DuPont Dow Elastomers L.L.C. - Hypalon Unit - Executive Summary
Executive Summary |
Risk Management Plan (RMP)
DuPont Dow Elastomers L.L.C. - Beaumont Plant
DuPont Dow Elastomers L.L.C., a global supplier of specialty elastomers, is a joint venture of the DuPont Company ("DuPont") and The Dow Chemical Company. The 50/50 joint venture was formed on April 1, 1996 to consolidate the elastomer resources, production facilities, technical expertise, and business skills from both companies. Globally, DuPont Dow Elastomers offers a wide variety of products ranging from thermoset rubber polymers used in the general rubber industry to high-performance fluoroelastomers used by the chemical processing and automotive industries.
The Environmental Protection Agency (EPA) requires certain companies, like ours, to share information about the chemicals we use, the potential risks those chemicals pose to the community, the ways that we manage these risks, and the plans we have made to respond to a possible release of these chemicals. This require
ment is part of the Congress's Clean Air Act known as the Risk Management Planning (RMP) rule. This executive summary is provided in compliance with 40 CFR ? 68.155 of the RMP rule.
Accidental Release and Emergency Response Policies
Dupont Dow Elastomers Hypalon? Unit is committed to operating and maintaining our process in a safe and responsible manner. We follow a corporate philosophy that the "goal is zero." This means we constantly strive for zero process safety incidents, zero environmental incidents and zero injuries. We have programs, procedures and management practices in place to support this goal of zero. We constantly assess our progress against this goal of zero and take corrective actions to get back on track whenever necessary.
Our primary focus is on prevention of any accidental releases. However, we have strong emergency response capabilities to back-up our prevention activities. We use this combination of prevention programs and emergency response capability
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:
o A description of our facility and use of substances regulated by EPA's Risk Management Program
o A summary of results from our assessment of the potential off-site consequences from accidental
o An overview of our accidental release prevention programs;
o An overview of our emergency response program;
o A five-year history of accidental releases of chemicals regulated by EPA's RMP rule;
o 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;
o The certifications that EPA's RMP rule requires u
s to provide; and
o The detailed information (called data elements) about our risk management program.
Site Identification and Regulated Substances
The DuPont Dow Elastomers Hypalon? Unit is part of a larger site called the Beaumont Industrial Park. This industrial park is located on Highway 347 in Beaumont, Texas. Our facility at the Beaumont Industrial Park presently employ 162 people who live and work in Jefferson County and vicinity. The Hypalon? Unit located at the site has been in operation since 1957, producing high performance products.
DuPont Dow Elastomers Hypalon? Unit, which was formerly operated by DuPont, has been handling toxic substances at this site for over 40 years. The long life and diversity of our operations means we have vast experience in operating processes in a safe and environmentally responsible manner.
In our process, we use the following chemicals that EPA has identified as having the potential to cause significant off-site consequences in the ev
ent of a substantial accidental release: Chlorine, Chloroform and Sulfur Dioxide.
Other chemicals are used in our Hypalon? Unit, but pose a lesser risk to the community, because they are not stored in large quantities, are less hazardous, and are not listed in the RMP regulations. These chemicals include: carbon tetrachloride and sulfuryl chloride.
Key Off-Site Consequence Analysis Scenarios
To help with understanding the potential impact on the community due to a release of chemicals from DuPont Dow Elastomers Hypalon? Unit, we have provided information about the worst-case release scenario and alternative release scenarios for our facility.
These scenarios were developed using the guidance and technical data supplied by the EPA. Scenario information similar to that described below has been used for many years as part of our process safety management program. In the past we have modeled potential releases and analyzed the results to help us continuously improve our proces
ses and reduce risk. We continue to do these assessments as part of our internal process safety management systems.
The EPA defines the worst case scenario as a hypothetical release of the largest quantity of a regulated chemical. The scenario assumes the entire quantity is released in ten minutes, even if it is impossible to do so.
Using the methods described by the EPA, the worst case release of a toxic chemical from the DuPont Dow Elastomers Hypalon? Unit would be the release of the entire contents of a sulfur dioxide railcar (180,000 pounds) in a 10-minute period. Using EPA guidelines, a release like this could impact the public 16 miles from the point of the release. Depending on the wind direction at the time of the release, most of Jefferson County and parts of Orange County would be affected.
The worst case scenario described above underscores the need for very rigorous process safety management systems. It is important to note however, that none of the prevention and
mitigation equipment, practices, and procedures that have been put in place by DuPont Dow Elastomers to prevent or respond to releases such as these are taken into account for these worst case scenarios.
Since the worst case scenarios are so very improbable, they are not good cases to focus on for emergency response planning with the local community. In order to facilitate emergency response planning with the community, the EPA has included the requirement for companies to report alternate case scenarios. These alternate case scenarios provide a more realistic picture of what could actually happen if the safety systems used by a facility were to fail.
The EPA requires that companies include one alternate release scenario for regulated flammables as a group and one for each regulated toxic chemical. This is because the impact of a flammable scenario on the public is expected to be similar for all the different types of flammables. The toxic chemicals can vary in their effects
and so must be reviewed individually. In the data elements section of this report you will find a detailed description of all these alternate release scenarios.
The largest and most significant toxic alternate case scenario for DuPont Dow Elastomers Hypalon? Unit is a large leak of chlorine from instrument tubing, a flange gasket, or a leaking valve. This could result in over 1,000 pounds of chlorine released into the atmosphere. Under normal weather conditions, this release could go 1056 feet before the toxic concentration falls below the level of concern. Because of the process location, this release would not leave the Beaumont Industrial Park site. Although it would impact our employees or others inside the Industrial Park boundaries, it would not impact areas where the public has access. Of course, we have accident prevention activities in place to protect our employees and Industrial Park personnel from injury.
Knowing the impact of a release like this, DuPont Dow Elast
omers has many things in place to prevent releases from ever occurring. The next section summarizes our release prevention activities.
Accidental Release Prevention Program
The concepts of accidental release prevention and process safety management have been intrinsic to DuPont Dow Elastomers since its formation. Site practices that incorporate these concepts include the following:
o A thorough understanding of our process technology including the safe limits of the processes and the
proper materials of construction for equipment;
o Proper design and installation of equipment;
o Systematic process hazard review studies to identify and manage process hazards;
o Written operating and maintenance procedures;
o Extensive training for all individuals involved in operating or maintaining a chemical process;
o Mechanical integrity testing and preventive maintenance to detect potential equipment problems early;
o Mechanical quality assurance programs to ensu
re the correct spare parts are installed every time
maintenance work is done;
o Procedures to assess and manage the safety and environmental impact of changes to the process
technology or equipment;
o Pre-startup safety reviews for equipment that is newly installed or modified;
o Compliance audits to ensure process safety management procedures are effective and implemented
o Investigation of actual and potential incidents to identify and implement corrective actions;
o Participation of all employees in the process safety management system;
o Documented safe work practices, and
o A contractor management system to ensure work done by contractors is done safely and meets
DuPont Dow Elastomers quality standards.
In addition to the practices described above, we have designed our processes to include multiple layers of safeguards. Examples of these include:
? Automatic valves for rail cars, which isolate the supply of materials fr
om the rail car in the event of a
? Computer display and control of process parameters;
? Interlocks to automatically shut down processes for certain process deviations;
? Motion detectors which automatically close the valves at the railcar if the railcar is moved;
? Low concentration chlorine and sulfur dioxide detectors in the rail car area that sound an alarm and
provide an alarm signal to the computerized process control system when a leak is detected;
? Emergency scrubber system to prevent emissions from reaching the environment;
? Isolation valves which can be operated remotely from the process control system;
? Check valves to prevent cross contamination of chemicals; and
? Operator surveillance during transfer of hazardous materials from shipping containers.
Five-Year Accident History
There have been no off-site injuries, evacuations, sheltering-in-place, property damage or environmental damage due to the accidental release of regulated substances fr
om the DuPont Dow Elastomers Hypalon? Unit in the past 5 years. DuPont Dow Elastomers began operation of the Hypalon? Unit on April 1, 1996. Prior to that time, the facilities were operated by DuPont.
Emergency Response Program
In addition to all we do to prevent accidental releases, DuPont Dow Elastomers is committed to maintaining a strong emergency response capability to back-up our prevention activities. The Beaumont Industrial Park has an on-site emergency response team, staffed 24 hours a day. The emergency responders are thoroughly trained and properly equipped to respond to releases of any chemicals used on the site.
Each operating area in the Beaumont Industrial Park has developed an Emergency Response Plan. These plans include steps to contain, control, and terminate any release of hazardous materials and bring under control any resulting fires or explosions.
Some of the elements of the plan include:
? Emergency shutdown procedures;
? Activation of the Emergen
cy Response Team (ERT);
? Activation of emergency systems such as fire suppression systems;
? Activation of emergency repair procedures or services;
? Shutdown of adjacent facilities as appropriate;
? Barricading of affected facilities or roadways, if needed, and;
? Activation of spill containment and clean up procedures.
Where appropriate, the plan provides for interfacing with local community response organizations using guidelines established in Beaumont Industrial Park's Responsible Care program. These guidelines address the following:
? Activation of the Emergency Response Plan;
? Notification of affected personnel both on and off-site;
? Notification of appropriate regulatory agencies;
? Escape and evacuation plans and practices for affected personnel;
? Personnel Accounting;
? Rescue Operations and medical assistance.
To ensure prompt and efficient implementation of these plans, emergency drills are conducted at appropriate frequencies. These drills include participation of
local emergency response organizations. All personnel with assigned responsibilities in these plans receive special training, including initial and refresher training to fulfill the competency requirements of their specific function within the plan.
The Beaumont Industrial Park Master Disaster Plan provides guidelines for handling a major emergency or disaster at the site to minimize hazards to site personnel and neighboring communities. The DuPont Dow Elastomers Area Plans serve as a supplement to this Plan. The safety of plant personnel and neighbors will take precedence over all other considerations in these plans.
The Beaumont Industrial Park operates the SAFER? System to track concentrations of releases that may move off-site. Specially trained personnel are available on a 24-hour basis to provide guidance to the Emergency Director. This guidance can be used to determine if off-site personnel should be notified and the extent of the potential hazard.
In addition to these
on-site activities, the Beaumont Industrial Park also maintains transportation emergency response capability, which allows the site to respond to chemical transportation incidents outside the site.
Planned Changes to Improve Safety
As part of our process hazards review procedures, all of our higher hazard processes are thoroughly studied on a periodic basis to identify risk reduction opportunities. As a result of these studies, we are currently implementing, or are in the planning stages to implement, the following risk reduction activities:
? Piping improvements including additional isolation and drain valves to improve the operation;
? Improving the control of the process by installing better instrumentation, more automatic process
shutdown interlocks, and upgraded computer control systems;
? Improving preventive maintenance inspections and procedures;
? Improving training programs; and
? Conducting process safety audits to identify any deficiencies in our management syste
RMP Data Elements
The following pages contain more detailed information on the topics listed below:
? Facility registration
? Offsite consequence analysis
? Five-year accident history
? Program 3 prevention program
? Emergency response program