Flexsys Nitro Plant - Executive Summary |
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Flexsys Nitro Plant Risk Management Plan Executive Summary ***Accidental Release Prevention and Emergency Response Policies At the Flexsys Nitro plant, our environmental, safety, and health policy is based on the principle that excellence in these areas maximizes the long-term value that Flexsys brings to our employees, our communities, our customers, and our shareholders. We ensure our leadership through concern for those values in our strategies, plant design and process, and products. Our corporate policy is that we will maintain strict compliance with the laws of the countries in which we operate, and manage our products and our plants to meet Responsible Care principles. The bases of our operating philosophy are: We will be recognized leaders in our industry in the development and implementation of ever safer, cost effective, products and processes, that have value to o ur customers. We will create the right environment to avoid all injuries and health risks to our employees and contractors, through safe design, training, and enforcement of safe work practices. We will have a positive impact on our communities through stringent control of emissions and partnerships with the community on awareness and emergency preparedness. Flexsys' commitment to these principals is evidenced in it's development of a process which was one of six 1998 recipients of the US EPA's Presidential Green Chemistry Award. That process eliminated 95 percent of the waste created by the former process and completely eliminated the use of chlorine. In ongoing implementation of the above philosophy, we use a combination of accidental release prevention programs, emergency response, and community outreach. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented. ***Facility and Regulated Substances Flexs ys is the world's largest producer of chemicals for rubber processing and related industries. Almost anything made of rubber contains Flexsys chemicals. Our products help cure and protect rubber, increase its durability and fatigue life, control color, and provide heat resistance. They are used in automotive, truck, and aircraft tires, as well as products ranging from hoses to footwear and rubber bands. Other Flexsys products are used in production of corrosion inhibitors, water treatment agents, mining chemicals, bactericides, fungicides, and antifreeze. Additionally, products are produced that are used in manufacture of fuel additives, paints, coatings, and adhesives. Still another is added to animal feeds to preserve quality. In manufacture of some of these products we use the following chemicals that EPA has regulated under the Risk Management Plan (RMPlan). Four are listed as toxics under that rule; one contains a listed flammable. - 360,000 lbs is the maximum inventory o f chlorine stored and in-use in manufacture of sulfenamides, one of our types of rubber chemicals. - 16,000 lbs of anhydrous ammonia is used in the central refrigeration system that provides cooling for some plant processes. - 430,000 lbs of carbon disulfide is stored for use in the manufacture of mercaptobenzothiazole (MBT). MBT is further processed into rubber chemicals. - 320,000 lbs of cyclohexylamine is sometimes on site, as needed, for use in manufacture of one of our sulfenamides. - 200,000 lbs of isoamylene is sometimes on site, as needed, for use in manufacture of Santovar TAHQ, another rubber chemical. Isoamylene contains approximately 8% 2-methyl-1-butene, which is a listed flammable under the RMP rule. Flexsys' accidental release prevention programs and our contingency planning efforts help us to effectively manage the hazards associated with use of these chemicals. ***Worst Case and Alternative Release Scenarios Our facility is required by the RMP rule to re port two worst case release scenarios and five alternative case scenarios. Toxic endpoints were developed by use of RMP Comp 1.06, and may be found in sections 2 and 3 of our RMPlan. Flammable endpoints were developed using equations in the EPA Offsite Consequence Analysis Guidance and RMP Comp 1.06, and may be found in sections 4 and 5. All cases outlined reach off-site, although, in some cases, it was necessary to assume multiple significant failures in order for that to be the case. Although the cases described are highly unlikely, we felt that the approach of choosing more severe cases would be most useful in evaluating and improving emergency response and emergency preparedness. The following are brief summaries of these scenarios, including key controls and mitigation measures that limit consequences of the potential releases. This information developed during this analysis is being used as a tool to help ensure that safeguards and emergency response plans address conceivab le release cases and scenarios. Worst Case Release Scenario - Chlorine: The worst case presumes catastrophic failure of a full chlorine railcar, resulting in release of its 180,000 lbs in 10 minutes. No mitigation measures were considered in analysis of this scenario. To reduce possibility of such an event, chlorine is handled in dedicated chlorine tank cars, which are designed to Chlorine Institute standards, including double walls with padding between. Additionally, our cars are placed at the end of rail spurs and piping is minimized by location of the process equipment adjacent to the rail facility. Worst Case Release Scenario - Isoamylene (2-methyl-1-butene) The worst case presumes catastrophic failure of a full isoamylene railcar, resulting in release of its 160,000 lbs. The entire volume volatilizes within 10 minutes and ignites in a vapor cloud explosion. To reduce possibility of such an event, railcars are designed to DOT standards, and are spotted with derails and war ning signs. Alternative Release Scenario - Chlorine: Our alternative release scenario for chlorine models a leak in the discharge line from the tank car. The hole is as large as it can be without causing the excess flow check valve to seat. Approximate hole size for this to occur is 0.3 inches. This scenario was selected since it is the worst case we could envision with the myriad of safeguards that are in place. The likelihood of a release of this type is low due to process safety management efforts at the facility, including piping location and mechanical integrity. Effects of a release would be limited by other factors including the extensive network of continuous area monitors that would detect and alarm the presence of chlorine. Key operating personnel and emergency responders would be alerted within minutes of the beginning of the release. The highly trained 24-hour emergency response team would then respond quickly to use the chlorine kit C, stored permanently on the ra il car dock, and seal the leak at approximately 30 minutes. Water spray would be used to further reduce vapor spread. (credit was not taken for that mitigation in modeling the scenario) Alternative Release Scenario - Anhydrous Ammonia: The alternative release scenario for ammonia assumes failure in the piping off the bottom of one of the high pressure receivers, resulting in an effective release diameter of 0.5 inches. As in the chlorine case, location of equipment, mechanical integrity, and commissioning procedures contribute to a low likelihood of a release of this severity. Size of the release would be limited by response to continuous area monitors, which would alert operations within minutes. A remote isolation button would be used to limit influx of additional ammonia from the system. The emergency response team would assemble, but would be unable to accomplish leak repair before the receiver contents would empty at about 12 minutes into the release. Responders would, ho wever, apply a water spray to reduce vapors. Credit for the water spray mitigation was not used in calculating spread of the cloud. Alternative Release Scenario - Carbon Disulfide: The alternative release scenario for carbon disulfide presumes that, while feeding material from the storage tank to the weigh tank, a leak develops. This leak is not noticed until the back-up timer alerts operations that the weigh tank has not filled as expected. Investigating the alarm, the operator shuts off the pump at 20 minutes, ending the release. As in the other cases, responders would assemble, but no further credit was taken for mitigation. Alternative Release Scenario - Cyclohexylamine Our next scenario assumes that, during feed from the cyclohexylamine storage tank into the reaction vessel, a failure occurs that is as large as possible without engaging the low flow alarm. This means that some flow continues to the reactor while some is spilled to the ground. An assumption is made that n o one notices the release or the delay in batch feed until the total batch feed is counted and the feed thereby automatically stopped, at about 45 minutes. No further credit was taken for mitigation activities, which would occur once the release was identified. Alternative Release Scenario - Isoamylene (2-methyl-1-butene) Our final alternative scenario assumes that, during unloading of a railcar, the unloading line ruptures. The facility is equipped with a remotely operated emergency valve and is monitored by an unloading technician. The unloader would quickly realize the problem and use the valve to isolate the car and stop further release. This would take no more than 10 minutes. The vapor cloud formed from the release is assumed to find an ignition source and result in a vapor cloud fire. ***General Accidental Release Prevention Program and Chemical-Specific Prevention Steps We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: - Process Safety Information - Process Hazard Analyses - Operating Procedures - Training - Mechanical Integrity - Management of Change - Pre-startup Reviews - Compliance Audits - Incident Investigation - Employee Participation - Permit Procedures - Contractor Safety Much of our facility is subject to OSHA PSM. We use back-up and redundant systems, and have interlock guidelines to define where additional layers of protection are prudent. These items apply plantwide. In addition, we have some prevention steps particular to specific chemicals and/or systems, outlined here: Chlorine - Excess flow check valves limit the size of potential releases from discharge piping. - Commissioning procedures insure internals are dry before chemical introduction. - Continuous area monitors provide early warning of any system emission. - Piping is minimized from storage to point of c onversion. - Process automation, alarms, and interlocks monitor and provide early warning of unusual conditions. Anhydrous Ammonia - Relief devices relieve into a scrubbing system. - Continuous area monitors provide early warning of system emissions. - Inventory has been reduced and the system centralized to minimize piping. - The area is curbed. - Process automation, alarms, and interlocks monitor and provide early warning of unusual conditions. Carbon Disulfide - Storage tank is diked. - Storage tank is water padded for containment and fire protection. - The process area is deluge protected. - Process automation, alarms, and interlocks monitor and provide early warning of unusual conditions. Cyclohexylamine - The storage tank is diked. - Inerting systems are used on vessels with flammable contents. - The process area is deluge protected. - Process automation, alarms, and interlocks monitor and provide early warning of unusual conditions. Isoamylene (2-methyl-1-bu tene) - The storage tank is diked. - Inerting systems are used on vessels with flammable contents. - The process area is sprinkler protected. - Process alarms and interlocks monitor and provide early warning of unusual conditions. ***Five Year Accident History We keep records for all significant accidental chemical releases that occur at our facility. Following is a brief summary of incidents meeting the RMP reporting criteria during the last five years. There have been no incidents meeting the RMP reporting criteria during the past five years for the following covered chemicals: Chlorine, Anhydrous Ammonia, Carbon Disulfide, Isoamylene (2-methyl-1-butene). Cyclohexylamine - There have been three RMP reportable accidental releases involving cyclohexylamine at the facility in the past 5 years. Each was a small leak that resulted in a small chemical burn to a Flexsys employee. All involved individuals recovered quickly and completely. None were of a reportable quantity, nor did they have any offsite impact. All occurred in 1995 and were repaired. No further incidents have occurred. ***The Emergency Response Program The Flexsys Nitro Plant maintains a comprehensive emergency preparedness plan that is integrated with the Kanawha/Putnam Emergency Planning Committee (KPEPC) and local response organizations. The plan is designed to provide immediate notification to plant personnel as well as the community in the event of an emergency. The plan may be activated by anyone within the facility that discovers an emergency condition. Communication and alarm systems are tested on a weekly basis to ensure proper functioning. The plant's Emergency Response Team (ERT) provides around the clock protection and is staffed by plantwide volunteers. Training for ERT members is conducted both within the plant by plant personnel and at specially designed schools such as West Virginia University and South Carolina Fire Academy. Each member of the ERT receives 32 hours of training per year including: Hazwoper (Technician Level), Interior Structural Firefighting, and First Aid/CPR. The plant is equipped with a hazardous material vehicle and a fire truck capable of pumping water at 750 gpm. In addition, fixed fire protection is strategically placed throughout the plant and is supported by 1 million gallons of on-site water storage. During emergency situations, an Emergency Operations Center (EOC) is activated. The EOC is staffed by two trained security officers who are responsible for coordinating internal and external communications during the emergency. A Crisis Management team (CMT) supports the EOC if activated. Training for plant personnel on the emergency response plan occurs on an annual basis. Employee responsibilities described by the plan include: reporting of emergency conditions, headcount procedures, and evacuation plans. Drills are held periodically for training of community/plant responders and plant personnel. ***Planned Ch anges to Improve Safety At the Flexsys Nitro Plant, we are continuously looking for ways to improve the safety of our facilities and processes. An example is the ammonia system, which was constructed and started up in 1998. Its construction reduced ammonia inventory by more than half and added many additional safeguards. In the area of the processes handling Chlorine, Carbon Disulfide, and Cyclohexylamine, two teams have been formed to look for and implement improvements. A multidisciplinary team met to discuss opportunities across the unit for prioritization and resourcing. Another team arose from that group's efforts and is engaged in efforts to improve training across the unit. One project example is an upgrade to the current continuous chlorine gas detection monitors. This project is currently in construction. In the area where Isoamylene (2-methyl-1-butene) is used, plans are underway to upgrade the sprinkler system to deluge. Additionally, a new control room and instr umentation upgrade project is being evaluated. In the area of emergency preparedness, utilization of the county telephone ringdown system is under development in order to enhance timely communications with plant neighbors. |