 1) inspection and testing procedures and implementation of these procedures on a regular schedule, 2) replacement equipment specifications, 3) procedures for safe work practices, 4) maintenance procedures for various equipment, 5) maintenance personnel training, and 5) required documentation. 4.6 Management of Change We review any changes to our processes to determine if new hazards are introduced or existing prevention measures are threatened. Except for replacements-in-kind (e.g., replacing a valve with an identical valve), all changes are subjected to a hazard analysis to ensure that 1) new hazards are not inadvertently introduced into the system, 2) safety consequences resulting from the change are addressed, 3) operators in the process are notified of the change and made aware of possible repercussions, and 4) all training material, process safety information, and operating procedures are updated. The management of change system applies to changes in the chemicals used, process equipment, technology, procedures, and other facility changes. 4.7 Pre-Startup Review The Vulcan-Wichita plant performs a pre-startup safety review for all new facilities or whenever a change at an existing facility occurs that requires updating the process safety information. This review ensures that safety features, procedures, personnel, and the equipment are prepared for service before the proc ess is restarted. A pre-startup review will generally include field verification of new construction and also serves a quality assurance function by verifying that accident prevention measures are implemented correctly. Generally, a pre-startup review will ensure that 1) construction and equipment are consistent with design standards, 2) adequate operating, safety, emergency and maintenance procedures are in place, 3) training for all affected employees is complete, and 4) process hazard analysis recommendations have been addressed and actions required for start-up have been completed. 4.8 Incident Investigation The Vulcan-Wichita plant investigates each incident that resulted in, or could have resulted in, serious injury to employees, the public, or the environment. Incident investigations are designed to determine the facts, identify the root causes, and provide recommendations for ensuring that the incident does not recur. Corrective actions resulting from an incident investi gation are tracked until they are resolved. Some examples of changes made as a result of incident investigations include limiting inventory of hazardous chemicals in storage tanks, developing new procedures or revising old ones, changing equipment construction material so it is compatible with process chemistry, expanding our reliability group's efforts under the mechanical integrity program, automation of a process using Distributed Control System (DCS) to allow safe shutdown of a process, requiring operators to perform additional monitoring and to document details of product transfers to tanks, use of nitrogen pad in tanks storing flammable materials, and additional training of operators. 4.9 Employee Participation The Vulcan-Wichita plant encourages employees to be involved in every aspect of process safety management and accident prevention. Employees are routinely asked to participate in process hazard analyses, incident investigations, management of change hazard analyses, a nd all other aspects of the prevention program. Employees have access to all information developed as part of the prevention program, and are specifically informed of any changes that occur in their process areas. The various ways employees are involved in the prevention program are documented in a written plan. 4.10 Safe Work Practices The Vulcan-Wichita plant has established safe work practices that ensure the safety of our employees and that of our contractors. Examples of these procedures include 1) a hot work permit that is designed to control spark- or flame-producing activities, 2) a permit and procedure to control confined space entry, 3) a lockout/tagout procedure for isolating energy sources during maintenance, and 4) procedures for preparing an equipment for maintenance. These procedures and permits along with personnel training ensure that operations and maintenance activities are performed safely. 4.11 Contractors The Vulcan-Wichita plant uses contractors for var ious activities, such as maintenance and construction. All contractors are evaluated to ensure that they are well trained and are able to perform their job function in a safe manner. A contractor's safety record and performance are reviewed during the selection process. Once a contractor is selected, the Vulcan-Wichita plant provides training and procedures to ensure that contractor employees 1) perform their work in a safe manner, 2) are aware of the hazards associated with the area in which they will be working, 3) understand the emergency response procedures, and 4) report any hazards they find during their work. Our personnel periodically monitor contractor activities to ensure they are performing their work in a safe manner. 4.12 Compliance Audits A compliance audit is performed periodically to help ensure that the prevention program activities at our facility are adequate and that safety issues are addressed effectively. Audits are performed by a team that is knowledgeabl e in our processes, but is independent of our facility, to ensure a thorough and complete evaluation. The audit team systematically evaluates each aspect of the prevention program, ensuring both compliance with the RMP rule and effective hazard prevention. The results of audits are documented, and recommendations are tracked until they are resolved. Compliance audits are conducted at least every three years. 5.0 CHEMICAL-SPECIFIC PREVENTION STEPS The prevention program described previously ensures the safe operation of our facility by providing our employees with a system they can use to safely perform their job functions. This management system helps prevent hazards associated with equipment failures and human error. In addition to the prevention program, the Vulcan-Wichita plant has safety features built into the design of our facility that help to ensure safe process operation for our employees, the public, and the environment. These features may contain or control a releas e, detect a release, or reduce the consequences of a release. They may also prevent a release by providing strict design standards for process equipment. The following types of safety features are used in various processes in our facility. 5.1 Release Detection a) On-line vinyl chloride detectors in areas where vinyl chloride is used or stored b) Releases are detected quickly because at least one operator is present at each plant at all times and operators inspect their plants on a routine schedule c) Video surveillance of the loading/unloading areas d) Procedures require that a Vulcan-Wichita plant employee be present during loading and unloading operations e) Hand-held monitoring equipment such as draeger tubes are used as needed for release detection 5.2 Release Containment and Control a) Breather valves on storage tanks discharge to a thermal oxidizer to capture and incinerate material released b) Some pressure relief valves discharge to scrubbers where the stream is neutralized before venting to the atmosphere c) Valves to permit isolation of a process where a release has occurred d) Excess flow valves or check valves on chlorine lines, methyl chloride lines, and in certain tanks to limit the amount of material released e) Automatic shutoff system on in-plant chlorine transfer pipeline limits the amount released in case of a pipe rupture f) Automated shutdown systems for some process parameters (e.g., high level, high or low pressure, high temperature) g) Manual shutdown systems located in control rooms h) Diked areas designed to contain a spill i) Pressure relief valves and rupture disks that discharge safely to the atmosphere. In our chloromethanes plant, valves downstream of rupture discs close automatically within a few seconds, minimizing the amount of organics released to the atmosphere j) Corrosion probes are installed in vessels containing corrosive materials. These probes provide online corrosion monitoring information which is used to schedule maintenance activities on a vessel, preventing vessel failure. 5.3 Release Mitigation a) Automatic fire suppression equipment at plant areas where flammable materials are stored or manufactured and at cooling towers. Fire extinguishers are located within easy reach of all plant areas. b) Trained emergency response personnel c) Spill control equipment is maintained onsite for containment and cleanup of spils d) PPE (such as protective clothing, self-contained breathing appratus) is kept in all control rooms. In addition, all personnel are issued PPE they need to do their job safely 6.0 FIVE-YEAR ACCIDENT HISTORY Our five-year accident history shows continued improvement in safe operations at our facility. The number of accidental chemical releases has generally been decreasing over the last five years, from 21 CERCLA reportable quantity (RQ) releases in 1993, of RMP regulated chemicals from RMP regulated processes, to 15 in 1998. Our OSHA 200 log recordab le injuries have also decreased from 26 in 1993 to 7 in 1998. None of these incidents resulted in offsite effects. None of the reportable chemical releases and OSHA recordable injuries over the last 5 years meet the RMP criteria for reporting accidental releases. One of the reasons for our improved safety record is that we conduct incident investigations to identify and correct the root causes of the events. Some of the improvements made as a result of these investigations include retraining of operators in standard operating procedures, process changes, new process controls, and installation of improved/upgraded equipment. 7.0 EMERGENCY RESPONSE PROGRAM The Vulcan-Wichita plant maintains a written emergency response plan that is designed to protect employees, the public, and the environment. The procedures include all aspects of emergency response, including proper first-aid and other medical procedures, the use of emergency equipment, the use of PPE, evacuation plans, account ability procedures, responsibilities of onsite personnel, and community emergency response notification procedures. Procedures for maintaining emergency response equipment are also contained in the emergency response plan. Employees receive periodic training in the duties they are expected to perform during an emergency. Affected employees are notified of any change in the emergency response plan. The emergency response plan is coordinated with local emergency responders so that they are aware of the hazards of our processes. We conduct annual Community Awareness and Emergency Response (CAER) and table top drills with the fire department, emergency medical services, 911, county disaster management and the sheriff department. We have annual orientation sessions for new members of these outside response agencies. We also actively participate in the local emergency planning commission (LEPC) meetings. Communication channels with local responders are kept open 24-hours per day. Th is coordination and communication ensures that the public is quickly notified, if necessary, and that action is promptly taken to minimize the consequences of a release. As indicated in Section 1.0, our SAFER and CAN systems allow us to quickly identify if residents and industrial complexes surrounding the plant will be impacted by a release, and to notify the affected population of the actions to take. 8.0 PLANNED CHANGES TO IMPROVE SAFETY As described in Sections 4 and 5 of this Executive Summary, the Vulcan-Wichita plant has implemented various programs to improve the safety of our processes and will continue to do so in the future. Suggestions for improving safety are regularly addressed through process hazard analysis, management of change procedures, incident investigations and employee suggestions. The following changes are currently planned or have recently been completed: a) Additional check valves will be added to limit the chemical quantity released from line failure s b) Additional pressure relief devices will be added or existing pressure relief devices on vessels will be upgraded to provide adequate protection against rupture c) Additional flow transmitters and back-up instrumentation will be added to provide more monitoring information to operators d) Additional alarms have been added on operator screens to alert an operator of upset conditions e) Upgrades to scrubber systems for neutralizing released chemicals and addition of online detectors on scrubber stacks are planned f) Specific safety and chemical release prevention topics are covered in monthly safety meetings to raise employee awareness. Topics are selected after reviewing safety and release incident investigation recommendations or employee suggestions In addition, Vulcan has implemented a comprehensive Year 2000 program that addresses all aspects of computer, microprocessor and software use throughout the company's business and industrial operations. At the Wichita Plant, t he Year 2000 program addresses computers, microprocessors and software controlling operations of the plant. |