ALTIVIA - Executive Summary |
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***** Executive Summary ***** Introduction Coastal Products & Chemicals (Coastal) St. Gabriel facility is located on approximately 6 acres, 12 miles south of Baton Rouge, LA in close proximity to the Pioneer Chlor Alkali Company, Inc. The main products produced at St. Gabriel are repackaged chlorine and sodium hypochlorite. Chlorine is an element that occurs naturally as sodium chloride (table salt). Coastal's products play an important role in the purification of drinking water, treating swimming pools and industrial waters and laundry bleach. Coastal's environmental and safety and health policies recognize the importance of safeguarding the environment and protecting the community throughout the manufacturing process. Programs are in place to ensure compliance with regulations and continuing improvement of performance over the years. Facility personnel are trained extensively in safe operation of the facility and in maintaining compliance with all applicable regulations. Ch lorine is the only chemical at the facility that falls under the RMP regulations. Prevention Program Coastal has developed an accidental release prevention program based on the elements of OSHA's Process Safety Management Program. Each of the 12 elements is fully implemented and integrated into the standard operating practices of the plant. Summarized below are brief descriptions of each of the elements: Process Safety Information - Critical information on chlorine properties, chlorine handling and chlorine repackaging techniques, is made readily available to facility personnel through Material Safety Data Sheets, current drawings, and comprehensive operations manuals. Additionally, the Chlorine Institute provides information and guidelines in the form of regularly updated technical pamphlets. This information is used as the basis for many of our operating procedures and chemical process systems. Process Hazard Analysis - Coastal performs Process Hazard Analyses on an establis hed schedule. A trained team rigorously scrutinizes the operating processes and makes recommendations for safety enhancements. The recommendations are then prioritized and implemented accordingly. Operating Procedures - Clear and concise instructions have been developed by experienced personnel for all facility operations. The operating instructions are kept current by regularly scheduled annual review, and by integrating the Management of Change procedures. Training - Employees are thoroughly trained on the technical aspects of the manufacturing process including on the job (OJT) training and operating procedures that lead them step by step through the necessary operating instructions. The training program is ongoing and used to continually enhance the capabilities of all plant employees. Mechanical Integrity - The Mechanical Integrity program in place at the plant is specifically designed to keep our equipment in viable condition. Operations personnel ensure all pipes, tanks, valves and mechanical equipment involved in chlorine service are checked prior to placing in service on a daily basis. Chlorine equipment is inspected and tested on an established schedule as established by the Chlorine Institute. Management of Change - Written procedures are in place to ensure that all process changes at the plant undergo review at the planning stage. No changes are made without review by a team that includes engineering, operations and maintenance personnel. Once a process change has been made, systems are in place to make sure that communication of the change will be made to all that may be affected. Pre Startup Reviews - Before being placed into service, any new or modified system is thoroughly reviewed by engineering and operations personnel. This review is designed to ensure appropriate design, adequate safety systems, and sufficient training. All recommendations from the review are then completed before start up. Compliance Audits - Internal audits will be performed by the Site Manager and the operations supervisor. Recommendations from the audits are reviewed by the executive committee and are promptly converted into action plans. Incident Investigation - Significant environmental, safety, or health incidents at the facility are fully investigated by appropriate teams to determine root cause and to put in place action plans designed to prevent recurrence. The findings are documented and communicated to facility personnel. Employee Participation - Employees are very involved in all aspects of the process safety management program. Employee participation is the cornerstone of the Voluntary Protection Program. Hot Work - The facility's Hot Work procedure requires that detailed permitting activities take place before, during, and after any job that has the potential to provide a source of ignition. Contractor Safety - The contractor safety program, places stringent qualification requirements on contracting firms. To become quali fied to work at the facility, contractors must provide proof of training that matches our tough requirements. Additional facility specific training is then required before any contract work can take place. Contractor safety performance and compliance with facility safety requirement are monitored closely during all contract projects. Emergency Response Program The Coastal facility is located in close proximity to the Pioneer Chlor Alkali Company, Inc. facility in St. Gabriel. Currently Coastal does not have a written emergency response plan due to the small number of employees at the facility however, Coastal plans on implementing an emergency response program in the near future. Coastal's personnel are trained to handle minor emergencies with back up assistance from Pioneer's ER team if necessary. Communication systems and chlorine detection systems have been installed to provide rapid communication between companies. Coastal and Pioneer work closely together to insure adequat e response personnel are available to respond if necessary. Pioneer's ER plan provides for 24 hour/day, 365 day/year response capabilities. Hypothetical Models The Environmental Protection Agency has defined the worst case scenario as the hypothetical rupture and full release of all contents of the facility's largest storage tank, assuming all safeguards have failed, during extremely stable weather conditions. While the probability of this scenario coming to pass at any facility is extremely low, it does provide a template for emergency response planning. The computer-generated model for our worst case scenario is the rupture of a chlorine tank trailer loading hose while actively loading the tank trailer. It is assumed that the chlorine tank trailer internal check valve does not seat which results in a planning zone of 5.8 miles. Each facility must also prepare an alternate scenario that could have an off-site impact, based on plant operations. As the alternate scenario we ha ve selected a transfer hose failure used in filling the ton chlorine containers. The computer-generated model for this release results in a possible impact of up to 0.2 miles. Five-Year History The facility is new and has only been in operation since August of 1999. There have been no incidents. Safety Coastal is committed to a continuous improvement process. Safety, health and environmental related matters are continually being reviewed and revised to make improvements in protecting our employees and our community. Coastal engineers and constructs our chemical manufacturing facilities using the best available control technology. Sound engineering design coupled with the continuous improvement process we feel provides the best long-term protection concerning everyone's well being. We aim to further enhance our partnerships with regulatory agencies and local responders, as well as with other industrial facilities, in the common goal of protecting our employees, our communitie s, and our futures. |