Rhone Poulenc Institute Plant - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Institute Plant has release prevention and emergency response policies and procedures in place in order to prevent and reduce the potential for releases from the Institute facility. Written procedures are maintained and are followed by Institute personnel. Release-reporting procedures are contained in Institutes manufacturing process units which prescribe immediate and follow-up reporting to federal, state, and local authorities, including the United States Environmental Protection Agency (USEPA), the U.S. Coast Guard, the West Virginia Division of Environmental Protection (WVDEP), the state and local emergency planning centers (EPCs), local fire and police departments, water departments, local residents, schools, hospitals and other interested parties. The plant maintains an emergency response team with appropriate training and equipment to respond to releases of toxic or flammable materials inside the plant. Th e plant also has mutual-aid agreements with local fire departments for response to various emergencies including chemical releases. Finally, the plant is subject to OSHA process safety management regulations to prevent potential releases inside the plant and the RMP program to help control or prevent releases which may affect off-site human health or the environment. FACILITY DESCRIPTION AND REGULATED SUBSTANCES HANDLED The Institute Plant is located eight miles west of Charleston, WV on the north bank of the Kanawha River. The site has a total area of 460 acres, which is owned by Rhone-Poulenc. Portions of the site are leased to Union Carbide, Lyondell, and Reagent Chemical Company. Rhone-Poulenc has two business entities that are supported by this plant. They are Rhone Poulenc Ag Company (agricultural chemicals) and RP Animal Nutrition (RHODIMET AT-88). Rhone-Poulenc also provides personnel to operate and maintain the Union Carbide and Lyondell chemical facilities. Reagent o perates their own facility inside the plant. Rhone-Poulenc has four production process at this site that are covered by the RMP rule. Three of those process, methyl isocyanate, methomyl, and aldicarb support the Rhone-Poulenc (agricultural chemicals) business. The forth one, RHODIMET, supports the RP Animal Nutrition business. The methomyl and aldicarb facilities both produce a solid crystalline material that is used as an insect control agent. Both of these facilities use methyl isocyanate, produced by the Methyl Isocyanate Unit, as one of the principle raw materials. In addition to methyl isocyanate, the methomyl facility uses acetaldoxime, chlorine and methyl mercaptan as raw materials. The aldicarb facility also uses aldicarb oxime and trimethylamine as raw materials. The methyl isocyanate is produced from natural gas and chlorine with phosgene being produced as an intermediate. The RHODIMET AT-88 facility produces methionine hydroxy analog that is used in poultry feed s upplies. Raw materials for this process include ammonia, sulfuric acid, natural gas, and methylthiopropionaldehyde. WORST-CASE TOXIC RELEASE SCENARIO The worst-case toxic release scenario involves methyl isocyanate and presumes the sudden loss of the entire contents of the double-walled stainless steel underground storage tank to the surface of the ground, when completely full, releasing 200,000 lbs. over a 10-minute period. The release duration is reported as 17.4 minutes since that is the time required for the liquid pool that is formed to evaporate and release the material to the air. No credit was taken for the passive mitigation that would occur, even with complete failure of both walls of the tank, by the earth that surrounds the tank. This scenario will have an off-site impact. There are many factors that make this scenario very unlikely. Some of the more significant are: 1) an emergency dump tank that is available for the safe transfer and containment of material from a leaking tank, 2) a process scrubber and a flare which are both capable of safely destroying all the methyl isocyanate from any storage tank, 3) in addition to containing the contents of the tank, the tank is also protected from external forces by the surrounding earth, and 4) the tank is monitored by redundant devices that continuously measure the tank pressure, temperature, and level. WORST-CASE FLAMMABLE RELEASE SCENARIO The worst-case flammable release scenario involves monomethylamine and presumes the sudden loss and ignition of the entire contents of a rail car (160,000 lbs.) over a 10-minute period. This scenario will have an off-site impact. There are many factors that make this scenario very unlikely. The most significant is that rail cars are designed and manufactured according to DOT standards (impact resistant and bullet proof) that meet or exceed American Society of Mechanical Engineering (ASME) standards. ALTERNATE TOXIC METHYL MERCAPTAN RELEASE SCENARIO The altern ate toxic release scenario for methyl mercaptan presumes the loss of 151,000 lbs. over a 45-minute period through a failed unloading hose while transferring from the rail car to the storage tanks. No credit was taken for active or passive mitigation measures that include: 1) operation of the tank car excess flow shut-off valve, 2) at least one trained employee is present during the entire unloading process to monitor for leaks and take corrective action, 3) tank car chocks, hand brakes, and derails are set to prevent tank car motion, 4) hoses are fabricated of rugged (braided stainless steel) construction with a burst pressure that is 12 times the normal operating pressure, and 5) new hoses are hydro tested prior to service and replaced annually to guard against catastrophic hose failure. This scenario will have an off-site impact. ALTERNATE TOXIC CHLOROFORM RELEASE SCENARIO The alternate toxic release scenario for chloroform presumes the loss of 180,000 lbs. over a 41-minute peri od through a failed unloading hose while transferring from the rail car to the storage tanks. No credit was taken for active or passive mitigation measures that include: 1) the tank car unloading area has slopped drainage to the process sewer, 2) at least one trained employee is present during the entire unloading process to monitor for leaks and take corrective action, 3) tank car chocks, hand brakes and derails are set to prevent tank car motion, 4) hoses are fabricated of rugged (braided stainless steel) construction with a burst pressure that is 12 times the normal operating pressure, and 5) new hoses are hydro tested prior to service and replaced annually to guard against catastrophic hose failure. This scenario will have an off-site impact. ALTERNATE TOXIC PHOSGENE RELEASE SCENARIO The alternate toxic release scenario for phosgene presumes the loss of 114 lbs. over a 45-minute period through a 0.8 mm hole in a metal gasket. A few of the many design and operating practices t hat are used to minimize the possibility and extent of leaks are: 1) strictly enforced inventory limits to limit the actual amount of material stored on site, 2) double-walled valves and pipelines for liquid service that are equipped with leak detection to provide secondary containment, 3) automatic isolation valves to prevent and minimize the extent of a leak should one occur, 4) a leak detection and repair (LDAR) program that identifies and repairs leaks while they are very small, and 5) periodic testing and inspections for tanks, columns, heat exchangers, pumps, instruments, and pipes to evaluate their integrity. This scenario will have an off-site impact. ALTERNATE TOXIC METHYL ISOCYANATE RELEASE SCENARIO The alternate toxic release scenario for methyl Isocyanate presumes the loss of 118 lbs. over a 45-minute period through a 0.8 mm hole in a metal gasket. A few of the many design and operating practices used to minimize the possibility and extent of leaks are: 1) double-wall ed pipelines for liquid service that are equipped with leak detection to provide secondary containment on critical transfer lines, 2) extensive use of all welded pipe to minimize the number of flange joints, 3) automatic isolation valves that are strategically installed to prevent and minimize the extent of a leak should one occur, 4) a leak detection and repair (LDAR) program that identifies and repairs leaks while they are very small, and 5) periodic testing and inspections for tanks, columns, heat exchangers, pumps, instruments, and pipes to evaluate their integrity. This scenario will have an off-site impact. ALTERNATE TOXIC AMMONIA RELEASE SCENARIO The alternate toxic release scenario for ammonia presumes the loss of 160,000 lbs. over a 48-minute period through a failed unloading hose while transferring from the rail car to the storage tanks. A pool of liquid on the ground vaporizes and airborne vapors reach an ignition source and explode. No credit was taken for active or pa ssive mitigation measures that include: 1) operation of the tank car excess flow shut-off valve, 2) at least one trained employee is present during the entire unloading process to monitor for leaks and take corrective action, 3) tank car chocks, hand brakes and derails are set to prevent tank car motion, 4) hoses are fabricated of rugged (braided stainless steel) construction with a burst pressure that is 12 times the normal operating pressure, and 5) new hoses are hydro tested prior to service and replaced annually to guard against catastrophic hose failure. This scenario will have an off-site impact. ALTERNATE TOXIC CHLORINE RELEASE SCENARIO The alternate toxic release scenario for chlorine presumes the loss of 164 lbs. over a 45-minute period through a 0.8 mm hole in a metal gasket. A few of the many design and operating practices that are used to minimize the possibility and extent of leaks are: 1) extensive use of all welded pipe to minimize the number of flange joints, 2) a utomatic isolation valves that are strategically installed to prevent and minimize the extent of a leak should one occur, 3) a leak detection and repair (LDAR) program that identifies and repairs leaks while they are very small, and 4) periodic testing and inspections for tanks, columns, heat exchangers, pumps, instruments and pipes to evaluate their integrity. This scenario will not have an off-site impact. ALTERNATE FLAMMABLE MONOMETHYLAMINE RELEASE SCENARIO The alternate flammable release scenario involves monomethylamine and presumes the loss of 160,000 lbs. over a 48-minute period through a failed unloading hose while transferring from the rail car to the storage tanks. A pool of liquid on the ground vaporizes and air-borne vapors reach an ignition source and explode. No credit was taken for active or passive mitigation measures that include: 1) operation of the tank car excess flow shut-off valve, 2) at least one trained employee is present during the entire unloading proc ess to monitor for leaks and take corrective action, 3) tank car chocks, hand brakes and derails are set to prevent tank car motion, 4) hoses are fabricated of rugged (braided stainless steel) construction with a burst pressure that is 12 times the normal operating pressure, and 5) new hoses are hydro tested prior to service and replaced annually to guard against catastrophic hose failure. This scenario will have an off-site impact. FIVE-YEAR ACCIDENT HISTORY There has not been an accident or incident that has met the RMP reporting criteria in any of the Institute Plant Rhone-Poulenc RMP-covered processes during the last five years. EMERGENCY RESPONSE PROGRAM The Institute Plant maintains a highly trained emergency response team to handle fires, explosions, toxic vapor releases, medical, chemical spills, and natural disasters and rescue emergencies. It also participates in local fire and industrial mutual aid systems. The Institute Plant has a dedicated in-plant Emergency Opera tions Center, trained incident commanders, and trained and state-certified emergency squad on site at all times. Additionally, a plant-wide notification system is in place in the event of an emergency. The plant has an on site dispensary and doctor as well as full-coverage with Emergency Medical Technicians (EMTs) and paramedics. CHANGES TO IMPROVE SAFETY There are many operating and mechanical changes that continuously occur to improve the safe operation of the Rhone-Poulenc facilities. These occur as a result of the on going process hazard assessment review Process. |