Occidental Chemical Corp. - Kenton facility - Executive Summary |
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EXECUTIVE SUMMARY Occidental Chemical Corporation (OxyChem), a wholly owned subsidiary of Occidental Petroleum Corporation (OPC), owns and operates a synthetic resin and molding compound manufacturing facility in Kenton, Ohio. This facility is known as the Kenton Plant and is located on State Route 68 South. The facility consists of two units. One manufactures phenolic resins and one manufactures molding compounds. The facility also conducts warehousing and shipping operations to support manufacturing. The facility was originally constructed in 1954 and employs approximately 170 full-time employees. 1. Accidental Release Prevention and Emergency Response Policies at the Stationary Source (' 68.155(a)): OxyChem is committed to operating the Kenton facility in a manner that is safe for its workers, the public and the environment. It is our policy to adhere to all applicable Federal, State and local rules and regulations, industry standards and best management practices. As par t of this commitment, OxyChem has established a system to help ensure safe operation of the processes at this facility, which includes the prevention of accidental releases of hazardous substances. One component of this system is a risk management program (RMP) that helps manage the risks at the Kenton facility and complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirement Risk Management Programs (the RMP rule). This document is intended to satisfy the RMP Plan requirement of the RMP rule. This also provides the public with a description of the risk management program at the Kenton facility. The RMP at the Kenton facility consists of the following three elements: 7 A hazard assessment program to help understand: (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances reg ulated by the RMP rule (regulated substances). The hazard assessment program includes Process Hazard Reviews (PHRs), PreStart-up Safety Reviews (PSSRs) and Management of Change (MOC). 7 A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes). The prevention programs incldes our Mechanical Integrity (MI), hot works, operating procedures, incident investigation and training (including contractors). 7 An emergency response program to help respond to accidental releases of substances, including materials from covered processes. Information further describing these elements is provided in this RMP Plan. Although the Risk Management Program at the Kenton facility helps provide assurance that the facility is maintained and operated in an enviromentally sound and safe manner, it is only one component of the environmental program at the Kenton facility. In fact, the Kenton facility has a c omprehensive environmental program in place, establishing many levels of safeguards against release of a hazardous substance, as well as injuries and damage from such a release. OxyChem limits the use of hazardous substances. Before using a hazardous substance at the Kenton facility, less hazardous alternatives are always considered. When a hazardous substance is used at the Kenton facility, OxyChem reviews the potential for an accidental release of this substance which could adversely affect plant workers, the public and the environment. Steps are taken to prevent any such effects through the facility's Chemical Pre-approval, MOC and PHR procedures, which are followed for all new processes or modifications of existing processes. OxyChem strives to prevent accidental releases of the hazardous substances used at the facility. OxyChem implements reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used at the Kenton facility, the equipment is carefully designed, installed, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction and operation of the equipment. OxyChem also uses the Corporate Fire, Safety and Environmental (FS&E) Guidelines when designing new or modifying existing processes. Each project is thoroughly reviewed in an MOC or PSSR (for all changes or new systems) before approval. These reviews inclue EHS, engineering, operations, maintenance and management personnel. In addition, OxyChem requires the documentation of standard operating procedures and training of affected employees (including call-ins) with regard to these procedures as part of the MOC procedure. OxyChem's mechanical integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances. OxyChem's goal is to minimize impacts from an accidental release. In the event of an accidental release, the Kenton facility controls and contains the release in a manner that will be safe for workers and will prevent impact to the public and the environment. OxyChem utilizes emergency response plans as required by government regulation. OxyChem trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs. The facility also maintains an active Emergency Response Team which is on call 24 hours a day to respond to an accidental release. OxyChem has established a Special Situations Center in the Dallas corporate office to assist in emergencies. In addition, OxyChem works with the Kenton City Fire Dept., 911 Review Board, BKP Ambulance Service, Kenton City Police Dept. and the Local Emergency Planning Commission (LEPC) to help prevent injuries and/or environmental damage if a release does occur. OxyChem is helping the LEPC write and implement the Hardin County Emergency Response Plan. The Kenton Facility's Emergency Response Plan has been developed to meet the emergency planning, response and notification requirements of all applicable regulations and OxyChem policies. This plan outlines the responsibilities and actions required to control an emergency. If the emergency extends beyond the facility boundaries and affects the surrounding community, the Hardin County Emergency Response Plan is initiated by a call to 911 and a statement of the type of emergency. OxyChem is an active participant in the community. OxyChem is an active participant in plant and community programs which promote education, safety and environmental awareness. We support activities of Keep Hardin County Beautiful, Household Hazardous Waste Collection, Arbor Day, Wildlife Federation and Earth Day. This is conducted by employees volunteering, cash donations and presentations to the community. The facility is implementing a Voluntary Protection Program (VPP) in which employee partici pation at all levels is required in designing, implementing and maintaining safety programs. OxyChem is an industry leader in the implementation of the Chemical Manufacturer's Association sponsored Responsible Care. Initiative. As part of OxyChem's Responsible Care. efforts, the Kenton facility has voluntarily established a Community Advisory Panel (CAP). The purpose of this group is to share information about plant operations with members of the community and to discuss community concerns. The group meets periodically and covers topics of interest to the members, including plant safety and environmental performance, emergency response programs, TRI reporting, process safety performance and RMP. Through this outreach effort, as well as other community involvement, the plant stays abreast of community concerns and works to address them. Over the past five years, the Kenton facility has received the following OxyChem environmental and safety awards: 7 OxyChem Corporate Environmental Merit Award - 1996 through 1998 7 Bronze Award for one year without a recordable safety incident - 1997 Although the Risk Management Program at the Kenton facility helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the environmental and safety programs. In fact, the Kenton facility has a comprehensive environmental and safety program in place establishing many levels of safeguards against release of a hazardous substance. In order to implement these policies effectively, OxyChem established a management system headed by the Health, Environment and Safety (HES) Department to oversee safety and environmental-related activities. This RMP Plan is primarily intended to describe those parts of the environmental and safety programs at the Kenton facility that are required by the RMP rule. 2. The Stationary Source and Regulated Substances Handled (' 68.155(b) ) The Kenton facility handles only one regulated substance that is covered by the RMP rule, as shown in the following list of RMP-covered Program Level 3 processes at the plant. Regulated Substance: Formalin (45% aqueous soln.) Process: Storage Tanks Quanity, lb.:840,000 solution RMP Threshold, lb.*: 10,000 * - Threshold quantity is the quantity of "pure" chemical, not of the solution Formalin is one of the major raw materials used at this facility. It is a solution of formaldehyde dissolved in water. No pressurized formaldehyde gas or liquified formaldehyde is used on-site. Formalin is stored in a 100,000 gallon aboveground storage tank with a recirculating distribution system to five reactors in two operating units. The finished material from the reactors only contains residual concentrations of formaldehyde, therefore, the storage tank, the recirulation loop and the reactors are the only RMP covered processes on-site. The facility complies with the Department of Transportation (DOT) regulations in the loading, unloading and shipm ent of materials. 3. The Worst-Case Release Scenario(s) and the Alternate Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario (' 68.155(c) ): The Kenton facility performed off-site consequence analysis to estimate the potential for accidental release of a regulated substance to affect the public or the environment. The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario " and an "alternative release scenario." In reality, however, OxyChem does not expect a worst-case release scenario to ever occur. A catastrophic event, such as earth quake or airplane crashing into the storage tank and no emergency response action would be required for this scenario to occur. The worst-case and alternative-case release scenario was developed to help OxyChem and local ER groups improve the community emergency response plan. Trinity Consultants were hired to model the scenarios for a formalin release, including the distance to the release endpoint (ERPG-2). The meteorological data used for the modeling was the EPA default for the worst case scenario and typical values in Kenton for the alternative release scenario. The EPA recommended Landview program was utilized to estimate the number of people living within this distance from the location of the storage tank. USGS and City school district maps were utilized to identify the public and environmental receptors located within this distance. The following information summarizes the off-site consequence analysis performed for the Kenton facility: 3.1 Toxic Substances - Formalin The "worst-case release scenario" modeled for formalin is the total failure of the Formalin Storage Tank, which would release 840,000 pounds of 45% formaldehyde solution instantaneously, as mandated by EPA. The reaction rate of formaldehyde to form solid paraformaldehyde and the evaporation rate were calculated by Trinity Consultan ts. Under the EPA default worst weather conditions, the formaldehyde would travel approximately 0.78 miles before the concentration of formaldehyde was reduced to below 1 ppm (which is the 'endpoint' established in the RMP rule). The U.S. Census indicates that 112 people live within this distance from the storage tank; The Hardin Co. Airport, residences, commercial facilities and one industrial facility are the only public receptor located within this distance. No sensitive environmental receptors are located within this distance. The "alternative case release scenario" is the failure of transfer hose while unloading a tanker truck into the storage tank, releasing approximately 500 lbs of formalin liquid in a 2-minute period. Trinity Consultants also modeled this alternative release scenarios to determine the off-site consequences, which showed that the formaldehyde would not leave the site before the formaldehyde concentration is below 1 ppm (which is the 'endpoint' value establ ished in the RMP rule). No people live within this distance from the tanker truck unloading area; no public receptors or environmental receptors are located within this distance. 3.2 Program 3 Processes-Flammable Substances There are no regulated flammable substances in quantities above the threshold quantities at the plant. Propane is stored on-site in 30 lb. cylinders, however, the total quantity is less than the threshold quantity of 10,000 pounds. 4. The General Accidental Release Prevention Program and the Specific Prevention Steps (' 68.155(d) ): Since 1994, the Kenton facility has used a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1994, the facility revised this prevention program to comply with the 14 elements of the OSHA Process Safety Management (PSM) prevention program. In 1996, the EPA RMP rule established two levels of prevention requirements. Of these, the Kenton facility falls under "Program 3". Program 3 is e ssentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment outside the plant's fenceline; The following sections briefly describe the elements of the Kenton facility's Program 3 prevention program that address EPA's RMP rule prevention program requirements. 4.1 Program 3 Prevention Program The Kenton facility's Program 3 prevention program consists of the following 12 elements: 4.1.1 Process Safety Information The Kenton facility maintains technical documents which are used to help ensure safe operation of the facility. These documents address: (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant and (3) design basis and configuration of the equipment at the plant. OxyChem ensures that this process safety information is available to all employees. Material safety data sheets (MSDSs) document the physical properties of the hazardous materials hand led at the plant, including regulated substances in covered processes. The information available for each hazardous substance typically includes: 7 Toxicity information and permissible exposure limits 7 Physical data (e.g., boiling point, melting point, flash point) 7 Reactivity and corrosivity data 7 Thermal and chemical stability data 7 Hazards of mixing substances in the process MSDSs for hazardous substances handled in each process are available from the plant's HES Department, the Supervisor's Trailer and the Security Desk. The engineering design documents include the operating parameters, the design basis and the configuration of the equipment in each covered process. The available information includes: 7 Operating parameters 7 Process flow diagrams 7 Process chemistry 7 Maximum intended inventories 7 Safe upper and lower limits for parameters such as temperature, pressure, or flow 7 Design basis and configuration of equipment 7 Piping and instrumentation diagrams, inclu ding materials of construction 7 Electrical classification 7 Safety systems 7 Applicable design codes and standards 7 Design basis for relief and ventilation systems Operating manuals contain the process objectives, process chemistry, overview of the process operations, critical process variables with consequences of deviations, equipment and instruments descriptions, troubleshooting guidelines, start-up and shut down procedures and equipment operating procedures. These documents are used to: (1) train employees, (2) perform process hazards analyses, (3) operate the processes and (4) help maintain equipment. 4.1.2 Process Hazard Review The Kenton facility performs and updates process hazard reviews (PHR's) once every five years for each covered process. This helps identify process hazards, corrective actions and preventive action to improve the safe operation of the process. A team composed of personnel with safety, environmental, engineering, process operation and maintenance ex perience and a leader with process hazard review experience is assembled to analyze the hazards of the process. The plant primarily uses the "HAZOP" technique to perform this analysis. The PHR team prepares a written report describing the results of the analysis, including a list of recommendations. Responsibility to resolve the recommendations is assigned to unit personnel and, when appropriate, changes to enhance the safety of the process are implemented. 4.1.3 Operating Procedures Kenton facility process engineers, operators and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. The operating procedures: (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: 7 Steps for safely conducting activities 7 Applicable process safety information, such as safe operat ing limits and consequences of process deviations 7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown and temporary operations. The operating procedures are used both to help in operating the plant's processes and as a training guide. 4.1.4 Training The Kenton facility trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training that covers: (1) a general overview of the process, (2) the properties and hazards of the substances in the process and (3) a detailed review of the process operating procedures and safe work practices. Oral reviews and written tests ar e used to verify that an employee understands the training material before the employee can work in the process. The operators are consulted regularly to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed and changes to the training program are implemented as appropriate. 4.1.5 Mechanical Integrity The Kenton facility maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public or the environment. The major aspects of the mechanical integrity program include: (1) an inspection and testing program for critical equipment to help identify deterioration and repair items before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes. The details of the mechanical integrity program include: 7 Specifications for inspection and testing of proce ss equipment 7 Specifications for replacement parts and equipment 7 Procedures for inspecting, testing and maintaining process equipment 7 Procedures for safe work practices such as Lock, Tag and Try; Hot Work; Confined Space Entry; and Line Breaking 7 Training of maintenance personnel 7 Documentation of maintenance activities 4.1.6 Management of Change The Kenton facility's management of change program evaluates and approves all proposed changes to chemicals, equipment and procedures for a covered process to help ensure that the change does not negatively affect safe operations. Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process s afety information and procedures are updated, and affected employees are notified of the changes. 4.1.7 Pre-startup Review The Kenton facility performs a pre-start-up safety review (PSSR) of a new process before the process is placed into service to help ensure that the process has been prepared to operate safely. This review confirms that: 7 Construction and equipment are in accordance with design specifications 7 Adequate environmental, safety, operating, maintenance and emergency procedures are in place 7 Employee training has been completed 7 For a covered process, a PHR has been performed if the process is new or management of change requirements have been completed if an existing process has been modified A PSSR checklist is completed for new processes to ensure that appropriate issues have been addressed. 4.1.8 Compliance Audit Both Occidental Petroleum Corporation and Occidental Chemical Corporation perform audits of the facility programs, processes and documentation a t regular intervals. The facility is required to address all action items within 6 months of notification. 4.1.9 Incident Investigation The Kenton facility investigates incidents, including near misses, that could reasonably have resulted in an injury to personnel, the public, the environment or property so that similar incidents can be prevented in the future. The plant trains employees to identify and report any incident. An investigation team is assembled and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved and appropriate process enhancements are implemented. OxyChem has a formal program, including training for incident investigations and report generation. 4.1.10 Employee Participation Employees from production and maintenance participate in technical analyses and PHR's for all covered processes to help ensure that the environmental and safety concerns of the plant's workers are add ressed. The plant encourages active participation of personnel in the prevention program activities of all processes at the plant. Employees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHRs, MOCs, PSSRs and operating procedures. 4.1.11 Hot Work Permits The Kenton facility established a hot work permit program to control spark or flame-producing activities that could result in fires or explosions in covered processes at the plant. The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The Shift Supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation and contractor orientation. 4.1.12 Contractors The Kenton facility establishe d a program to help ensure that contractor activities at the plant are performed in an environmentally sound and safe manner. The program reviews the safety record of all contractors to help ensure that the plant only hires contractors who can safely perform the desired job tasks. The plant explains to the contract supervisors the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant's emergency response procedures. The plant requires that the contractor supervisors train each of their employees who will work at the plant before that worker begins work at the plant site. The plant periodically reviews contractors' training documents. 4.2 Chemical-specific Prevention Steps In addition to the required prevention program elements, the Kenton facility has implemented safety features specific to the hazardous substances used at the site. For formalin, industry standards are followed at the plant to help ensure responsible m aterial use and handling. Formalin is supplied in DOT approved tank trucks. DOT standards are followed when loading formalin into its storage tank. The storage tank is designed in accordance with ANSI standards. Workers who perform operations involving formalin receive training emphasizing safe handling procedures, which are specific to the site. The formalin storage tank is surrounded by a concrete dike, which is large enough to contain all of the tank's contents and storm water. 5 Five-year Accident History (' 68.155(e) ): There have been no releases in the past five years which had an off-site impact. 6. The emergency response program (' 68.155(f) ). The Kenton facility has established a written emergency response plan and maintains an emergency response team trained in these emergency response procedures. All plant personnel are trained in evacuation procedures. The written emergency response plan complies with the following federal regulations (and parallel state regulat ions): 7 OSHA 29 CFR 1910.38(a) - Employee Emergency Action Plans 7 OSHA 29 CFR 1910.119 (n) - Process Safety Management of Highly Hazardous Chemicals 7 OSHA 29 CFR 1910.120(p) and (q) - Hazardous Waste Operations and Emergency Response (HazWOPER) 7 OSHA 29 CFR 1910, Subpart L - Fire Protection 7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention 7 EPA 40 CFR 112 - Spill Prevention, Control and Countermeasures Plan 7 EPA 40 CFR 265 Subpart D - Contingency Plan and Emergency Procedures (Referenced by 40 CFR 262) 7 EPA 40 CFR 302.6 - Notification Requirements 7 EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Plan 7 EPA 40 CFR 355.40 - Emergency Planning and Release Notifications The Kenton facility has an Emergency Response Team (ERT) available 24 hours per day to respond to in-plant chemical emergencies. The team maintains an Incident Command Center (for response operations and planning) and emergency operations center (for logistical support). Each center is equipped with the necessary equipment and information to respond to chemical emergencies. The Kenton facility has an on-site alarm system and coordinates public notification through the local 911 system and police department. Additionally, the Kenton facility has developed a Special Situations Plan which is a program designed for responding to emergencies that may have impacts beyond the immediate plant and is a supplement to the Emergency Response Plan. The Special Situation Plan links the local response to the OxyChem Corporate Emergency Response Center located in Dallas, Texas which can then provide assistance as needed. 7. Planned Changes to Improve Safety (' 68.155(g) ). The Kenton facility constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, and a program soliciting safety and environmental suggestions from the plant employees. 8. Certification To the best of the undersigned's knowledge, information and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. __________________________________ Jordan Morgan__________________ Signature* Print Name Plant Manager______________________ 06/18/99_______________________ Title Date * Original signature is included in the cover letter |