Stepan Company - Executive Summary |
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STEPAN COMPANY - Winder Plant Risk Management Plan I. EXECUTIVE SUMMARY Stepan Company is committed to operating in a manner that is safe for Stepan Company's employees, the public, and the environment. As part of this commitment, Stepan Company has established operations and management systems to help ensure safe operation of the processes at this facility. One part of this system is a risk management program (RMP) that helps manage chemical risk at the Stepan Company's Winder facility and complies with the Environmental Protection Agency's (EPA) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Program Rule (RMP Rule). One of the requirements associated with the RMP Rule is to submit a Risk Management Plan (RMPlan) describing the risk management program at Stepan Company's Winder Plant. This document is intended to satisfy the RMPlan requirements associated with the RMP Rule and to provide the public with a description of the risk manageme nt program at Stepan Company's Winder Plant. 1.1 Accidental Release Prevention and Emergency Response Policies Stepan Company is committed to the safety of Stepan Company employees, public, and preservation of the environment, through the prevention of accidental releases of hazardous substances. Stepan Company implements controls to prevent foreseeable releases of hazardous substances. In the event of a chemical release, trained personnel will respond to control and contain such releases. Stepan Company evaluates each situation, evacuates employees as necessary, and contacts the local fire department to control and contain the release to prevent and/or reduce the consequences of the release. The Winder Plant will also contact the Barrow County Emergency Management Agency (EMA) and LEPC to assist with emergency management. The Winder facility conducts training and practice exercises on a regular basis to assure effectiveness in emergency response. 1.2 The Stepan Company an d Regulated Substances Stepan Company is a major manufacturer of specialty and intermediate chemicals used in a broad range of industries. Stepan Company is a leading merchant producer of surfactants that are the key ingredients in consumer and industrial cleaning compounds. Stepan Company's Winder Plant handles two (2) substances regulated by the RMP rule in sufficient quantities to be covered by the regulation. Ethylene Oxide (EO) is delivered by rail car, stored on site, and used in the alkoxylation process. The process is used to manufacture products that may be sold to customers, such as fabric softners and ag chemical emulisifiers. Ethylene Oxide is classified as a toxic gas in the RMP Rule. Propylene Oxide (PO) is delivered by rail car, stored on site, and used in the alkoxylation process. The process is used to manufacture products that may be sold to customers, such as fabric softners and ag chemical emulisifiers.Propylene Oxide is classified as a toxic liquid in the R MP Rule. 1.3 Offsite Consequence Analysis Stepan Company's Winder Plant performed an Offsite Consequence Analysis (OCA) to estimate the potential for an accidental release of the regulated substances and its effect on the public and environment. The OCA consists of both Worse Case Scenarios (WCS) and Alternative Release Scenarios (ARS). An ARS represents a release that might occur during the lifetime of a facility. Both WCS's and ARS's help the Local Emergency Planning Committee (LEPC) improve the community emergency response plan. The scenarios also assist the Winder Plant for emergency response pre-planning by identifying potentially impacted off-site areas. The WCS and ARS are completed as defined in the RMP rule. The main objective of performing the OCA is to determine the distance at which certain effects might occur off-site because of an accidental release. Each regulated substance has an independent concentration to estimate the distance to the endpoint. Endpoints hav e been defined for toxic and flammable substances and defined by the EPA lookup tables. The toxic endpoints are defined as concentrations in the RMP Rule. The concentrations vary among the covered substances based on potential health effects upon exposure. The endpoints have been defined in a manner that minimizes the potential for long term health effects if exposure to the concentration occurs. The distances to endpoints are estimates using calculations and dispersion models as supplied by the EPA. The RMP Rule requires regulated facilities to estimate the population within a circle with radius defined by the distance to endpoint from the release source. The populations within the circles associated with WCS and ARS have been estimated using 1990 census data and the Landview III software. Worse Case Release Scenario (WCS) The WCS for toxic substances is a catastrophic failure of a rail car containing liquid Ethylene Oxide. The maximum distance to the toxic endpoint conce ntration has been estimated at 7.4 miles. Several communities are located within this distance from the rail car. Several public gathering areas are also within this distance. The distance to endpoint associated with the WCS was calculated using EPA's Offsite Consequence Analysis (OCA) Document and RMPcomp. The document includes look-up tables that may be used to find the distance from a release point based on the release rate and the substances toxic endpoint. Alternative Release Scenario (ARS) An Alternative Release Scenario is an event that is more likely to occur compared to the WCS. The rupture of an unloading hose was chosen as the ARS due to the more likely event involving a non stationary source. The following is a description of the release scenarios and mitigation available to respond to the release. The ARS for Ethylene Oxide (EO) is the rupture of a 2-inch diameter transfer hose from the rail car to the storage tank(s). The hose fails due to movement of the ra ilcar. EO railcars are equipped with excess flow valves set to shut flow at 868 lb/minute. Immediate shutoff will occur with a hose rupture. The ARS scenario assumes a 5 minute release before the excess flow valve stops flow. In addition to excess flow valve controls and immediate response by employees (such as tripping deluge system), area monitors have been installed to detect airborne concentrations of EO. Video cameras monitor the rail car unloading area. All railcar brakes are set and wheels chocked prior to unloading. The estimated distance to the toxic endpoint is .7 miles. The ARS for Propylene Oxide (PO) is the rupture of a 2-inch diameter transfer hose from the rail car to the storage tank(s). The hose fails due to movement of the railcar. EO railcars are equipped with excess flow valves set to shut flow at 868 lb/minute. Immediate shutoff will occur with a hose rupture. The ARS scenario assumes a 5 minute release before the excess flow valve stops flow. In addit ion to excess flow valve controls and immediate response by employees (such as tripping deluge system), area monitors have been installed to detect airborne concentrations of EO. Video cameras monitor the rail car unloading area. All railcar brakes are set and wheels chocked prior to unloading. The estimated distance to the toxic endpoint is.2 miles. The distance endpoints were determined using RMPcomp. 1.4 Accidental Release Prevention Program and Chemical-Specific Prevention Steps The following is a summary of the general accident prevention program in place at Stepan Company's Winder Plant. The Environmental Protection Agency (EPA) RMP regulation and the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulation regulate processes at Stepan Company's Winder facility. The following summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Management System T he overall RMP program is managed by the Safety/Environmental Manager (see enclosed organizational chart). Delineation of specific management responsibilities for each element of the RMP plan is the same as Winder's PSM program, section I. It states: "The Winder Safety/Environmental Manager is responsible for defining, updating, implementing and auditing the Winder Process Safety Management Program (PSM). The PSM is managed by the Process Safety Management Team (PSM Team). Members and their responsibilities are as follows: Safety/Environmental Manager - PSM/RMP program Leader/coordinator Production Manager - Operating procedures/operator training Technical Manager - Engineering standards, Process safety information, PHA coordinator, contractor program, Management of Change, Pre- startup safety reviews (PSSR) Maintenance Supervisor - PM programs, mechanical integrity" Employee Participation Stepan Company's Winder Plant encourages employees to participate in all facets of process safety management and accident prevention, including team membership in process hazard analyses, team membership during pre-startup safety reviews, emergency response team participation and creating/updating operating procedures. Process Safety Information Stepan Company's Winder Plant maintains a variety of technical documents that are used to help maintain safe operation of processes. These documents address chemical properties and associated hazards, limits for process parameters, chemical inventory, and equipment design information. The facility management of change procedure (MOC) is used to maintain up to date information. Chemical specific information, including exposure hazards and treatment are provided in the material safety data sheets (MSDS). Each regulated process has defined operating limits for key process variables. The processes are operated within these limits using process controls (hardware and software), trained personnel and alarms/safety shutdown system s. The Stepan Company's Winder Plant also maintains technical documents and specifications related to the design and construction of process equipment. This information in conjunction with operating procedures and trained personnel, provide a basis for establishing inspections and maintenance activities, as well as evaluation of proposed processes and facility changes to ensure safety features in the processes are not compromised. Process Hazard Analysis Stepan Company's Winder Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. Analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigat ion measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The team's findings are summarized in a report and communicated to plant management and all employees associated with the process. All findings are tracked until resolution. The Winder Plant revalidates the process hazards analysis on a five (5) year frequency for the entire life of the process in accordance with the PSM regulation. Operating Procedures The Stepan Company's Winder Plant maintains written procedures and manuals that address various modes of operations such as: ? Process Startup ? Normal Shutdown ? Emergency Shutdown ? Operating Conditions ? Safety and Health Information The procedures are used as a reference for experienced operators and provide a basis for training new operators. Procedures are maintained current. Training Stepan Company's Winder Plant requires all new operators to receive facility safety and health tr aining prior to introduction into their process area for on the job training. The operators begin to work independently once they have demonstrated through tests and/or skill demonstration that they are knowledgeable regarding their duties. All training is documented. Contractor Safety Stepan Company's Winder Plant uses contractors to supplement the work force during periods of increased maintenance or construction. The Winder Plant has procedures in place to ensure contractors: ? Perform work in a safe manner ? Have appropriate knowledge and skills ? Are aware of hazards in the workplace ? Understand responsibilities during an emergency ? Understand site safety rules ? Inform Stepan Company employees of potential hazards The Winder Plant monitors contractor performance at the plant site to ensure they are fulfilling their safety obligations. Management of Change The Stepan Company's Winder Plant has a comprehensive system to manage changes to the process. This system req uires that changes to items such as process equipment, chemicals, and procedures are properly reviewed and authorized by a multi-functional and multi-level review team prior to implementation. Affected drawings, procedures, and/or technology documents are updated to reflect these changes. Pre-Startup Safety Review (PSSR) Stepan Company's Winder Plant conducts a safety review prior to startup of any new facility or facility modification. The purpose of the review is to ensure safety features; procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. The procedure assures construction is completed within design specification and confirms the integrity of the equipment once installed. The procedure also includes process-commissioning tests using non-hazardous fluids to confirm system operations function as desired. Mechanical Integrity The Stepan Company's Winder Plant has a program to maintain process equipment in a safe working condition: Maintenance personnel receive training related to safety and health hazards, emergency response, safe work practices, and maintenance procedures to help ensure they can perform their job in a safe manner. Inspections and tests are performed to help ensure equipment function as intended. Safe Work Practices The Stepan Company's Winder Plant has long-standing safe work practices in place to help ensure worker and process safety. Safety rules, procedures and training provide a system to help ensure operations, maintenance, and contractor activities are performed safely. Incident Investigation The Stepan Company's Winder Plant has a comprehensive incident investigation procedure that promptly reviews all incidents that resulted in, or could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The objective for each investigation is to determine the facts associated with the incident, id entify root cause, develop corrective action, and learn from the incident to prevent recurrence. The investigations are completed using the Winder Plant Safety Team. Compliance Audits To help ensure the process safety management program is functioning properly; The Stepan Company's Winder Plant completes annual audit. Corporate personnel knowledgeable of the regulations conduct audits. The audit team may identify findings that are tracked to completion. Stepan Company is a member of the Chemical Manufacturer's Association (CMA). CMA members participate in a program titled Responsible Care. In addition to internal audits, the Winder Plant participated in a voluntary audit sponsored by the Responsible Care Program in 1998. The purpose of the program is to ensure participating companies have management systems regarding environmental, health, and safety. Chemical Specific Prevention Steps The prevention program summarized in this document is applied to Program 2 and Progra m 3 EPA RMP regulated processes at Winder Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by design error, equipment failure, and human error. The Stepan Company's Winder Plant also has safety features on many processes to help contain/control a release, quickly detect a release, and reduce the consequences associated with a release. The following types of safety features are used in various processes: Release Detection ? Hydrocarbon detectors with alarms ? Smoke detectors ? Video Monitors Release Containment/Control ? Scrubbers and absorbers to remove hazardous materials from process streams ? Automated valves to provide isolation ? Safety Interlock Systems ? Curbing and dikes for containment ? Redundant equipment and instrumentation ? Pressure relief devices Release Mitigation ? Automatic fire suppression and extinguishing systems ? Trained emergency response personnel ? On-site emergency response equipmen t ? Blast resistant building construction 1.5Five-Year Accident History No releases of any of the regulated substances at the Winder Plant have occurred within the last five (5) years that have resulted in fatalities, injuries, or significant property damage on site, or known fatalities, injuries, evacuations, shelter-in-place, property damage, or environmental damage off-site. 1.6Emergency Response Program Stepan Company's Winder Plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to an accidental release of a regulated toxic substance, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel during and after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. Emergency response equipme nt is maintained on site for fire fighting, first aid, and rescue. Members of Stepan Company's Winder Plant's Emergency Response Team (ERT) receive training throughout the year. Emergency response equipment includes: ? Two (2) 2,000 gallon per minute fire pumps ? Approximately 3,000,000 gallons for fire water supply ? 500 gallons of foam extinguishing agent ? Approximately 180 portable fire extinguishers ? Trauma kits for first aid ? Automatic Fire Protection Systems ? Confined Space rescue equipment ? Self Contained Breathing Apparatus (SCBA) ? Incipient fire fighting equipment The overall emergency response program for Winder Plant is coordinated with Barrow County Local Emergency Planning Committee (LEPC). The committee members include local emergency response officials, local government officials, and industry representatives. The Winder Plant has 24-hour communications capability with LEPC officials and the local emergency response agencies. Should an event occur the Barrow C ounty Emergency Management Agency would be notified per Winder's SPCC plan. The Barrow County EMA would then communicate the situation to the public per the protocol in EMA's Annex 17 plan. In addition to LEPC meetings, Winder Plant conducts regular emergency drills that involve the LEPC, local fire department, and Winder Plant's emergency response team. 1.7 Commitment to Accident Prevention Stepan Company's Winder Plant constantly strives to improve the safety of Winder Plant' processes through safety reviews, safety committees, process audits, and a program to solicit safety suggestions from employees. 1.8Certification I hereby certify that to the best of my knowledge the information associated with all RMP regulated processes at the Winder Plant, after reasonable inquiry, is true accurate and complete. Edward T.C. Hyer, Plant Manager |