Witco Corporation Memphis Plant - Executive Summary

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                                          Witco Memphis Plant 
                       Risk Management Plan: Executive Summary 
1.0    Introduction and Background 
The Accidental Release Prevention (ARP) requirements mandated in Section 112( r) of the 1990 Clean Air Act Amendments were promulgated by the Environmental Protection Agency (EPA) on June 20, 1996.  The requirements are codified in 40 CFR 68, Subparts A through H.  Under the ARP Program, processes with chemical quantities on site exceeding the listed threshold quantities have applicable requirements. 
Witco Corporation manufactures fatty acids, emulsifiers, derivatives, amines and amides at its Memphis Plant.  Witco Memphis stores ammonia, a listed toxic substance, in excess of the threshold quantity in several storage tanks; thus the facility is subject to the ARP Program.  In addition, methyl chloride, a listed flammable substance, is stored in excess of the EPA's threshold quantity. 
The Witco Memphis Plant (WMP) has a l 
ong-standing commitment to worker and public safety.  This commitment is demonstrated by the resources invested in safety and environmental protection, employee safety training, safety in the design, installation, operation and maintenance of plant equipment.  In both Witco's written Safety and Environmental Policies, "Safety is unequivocally our number one priority".   WMP has implemented reasonable controls to prevent probable releases of hazardous chemicals. 
Should a release occur, trained personnel would respond to control and contain the release. 
1.1   Description of the Stationary Source and Regulated Substances 
Witco's Memphis Plant is an Oleo-Chemical processing facility located at 1231 Pope Street in Memphis, Tennessee.  The plant is situated on approximately 42+ acres in north Memphis.  The immediate area surrounding WMP are occupied by the Central Illinois Railroad to the North; several different warehouses to the East; a personal care / pharmaceutical Manufacturer to the 
South; and, a printing company and another chemical company to the West. 
Oleo-chemicals have been processed at this site since the late 1950s.  Witco's Memphis Plant makes a variety of Oleo-Chemical and Derivatives that are sold to the food, cosmetic, plastic, and rubber industries.  The facility is operated 24 hours per day, seven days per week.  Manufacturing activity at the site requires approximately 360 employees.  Plant manufacturing can be broken down into five areas: Enenco, Stearates, Derivatives, Northwest Processing and Northeast Processing.  Even during holiday periods, at least one salaried production leader and hourly chemical plant operators operate or maintain the plant. 
One of the major product lines operated within our Enenco Department is the Nitrile system.  Fatty acids are pumped from the tank farm and reacted with ammonia and catalyst to form nitriles.  An actual reaction of the ammonia is done under pressure in one of two process reactors.  Anhydrous ammonia i 
s supplied from a tank (D-11) that is administratively controlled to 47,000 pounds or less in capacity. 
Witco Memphis Plant was evaluated to determine if any regulated flammable or toxic substances exceeded the Environmental Protection Agency's (EPA) maximum of 10,000 pounds threshold quantity.  The WMP evaluation indicated that anhydrous ammonia would present the largest concern to the community in the unlikely event of an off-site excursion.  
2.0   Hazard Assessment 
2.1   Chemical Quantities and Processes 
The "List Rule" (see 40 CFR 68, Subpart F and Table 1 to '68.130) identifies threshold quantities for purposes of applicability to the ARP Program.  Based on process knowledge, Witco Memphis identified the regulated substances and the quantities stored on site.  The facility uses several regulated substances in many separate processes.  The chemicals, process unit, largest quantity on site and their threshold quantities are as follows: 
                           Table 1 
Chemical Name                    Process Unit           Largest Quantity         Threshold Quantity (lbs.)  
                                                                              On Site (lbs.)* 
Anhydrous Ammonia    Derivatives Department        71,900                            10,000 
Ethylene Diamine           Derivatives Department        42,000                            10,000 
Formaldehyde               Enenco Department              75,300                             10,000 
Hydrogen                      Northeast Processing             9,200                             10,000 
Methyl Chloride             Enenco Department             148,000                            10,000 
*Quantity on site refers to the largest quantity in a single storage unit. 
2.2        Offsite Consequence Analysis 
The ARP Program requires that one worst-case release be analyzed for all listed toxic substances and that one worst-case release be analyzed for al 
l listed flammables on site.  A realistic alternative release is analyzed for each regulated toxic substance and one alternative release is analyzed for all flammable substances.   Witco Memphis Plant (WMP) has identified ammonia, ethylene diamine, formaldehyde, hydrogen and methyl chloride as being stored on plant above the threshold quantities.  Hydrogen and methyl chloride are the two flammables evaluated for offsite consequence analysis.  The purpose of the worst and alternate case analysis is to determine the distance from the Witco Memphis Plant (WMP) to the toxic or flammable endpoints. 
The EPA has prepared lookup tables in the Risk Management Plan (RMP) Offsite Consequence Analysis Guidance for determining distances to the toxic and flammable endpoints.  In addition to the lookup tables, computer software which incorporates current knowledge on Chemical Release Modeling (CRM) was utilized to construct air dispersion models in order to estimate distances to endpoints for toxic  
and flammable substances. 
2.2.1              Worst-Case Releases 
The worst-case release is defined as "the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint"  Worst-case releases are also assumed to occur under the following circumstances: 
7 Total quantity released in ten minutes, 
7 Worst-case meteorological conditions including, 
1. wind speed of 1.5 meters per second 
2. 'F' atmospheric stability class 
3. three-year highest maximum daily temperature 
4. average relative humidity 
7 ground-level release height, and 
7 active mitigation systems fail, but passive mitigation remains. 
2.2.2        Toxic Substances 
Endpoints for toxic substances are based on the Emergency Response Planning Guideline level 2 (ERPG-2) developed for each substance by the American Industrial Hygiene Association.  Toxic endpoints are listed in Appendix A to 40 CFR Part 68 (Table of Toxic Endpoints). 
is contained as a liquefied gas.  Under the ARP Program  
['68.25( c) (1)], gases liquefied by pressure alone (i.e., without refrigeration) are released as gas over 10 minutes for worst-case purposes. 
Table 3 shows the calculation parameters and distances to toxic endpoints for ammonia based on the EPA lookup tables and the SAFER model.  The distance to the toxic endpoint is 6.5 miles as determined by the SAFER computer software and 1.2 miles on the EPA's look up Table 13. 
                                                                    Table 2 
                                  Largest Quantity of Regulated Toxic Substances 
Regulated Substance or Mixtures             Process Unit        Largest Quantity            Threshold Quantity 
Containing Regulated  Chemical                                                  On Site (lbs)                   (lbs)      
Anhydrous Ammonia                                   Nitrile Process            71,900                    
Ethylene Diamine                                        Bisamide Process       42,000                            10,000 
 Formaldehyde                                           Amine Process            75,300                            10,000 
 Methyl Chloride                                          Quat Process            148,000                            10,000 
                                                                         Table 3 
                                 Distances to Endpoints for Toxic Worst-Case Scenarios 
Chemical Name                                        Weight                                  Distance to Toxic Endpoints 
                                                               (pounds)                                              (miles) 
Anhydrous Ammonia                                 71,900                                                 6.5 
Ethylene Diamine                                        42,000            
Formaldehyde                                            75,300                                                 0.2 
Methyl Chloride                                        148,000                                                 1.8 
2.2.2            Flammable Substances 
For regulated flammable substances, the worst-case release is assumed to result in a vapor cloud containing the total quantity of the substance that could be released from a vessel or pipeline.  The entire quantity in the cloud is assumed to be between the upper and lower flammability limits of the substances.  For the worst-case consequence analysis, endpoint is an overpressure of one psi.  For the alternative release, a review of consequences resulting from a vapor cloud release of hydrogen as well as methyl chloride indicated that only methyl chloride would impact receptors off-site. 
Table 4 depicts the distances to the endpoint for the worse-case release of methyl  
chloride from the SAFER system. 
                                                                           Table 4 
                      Distances to Endpoints for Flammable / Explosive Worst-Case Scenarios 
Chemical                   Hypothetical Release    Mitigating       Largest Quantity      Distance to Overpressure 
                                 Scenario                        Measures     on Site (lbs.)              Endpoint (miles) 
Hydrogen                   Catastrophic failure       None               9,200                         0.81 miles 
                                  of liquid storage tank 
Based on worst-case analyses, the distances to endpoints [i.e., Emergency Response Planning Guideline level 2 (ERPG-2) as well as Immediately Dangerous to Life and Health (IDLH) concentrations], ammonia exceeds the distances to public receptors (i.e., off-site residences, institutions, industrial and commercial office buildings, parks, o 
r recreational areas inhabited or occupied by the public).  In addition to the EPA's Risk Management Plan (RMP), Witco's Memphis Plant is subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) regulations and is classified under SIC Code - 2869.  Therefore, Witco Memphis is classified as a Program 3 process under the Accidental Release Prevention (ARP) Program. 
1.2        Off-Site Consequence Analysis Results 
1.3.1  Worst-Case Releases 
Toxic Substances 
Endpoints for toxic substances are based on the ERPG-2.  Toxic endpoints are listed in Appendix A of 40 CFR Part 68 (Table of Toxic Endpoints).  The conditions at Witco Memphis Plant were studied to determine the distance to an endpoint for anhydrous ammonia. 
Table 5 shows the calculation parameter and distance to the toxic endpoint of  
6.5 miles derived by SAFER Systems TRACE version 8.0b computer software, which is less than the 8.7 miles for a worst-case release of anhyd 
rous ammonia based upon the EPA lookup tables.  Anhydrous ammonia is contained within a tank as a liquefied gas.  Under the ARP Program [' 68.25 (c) (1)], gases liquefied by pressure alone (i.e., without refrigeration) are released as a gas over 10 minutes for worst-case purposes.  Figure 2 shows the distance to the endpoint for anhydrous ammonia on a computer generated map. 
                                                                     Table 5 
                               Distances to Endpoints for Toxic Worst-Case Scenarios 
Chemical Name                               Weight  (pounds)             Distance to Toxic Endpoints  (miles) 
Anhydrous Ammonia                           71,900                                     6.5 
Flammable Substances 
Table 6 depicts the worst case scenario developed through calculations by SAFER Systems TRACE version 8.0b computer software for a large release of hydrogen from a full storage tank, due to a catastrophic fa 
ilure.  A vapor cloud containing 9,200 pounds of hydrogen is assumed to be ignited, resulting in a Vapor Cloud Explosion (VCE).  This would result in a 1-psi overpressure for the distance indicated in Table 6. 
                                                                 Table 6 
                    Distances to Endpoints for Flammable / Explosive Worst-Case Scenarios 
Chemical                 Hypothetical Release       Mitigating           Largest Quantity    Distance to Overpressure 
                               Scenario                           Measures          on Site (lbs.)          Endpoints (miles) 
Hydrogen               Catastrophic failure of      None                  9,200 lbs.               0.81 mile 
                               complete tank 
1.3.2  Alternative Releases 
Alternative release scenarios are those that are more likely to occur than the worst-case release scenario.  Alternative release scenarios for toxic substances shou 
ld be those that lead to concentrations above the endpoint beyond the facility's fenceline.  The following conditions are considered for alternative release scenarios: 
( Release rate dependent upon scenario; 
( Use of typical meteorological conditions at the stationary source; 
( Actual release height; and,  
( Consideration of active and passive mitigation systems. 
For the Witco Memphis facility, the most likely alternative release scenario would be a release of ammonia from a ground level relief valve on storage tank D-18.  The valve lifts and relieves ammonia at a rate of 380 lbs./min for five minutes.  Table 7 depicts the calculated parameters and distances to toxic endpoints for the alternative toxic release scenario. 
                                                                   Table 7 
                                              Alternative Case Release - Ammonia 
Chemical                           Release Scenario                                Mitigating Meas 
ures                Distance  
                                                                                                                                                    to Endpoint 
Anhydrous Ammonia       A ground level release of ammonia      A water spray system is         0.61mile 
                                         from a relief valve on storage tank       available to break up 
                                         D-18.  The valve lifts and relieves        the vapor cloud, but  
                                         ammonia at a rate of 380 lbs./min         not considered in 
                                         for 5-minutes.                                       the scenario.                                                 A single alternative release scenario for ALL flammable substances is provided in response to the General Duty Clause under the ARP Program.  The endpoint for a flammable substance for an alternative release scenario is either: 
Overpressure of one pound per square inch (psi) for vapor cloud explosions; or, 
( Radiant heat level of five kilowatts per square meter (kW/m2) for 40 seconds for heat from fires (or equivalent dose); or, 
( Lower flammability limit (LFL) as specified in National Fire Protection Association (NFPA) documents or other generally recognized sources. 
Table 8 shows the distance to the endpoint for the alternative-case release of hydrogen predicted using the SAFER Systems TRACE version 8.0b computer software. 
                                                                Table 8 
                                     Alternative Case Release for Hydrogen 
As set forth in the standard, an alternative case scenario is required for all flammables.   
Accordingly, a hypothetical release scenario has been identified for the Memphis Plant's hydrogen facility.  The most likely release of hydrogen would could from a relief valve discharge which vents due to fire exposure and relieves at a rate of  
100  pounds / minute for 5 minutes, at which time the operator snuffs out the fire with steam.   This scenario was calculated by the SAFER computer software and not any off-site impact  would be realized. 
Chemical Name                Amount Released           Release Rate                        Distance to Endpoint 
Hydrogen                              500 lbs.                    100 lbs. per minute                  701 Feet-NO offsite impact 
1.4     General Accidental Release Prevention Program 
The following is a summary of the accident prevention program in place at Witco's Memphis Plant.  All of the EPA RMP regulated processes at the facility are also subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard.  Accordingly, the following synopsis describes the management system implemented to address both requirements.  A more in depth description of each program element may be found in the corresponding chapters of the Memp 
his Plant's PSM/RMP written program. 
1.4.1   Employee Participation 
Witco Memphis encourages employees to participate in all facets of process safety and our accident prevention program.  Examples of employee participation including self-directed work teams assessing plant personal protective equipment requirements to participating as a member of a process hazard analysis (PHA) team.  Employees have access to all information created as part of the Witco Memphis accident prevention program.  Specific ways that employees can be involved in the accident prevention program include but are not limited to participation in the safety committee; root cause accident investigation, management of change meetings, and process hazard analysis of plant processes.   Chapter 1 of the Memphis Plant's PSM/RMP manual provides in depth detail regarding employee participation in the facility's compliance plan. 
1.4.2   Process Safety Information 
Witco Memphis Plant (WMP) maintains a variety of technical 
documents that are used to help maintain safe operation of the processes.  These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.  Each department following within the purview of the regulations is responsible for maintaining up-to-date process safety information. 
Chemical specific information, including exposure hazards; reactivity data; first aid; flash point; emergency response; and protective equipment recommendations are provided in material safety data sheets (MSDSs).  For manufacturing processes, Witco Memphis has documented safety-related limits for specific operating and temperature process parameters.  The plant insures that the process is maintained within these limits using state-of-the-art process controls, monitoring instruments, emergency relief devices, fire fighting water spray, highly trained personnel and emergency shutdown procedu 
The plant also maintains numerous technical documents that provide information about the design and construction of process equipment.  This information includes materials of construction, design pressure and temperature ratings, and electrical classification of equipment.  This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Chapter 2 of the Memphis Plant's PSM/RMP manual provides significantly more detail regarding the control of process hazards. 
1.4.3   Process Hazard Analysis 
Witco Memphis has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled.  Within this program, each new and altered process is systematically examined to identify hazards and ensure the adequate controls are  
in place to manage these hazards. 
Witco Memphis primarily uses the "What If" analysis technique to perform these evaluations.  What If analysis is recognized as one of the most systematic and thorough hazard evaluation techniques.  The analyses are conducted using a team of people who have operating, maintenance, environmental, safety and engineering expertise.  Each team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures.  Further, the PHA Team makes suggestions for additional minor safety, environmental and maintenance items for review by the responsible department head. 
The PHA Team findings are forwarded to local and corporate management for resolution.  Implementation of mitigation options in response to PHA findings is based on a relative risk / severity ranking assigned by the team.  This priority ranking helps ensure that probable accident scenarios assigned the highest risk and severity receive immediate attention.  All cat 
astrophic mitigation options in response to PHA team findings are tracked until they are completed.  The final resolution of each finding is documented and retained. 
To ensure that the process controls and / or process hazards do not deviate significantly from the original design safety features, Witco Memphis periodically updates and revalidates the hazard analysis results.  These periodic reviews are conducted at least every 5 years for covered processes and will be conducted at this frequency until the process is no longer operational.  The results and findings from these updates are documented and retained.  Once again, the team findings are ranked by severity and probability prior to forwarding to plant management for consideration. The final resolution of the findings is documented and retained. Chapter 3 of the Memphis Plant's PSM/RMP manual provides in depth detail regarding the scheduling and completion of the facility's PHA program. 
1.4.4   Operating Procedures 
Witco Me 
mphis maintains written procedures that address various modes of process operations, such as (1) process startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process.  These procedures are used as a reference by experienced operators and provide a basis for consistent training of new operators.  These procedures are periodically reviewed and certified as current and accurate as part of the review of the Process Safety Management review every 3 years.  The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the Management of Change Process.  These procedures are readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Chapter 4 of the Memphis Plant's PSM/RMP manual provides examples and significantly more detail pertaining to the facility's operating procedures program. 
.5   Training 
To complement the written procedures for process operations, Witco Memphis has implemented a comprehensive training program for all employees involved in operating a process.  New employees receive a basic safety orientation and are subsequently referred to a Unit Leader for departmental specific safety and job training.  After successfully completing this training, a new operator is paired with a senior operator to learn process specific duties and tasks.  After demonstrating process competency (e.g., through tests, skills, demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently.  In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level.  This refresher training is conducted at least annually.  All training is documented for each employee, including the means used to verify tha 
t the operator understood the training. Chapter 5 of the Memphis Plant's PSM/RMP manual provides greater detail pertaining the facility's PSM/RMP training program. 
1.4.6   Contractors   
Witco Memphis uses contractors to supplement its workforce during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the plant has developed a training manual for each OSHA/EPA covered process to ensure that contractors receive the necessary knowledge to work in the covered process area.  The Process Safety Overview training for personnel (Witco maintenance personnel and contractors) engaged in maintaining the process is conducted utilizing the aforementioned manuals.  The training is conducted to insure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand emergency procedures, (5) understand and comply with plant sa 
fety rules, and (6) inform plant personnel of any hazards that they incur during their work.  In addition to the Process Safety Manuals for each covered process, the trainer provides contractors with (1) a process overview, (2) information about safety, chemicals and process hazards, (3) site emergency plan requirements, and (4) safe work practices prior to their beginning work.  In addition, Witco Memphis evaluates contractor safety programs and performance prior to their beginning work.  Plant safety personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety and environmental obligations. Chapter 6 of the Memphis Plant's PSM/RMP manual provides in depth detail regarding the facility's contractor safety plan. 
1.4.7   Pre-startup Safety Reviews (PSSRs) 
Witco Memphis conducts a PSSR for any facility modification that   requires a change in the process safety information.  The purpose of the PSSR is to ensure that safety features, proc 
edures, personnel training, and equipment are appropriately prepared for startup prior to placing the equipment into service.  This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready.  The PSSR review team uses checklists to verify all aspects of readiness.  A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Chapter 7 of the Memphis Plant's PSM/RMP manual provides examples as well as detailed information regarding the facility's Pre-Startup Safety Review program. 
1.4.8   Mechanical Integrity 
Witco Memphis has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition.  The basic aspec 
ts of this program include:  1) conducting training, 2) developing written procedures, 3) performing inspections and tests, 4) correcting identified deficiencies, and 5) applying quality assurance measures.  In combination, these activities form a system that maintains the mechanical integrity of the facility's processes. 
Maintenance personnel receive training on 1) an overview of the process, 2) safety and health hazards, 3) applicable maintenance procedures, 4) emergency response plan, and 5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner.  Written procedures help ensure that work is performed in a consistent manner and provide a basis for training.  Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the eq 
uipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. 
Another integral part of the mechanical integrity program is quality assurance.  Witco Memphis incorporates quality assurance measures into equipment purchases and repairs.  This procedure ensures that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Chapter 8 of the Memphis Plant's PSM/RMP manual provides greater detail regarding the facility's on-going mechanical integrity program. 
1.4.9   Safe Work Practices 
Witco Memphis has long-standing safe work practices in place to help ensure worker and process safety.  Examples of these safety rules include 1) control of the entry/presence/exit of support personnel, 2) a lockout, tag, clear, test and try procedure to ensure isolation of energy sources for equipment undergo 
ing maintenance, 3) a linebreaking procedure for safe removal of hazardous substances before process piping or equipment is opened, 4) a hot work permit procedure to control heat/spark producing activities, 5) a confined space entry permit procedure to ensure that adequate precautions are in place before entry into a confined space, and 6) a pre-start-up safety review on each unit.  These procedures, in conjunction with site safety rules and training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Chapter 9 of the Memphis Plant's PSM/RMP manual provides more detail regarding the plant's safety permit (hot work, linebreaking, confined space entry) program. 
1.4.10  Management of Change 
Witco Memphis has a comprehensive system to manage changes to all processes.  This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other f 
acility changes be properly reviewed and authorized before being implemented.  Changes are reviewed to 1) ensure that adequate controls are in place to manage any new hazards and 2) verify that existing controls have not been compromised by the change.  Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes.  In addition, operating and maintenance personnel are provided any necessary training on the change. Chapter 1 of the Memphis Plant's PSM/RMP manual provides in depth detail regarding employee participation in the facility's compliance plan. Chapter 10 of the Memphis Plant's PSM/RMP manual provides a sample of the facility's MOC form and describes in greater detail exactly how the program functions. 
1.1.11   Incident Investigation 
Witco promptly investigates all incidents that result in or reasonably could have resulted in a fire/explosion, toxic gas release, major property damage 
, environmental loss, or personal injury.  The goal of each investigation is to determine the facts, root cause(s) and develop corrective actions to prevent a recurrence of the incident or a similar incident.  The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards their report to plant management for resolution.  Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete.  The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including  contractors) who could be affected by the findings.  Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Chapter 11 of the Memphis Plant's PSM/RMP manual provides a description of the facility's incident investigation policy and procedure. 
1.4.12   Compliance A 
To help ensure that the accident prevention program is functioning properly, Witco Corporation periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented.  Compliance audits are conducted at least every 3 years.  Both hourly and staff personnel participate as audit team members.  The audit team develops findings that are forwarded to the Plant PSM/RMP Committee for resolution.  Corrective actions taken in response to the audit team's findings are tracked until they are complete.  The final resolution of each finding is documented, and the two most recent audit reports are retained. Chapter 1 of the Memphis Plant's PSM/RMP manual provides in depth detail regarding employee participation in the facility's compliance plan. Chapter 13 of the Memphis Plant's PSM/RMP manual provides specific program elements pertaining to the Memphis facility's compliance audit  program. 
1.5   Chemical-Specific  
Prevention Steps 
The processes at Witco Memphis have hazards that must be manage to ensure continued safe operation.  The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. 
1.5.1   Universal Prevention Activities 
The accident prevent program summarized previously is applied to all processes and areas at the Memphis Plant.  Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. 
1.5.2   Specialized Safety Features 
Witco Memphis has safety devices on many units to help 1) contain/control a release, 2) quickly detect a release, and 3) mitigate the consequences of a release.  The following type of safety features are used in the covered processes: 
Release Containment / Control 
1. Process relief valves that prevent overpressurization and a subsquent discharge. 
2. Valves that permit isolation of th 
e process (manual or automated) 
3. Automated fog spray system to minimize ammonia cloud formation 
4. Check valves in piping to prevent free flow of hazardous materials 
Release Mitigation 
1. Fire extinguishers 
2. Fire monitor spray system for ammonia tank 
3. Use of offsite emergency response personnel located within 5 minutes of the site. 
4. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus) 
1.6   Five-Year Accident History 
Witco Memphis has not had any accidental releases during the past five years which meet the criteria for an accidental release as defined within 40 CFR 68.42. 
1.7   Emergency Response Program Information 
Witco Memphis maintains a written incident response plan, which is in place to protect worker and public safety as well as the environment during an emergency.  The plan consists of procedures for responding to a release of anhydrous ammonia, including the possibility of a fire, explosion or tornado.  The proc 
edures address all aspects of emergency response, including proper first aid and medial treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements.  In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment.  Employees receive training in these procedures as necessary to perform their specific emergency response duties.  The incident response plan is updated when necessary, based on modifications to plant processes and roadways. 
The overall emergency response program for Witco Memphis is coordinated with the Memphis Fire Department and Ferguson Harbors.  This coordination includes periodic meetings of Witco Memphis personnel and representatives of the local fire station to discuss needs and concerns in the event of an incident at the plant.  Witco M 
emphis has around-the-clock communications capability with the Memphis Fire Department who have the ability to communicate to all state, federal and county agencies as to needed equipment (i.e., fire fighting equipment, manpower, ambulances, hospitals, law enforcement and Hazmat operations).  In addition, Witco Memphis maintains an open contract with Ferguson Harbors to respond and remediate any environmental upsets.  Further, Witco Memphis has contributed to a chemical warning siren as a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.  Witco Memphis participates as requested in periodic emergency drills that involve the Local Emergency Planning Committee (LEPC) and the Memphis Fire Department. 
1.8   Planned Changes to Improve Safety 
Witco Memphis has several elements of the management system of the accident prevention program in place to improve safety throughout the facility.  These elements are part of an overall o 
ngoing safety improvement process.  The following elements of the PSM/RMP are used to improve safety 
7 Process Hazard Analysis (PHA) 
7 Management of Change (MOC) 
7 Compliance Audits 
1.9 Trade Secrets 
Witco Memphis developed this program (with involvement of the plant's management, technical staff and hourly employees) to ensure that Witco Memphis can make available all PSM / RMP information associated with the work of an employee or contractor without concern over trade secrets being disclosed to outsiders.  No facility process, equipment or technology information shall be withheld from employees, their representatives, or any other persons requiring access to such information based on trade secret status. 
Additional information is available with Section 14 of the facility's PSM / RMP manual. 
2.0 Release Modeling 
Witco Memphis purchased the SAFER Trace 8.0 Software system to model  releases of the chemicals on site.  Full detail of the requisite Worse Case and Alternate Case Sce 
narios for each chemical are setforth in full elsewhere within this submission of the facility's RMP Program.  The complete modeling results are setforth in Chapter 15 of the Plant's PSM / RMP manual.  Copies of the manual are available in the Safety and Environmental Department.
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