FERRO Delaware River Plant - Executive Summary |
|
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 10/4/2000 At the Ferro (formerly Solutia) Delaware River Plant, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by the Environmental Protection Agency's (EPA) Risk Management Plan (RMP) regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases, based on EPA guidelines * An overview of our accidental release prevention programs * A five-year history of accidental rel eases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES The Ferro Delaware River Plant produces the following products, using a variety of materials and processing operations: * Benzyl chloride, which is used as an intermediate to produce a variety of end-products, including plasticizers, perfumes, biocides, and flavorings. * Tetrachlorophthalic anhydride (brand name is Tetrathal (R)), which is used to produce pigments and polyester resin flame retardants. * Plasticizers, which are used to produce vinyl flooring, wire coating, caulk, and other soft vinyl end pro ducts. * Dibutyl phenyl phosphate (DBPP) and Tri-isobutyl phosphate (TiBP), which are used to make hydraulic fluids for use in aviation control systems. Our plant runs 24 hours, (7) days a week, year-round, except for planned or unplanned downtime for maintenance or inventory control. Our plant employs approximately 130 people, including operators, mechanics, supervisory and technical people, plus approximately 15 maintenance and construction contractors on a full-time basis. Our plant has operated safely since its initial startup in 1961without a major incident affecting our community. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemica ls: Toxics Our facility uses two RMP-regulated toxic chemicals, chlorine and phosphorus oxychloride, to produce our products. Chlorine, which is purchased and not manufactured, is used at our site to produce benzyl chloride and Tetrathal(R), is stored in and used from 90 ton railroad tank cars shared between the two processes. Chlorine is a gas at normal pressure and temperature, but is stored as a liquid under pressure in the tank cars. It is unloaded directly from the tank car into a steam-heated vaporizer, where it is heated up to vaporize the liquid chlorine for use in both the benzyl chloride and Tetrathal(R) processes. We store a maximum of (14) chlorine tank cars on our property, although no more than (2) cars are connected to the process at any one time. Phosphorus oxychloride (POCl3) is used in our Phosphate Esters manufacturing facility to manufacture dibutyl phenyl phosphate (DBPP), tri-isobutyl phosphate (TiBP) and several plasticizer products (Santicizers 141, 148, and 2148). Phosphorus oxychloride is received in 5,000 gallon tanker trucks and unloaded into a 12,500-gallon storage tank, from where it is transferred to the Phosphate Esters manufacturing process. Flammables We have no RMP-regulated flammables stored or handled at our facility. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals. The Worst-Case Scenario, as defined by the EPA, is a hypothetical and extremely unlikely incident in which the largest amount possible of a re gulated substance is accidentally released within 10 minutes. Worst-case scenarios assume no active mitigation (i.e. assume failure of response procedures or equipment to stop or contain the release), but do take into affect passive mitigation (facilities that do not require people or energy to operate such as a containment dike or building). Based on the EPA definition, our site's Worst-Case scenario involves the catastrophic failure of a 90-ton chlorine railroad tank car, resulting in the loss of the entire contents in 10 minutes. The resulting spill of liquid chlorine would vaporize, forming a plume that would travel with the prevailing wind direction to an endpoint distance (distance within which people exposed for up to one hour would suffer permanent health effects) as estimated by dispersion modeling. This is a highly improbable scenario, due to the strict requirements for construction and maintenance of the tank cars used to transport and store chlorine. The walls of the car are 3/4" thick steel, and are tested to withstand a pressure of at least 500 lbs. per square inch (psi), over three times the normal operating pressure. A remote shutoff valve and an excess-flow valve are provided to stop flow in the event of failure in the unloading line. An outer insulation shell is provided to prevent overheating in the event of a nearby fire. A relief valve is also provided to prevent overpressurization of the car. Tank cars are stored and moved on dead-end sidings where travel speed is low, and our railroad tracks are well-maintained. A special siding is used for unloading tank cars, isolated from the main track by locked deraillers to prevent inadvertent contact. Alternative Release Scenario(s) - Regulated Toxic Chemicals Alternative Release Scenarios, as defined by EPA, are hypothetical or actual incidents which are more likely to occur than the Worst-Case Scenario, but which take into account procedures and equipment which would be used to stop or contain the release (such as closing a valve or shutting down a process system). It must be also be assumed that the resulting release reaches an off-site receptor. The Alternative Release Scenario for chlorine involves failure of the chlorine unloading hose, resulting in the loss of approximately 2500 lb. over a 10-minute time period. The Alternative Release Scenario for phosphorus oxychloride involves a reactor outlet piping leak, resulting in a spill of approximately 1500 lbs. over a 30-minute time period. Worst-case Release Scenario(s) - Regulated Flammable Chemicals Alternative Release Scenario(s) - Regulated Flammable Chemicals We have no RMP-regulated flammables stored or handled at our facility. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach t o preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs, including those incorporated into EPA, OSHA, and New Jersey Toxic Catastrophe Prevention Act requirements: * Inventory Control to minimize the quantity that could be released in an accident * Process Safety Information to ensure up-to-date parameters for safely operating the process * Process Hazards Analysis to identify and correct potential safety problems * Standard Operating Procedures which clearly describe how to safely operate the process * Training to ensure that operators and mechanics are qualified to safely perform their job * Mechanical Integrity/Preventive Maintenance to inspect and test equipment to ensure mechanical integrity and prevent equipment failure * Management of Change to identify and address potential safety concerns associated with process modifications prior to installation * Pre-Startup Safety R eview to ensure that process modifications are safe prior to start-up. * Annual Compliance Audits to verify that procedures are being followed and to institute corrective actions if necessary. * Incident Investigations to identify and address the root causes of incidents or near-misses to prevent recurrence * Employee Participation in all process safety management activities * Hot Work Permit to ensure that work involving flame, sparks or heat producing equipment is controlled to minimize the chance of a fire * Contractor Safety Program to ensure that only the safest contractor companies are hired to work in the plant, and to make sure that contract employees are aware of potential hazards and safety procedures and are trained to safely perform their job. A permit system is also in place to control contractor work and help ensure that it is done safely * Risk Assessment to estimate and reduce the likelihood and impact of potential accident scenarios * Breaking into Proce ss Permit Procedure to ensure that proper precautions are taken when opening up process equipment to prevent release of hazardous chemicals As part of our prevention efforts, we have implemented chemical-specific prevention steps: The risk associated with chlorine releases is minimized by the following design, maintenance, and operating features: * Both the benzyl chloride and Tetrathal(R) processes are heavily monitored, alarmed, and interlocked to shut down if any problem occurs, using state-of-the-art computer control systems. * Atmospheric chlorine sensors are in place to quickly detect a leak in the unloading area if it occurs * All vents and relief devices are connected to scrubbers, where the chlorine is neutralized with caustic soda * Piping is extra-thick (Schedule 80), and periodic thickness checks are made to make sure that internal corrosion is not taking place which would weaken the pipe. All new welds are x-rayed prior to putting them into service. * Special cor rosion-resistant Monel hoses are used to connect tank cars to the process, and these are replaced every 6 months. * A specially designed tank car-mounted valve and an excess-flow valve are used to allow the car to be shut off remotely if a leak in the unloading line. * Both Chlorine Institute and plant standards are used to ensure state-of-the-art design, installation, operation, and maintenance of chlorine systems. * A special capping kit is available to seal any leaks in the tank car unloading fittings. The risk of phosphorus oxychloride releases is minimized by a number of features: * The Phosphate Esters process is thoroughly monitored, alarmed, and interlocked to shut down if a problem occurs, using state-of-the-art computer control systems. * Atmospheric sensors are installed to quickly detect a leak if one occurs. * Phosphorus oxychloride is unloaded and stored in an enclosed building vented to a scrubber, so that any leaks and resulting vapors are fully contained. * Special spill blanketing systems are provided in case of a spill which would minimize the formation of hazardous vapors. * State-of-the art plant standards are used to minimize the potential for a release, including design, installation, operation, and maintenance of phosphorus oxychloride handling systems. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: * In August, 1996, there was a small release of chlorine from a vent system in the benzyl chloride process. A truck driver, who was in the area was was subsequently treated at a nearby hospital for respiratory problems. As with all significant incidents at our facility, a formal investigation was conducted to identify and correct the root causes of this incident. EMERGENCY RESPONSE PROGRAM The Ferro Delaware River Plant maintains a comprehensive emergency response plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. Features of our emergency response plan include the following: * Atmospheric monitors to provide prompt detection of leaks. * A plant alarm system to notify everyone of an incident * Department-specific emergency procedures which address potential incidents * Remote shutdown capability to permit quick process isolation and shutdown. * A State-the-Art Dispersion Modelling System to assess potential for off-site impact of a release. * Emergency generators to provide backup electrical power to critical equipment in the event of a power failure. * Fire Protection systems for all process areas handling flammable materials, as well as 1.25 million gallons of firewater storage and primary and backup fire pumps. * An Emergency Brigade comprised of approximately 25 plant volunteers who provide emergency response to fires and chemical releases. Their leadership includes two former Fire Chiefs of local fire departments. * Emergency Response Training of all employees, on at least an annual basis, in their emergency responsibilities. * Emergency Drills at least annually with outside responders to test performance of the Emergency Response Plan. PLANNED CHANGES TO IMPROVE SAFETY Our plant has practiced good process safety management for many years, and many improvements have already been made, including: * Atmospheric monitors to provide prompt detection of leaks. * Reduced on-site inventory of phosphorus oxychloride through installation of a smaller storage tank * Construction of a full enclosure for phosphorus oxychloride unloading and storage to contain any leaks. * Installation of scrubbers for all process vents which could could release hazardous vapors to the atmosphere. * Installation of state-of-the-art process control systems with backup power to better monitor processes and take immediate action if a problem occurs. * Installation of a remotely-operated shutdown for chlorine tank cars * Relocation of the chlorine vaporizer close to the tank car unloading to minimize the amount of liquid chlorine handled (liquid chlorine is much more hazardous than chlorine v apor since it expands to 460 times its volume if released). * Elimination of the phosphorus oxychloride Weigh Tank in order to minimize the amount of this material in the process. * Installation of emergency generators to provide backup electrical power to critical equipment in the event of a power failure. * Operator certification program to ensure that operators are fully qualified to perform their jobs. * Certification of inspectors for state-of-the-art testing of critical equipment. Planned improvements include on-going followup on recommendations made as a result of incidents and periodic process hazards analyses to reduce the potential and impact of releases of hazardous chemicals. |