PPG Industries - La Porte Plant - Executive Summary |
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EXECUTIVE SUMMARY PPG Industries, Inc. - La Porte, TX The Environment, Health and Safety Policy of PPG is "to manufacture, sell, and distribute products worldwide in a manner that is safe and protective of our employees, neighbors, customers and other stakeholders, and the environment." In fulfilling this policy, PPG has made a commitment to follow several guiding principles including: 7 providing a safe and healthful workplace for our employees; 7 operating our facilities so as to prevent harm to public health and the environment; 7 assuring that PPG products can be produced, distributed, used, and disposed of safely; alerting potentially affected persons to known or reasonably foreseeable hazards of our products and activities and informing them about proper protective measures; 7 contributing to the public's understanding and management of any significant risks arising from our products or activities; 7 training, equipping and supporting all employees in the management and im plementation of environment, health and safety activities at our facilities; and 7 complying with applicable laws and regulations concerning environment, health and safety. PPG is committed to the Responsible Care voluntary initiative for safe management of chemicals. PPG follows the Responsible Care Codes of Management Practice which are integral to the implementation of the PPG Environment, Health & Safety Policy. The Responsible Care Community Awareness Code of Management Practice and PPG's Community Awareness and Emergency Response (CAER) Policy are designed to assure emergency preparedness and to foster community right-to-know. PPG's CAER Policy requires each manufacturing plant to have a pro-active community awareness and emergency response program to handle emergencies that might happen in that facility. Our community awareness programs include: emergency response plans; making Material Safety Data Sheets available to the appropriate police department, fire departme nt, hospital emergency medical services and other appropriate services; open house programs; periodic dry runs or drills to test the emergency response plans; and an annual review and test of the plans. The La Porte facility complies with corporate goals and maintains a safe work place and environment. This is accomplished by developing site specific programs that address EHS issues. These issues are addressed in management accountabilities to assure their effectiveness. The environmental department and safety department are examples of this commitment. Regulated substances handled. La Porte is part of the Specialty Chemicals Strategic Business Unit of PPG Industries, Inc.. La Porte produces alkyl chloroformates, organic acid chlorides, blocked amino acids, both phosgene and non-phosgene based pharmaceutical intermediates and bulk active compounds, and various single use specialty chemicals. The facility produces or stores chlorine, phosgene, methyl chloroformate, iso-propyl ch loroformate, and n-propyl chloroformate. Worst-case and alternative case release scenarios. An off-site consequence analysis was performed for the largest quantities of toxic materials in the facility. The guidelines and Offsite Consequence Analysis Guidance (OCAG) look-up tables were utilized in this process. EPA rules require that a worst case scenario be analyzed which would involve the highly unlikely release in ten minutes of the entire contents of the largest vessel or container. Based on dispersion modeling using OCAG look-up tables and the EPA specified assumptions, offsite concentrations of phosgene would cause offsite impact. Alternative case release scenarios (ACRS) were developed for each of the listed chemicals in the facility. These scenarios followed the guidelines provided by EPA and used the OCAG look-up tables to perform the end-point calculations. The local emergency planning committee and office of emergency planning will utilize the alternative case release scenario information in conjunction with PPG experts to develop an emergency response plan, train responders, perform practice drills and maintain the appropriate equipment. An alternative case release scenario was developed for chlorine, methyl chloroformate, iso-propyl chloroformate, and n-propyl chloroformate. These cases were as follows: 7 Chlorine - A small hole in a liquid chlorine feed line that was mitigated by the closure of automatic block valves. Evaluation from the ACRS showed an off-site impact. 7 Methyl chloroformate and n-propyl chloroformate - The failure of a 55-gallon drum of material that was mitigated by the use of an absorbent material. Evaluation from the ACRS showed an off-site impact. 7 Iso-propyl chloroformate - A release from a storage tank that was mitigated by the dike around the tank. Evaluation from the ACRS showed an off-site impact. General accidental release prevention program and chemical specific prevention steps. La Porte complies with OSHA's Process Safety Management Rule (29 CFR 1910.119), Texas and applicable EPA Regulations, and Department of Transportation Requirements. The facility is ISO 9002 certified. The facility has installed multi-point gas release detectors in the various production units and a fenceline gas release detection network. In addition, the site monitors more than 20,000 connections each quarter to detect fugitive emission sources. Trained personnel and environment, health and safety measures are included in all phases of the La Porte operation. Detailed engineering and design standards are used. These standards include national codes and standards, quality assurance inspections, over pressure protection systems, toxic gas detectors, emergency shutdown systems, a fire water system, and computer controls for the processes. Every individual in the facility receives appropriate training. Training may consist of an overview of the plant and safety signals that is given to visitors, a proce ss and hazards overview for contractors before they begin working in a unit, or a job-related training or testing for an operator or supervisor prior to assuming their duties. Training is an ongoing process that includes periodic retraining, as necessary. Safety, environmental, operating, and training procedures are subject to periodic reviews and updates, as appropriate. Additional systems are in place to review proposed changes and assure that any new training requirements are met. Another system assures a detailed review for hazards in each operating unit on a prescribed frequency. Training and updating procedures are monitored with multiple systems. The La Porte facility has an array of maintenance and inspection programs that minimize the possibility of equipment or piping failures. Routine inspections of equipment are done in the same manner as the initial quality assurance inspections completed prior to installation. Equipment inspections utilize procedures such as pr oof testing, where safeguard systems are forced to function in a controlled manner. This assures that the safeguards will function if they are ever needed. Preventive and predictive maintenance programs are utilized including, vibration monitoring, infrared images to detect differences in temperature, inspections by insurance specialists, and root-cause analysis procedures. Piping is inspected and tested with X-rays and hydrostatic tests prior to installation. The piping is monitored by methods such as visual inspections by the operators or maintenance personnel, emissions monitoring using sophisticated instruments, or thickness measurements by people trained in testing procedures. Maintenance personnel and supervisors are included in many of the training and testing programs that the operators utilize. Additional training and procedures have been developed for activities that are specific to maintenance. Although some of the training and testing is specific to maintenance, the s ame monitoring process is used. Five-year accident history. The La Porte plant has not had a release of a regulated chemical that meets the EPA's reporting guidelines in the past five years. Emergency response program. The La Porte plant has a written emergency response plan. The plan includes procedures for informing the public and emergency response organizations of an emergency condition; documentation of proper first aid and emergency medical treatment; and procedures and measures for emergency response. The plant's emergency response plan has been reviewed and coordinated with the City of La Porte's emergency response program. In addition, the plan is coordinated with the Channel Industries Mutual Aid plan. In addition to the written plan, La Porte's emergency response program includes a permanently installed fire protection system; mobile fire fighting equipment; a PlantSafe computer based gas dispersion modeling program; membership in the local area-wide industrial em ergency response organization; participation with the La Porte Local Emergency Planning Committee in coordinating emergency response plans and in planning and practicing emergency response drills Planned changes to improve safety. PPG is committed to the process of continuous improvement. This commitment extends beyond production issues into the environmental and safety aspects of all operations. Changes in control instruments are made on an ongoing basis, as necessary, to assure that the most reliable and effective controls are used. A fugitive emission collection system is being installed to reduce the possibility of a gas release leaving the plant site. For additional plant information, contact John A. Weihrich, Plant Manager, at 281-471-0943. For additional information about PPG Industries, Inc., see www.ppg.com. |