Henkel Corporation/Charlotte, NC Mfg. Plant - Executive Summary
The Cognis Corporation Charlotte, NC facility considers protection of employees, the public and the environment to be its most important responsibility. A key element of its protection program is the development and implementation of plans to prevent accidental chemical releases. In addition, if an accidental release should occur, the facility is prepared to respond in an organized and effective manner.
The Cognis Corporation Charlotte, NC facility accident prevention and emergency response programs have been developed in accordance with federal and state regulations, industry standards, and guidance from Mecklenburg County emergency response organizations. Although the facility's programs have been highly successful - the facility has never had a significant chemical release - the facility continually seeks ways to improve its prevention and response programs.
This document, the Risk Management Plan (RMP) for the facility, was prepared to comply with federal r
egulatory requirements regarding the prevention of accidental chemical releases (40 CFR Part 68 Accidental Release Prevention Requirements). The purpose of the regulation is to reduce the potential for an accidental chemical release and strengthen emergency response planning at the facility and within the community. The RMP describes the incident at the facility which would have the most catastrophic effects ("the worst case") and several scenarios of lesser magnitude ("alternative cases"). Although it is technically infeasible for the worst case described in this report to occur, worst case information is provided to support conservative emergency response planning. In this way, the community is well prepared to respond to the lesser magnitude scenarios, which are more likely to occur.
Areas that could be impacted by an accidental chemical release were identified using PHAST software. PHAST is a very sophisticated, EPA-recognized program specifically designed for accidental chem
ical release modeling. Cognis invested in this software to ensure that it had access to the most accurate emergency planning data available.
Cognis Corporation, which was previously Henkel Corporation, is now a wholly owned subsidiary of the Henkel Group, headquartered in Dusseldorf, Germany. Cognis Corporation manufactures products that improve people's lives. Cognis produces chemical ingredients that are used in many industries including personal care (such as soap and shampoo), nutrition, automotive, construction, paint and agriculture. The Henkel Group has more than 55,000 employees serving in more than 330 companies in 70 nations.
Respect for the environment is a central tenet of Cognis. Henkel Corporation was cited by the U.S. Environmental Protection Agency as an Environmental Champion for our performance in the voluntary 33/50 pollution prevention program. Cognis voluntarily participates in the Chemical Manufacturers' Association Responsible Care ? i
nitiative and is implementing its environmental, health and safety codes of practice on a worldwide basis.
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
It is the policy of the Cognis Corporation Charlotte, NC facility to prevent all releases of potentially harmful substances. Senior management is responsible for release prevention and response programs and the facility has invested extensive time and resources in this effort.
The facility has detailed procedures, which ensure that safety is considered in the design, installation, operation, and maintenance of each process. Facility personnel receive regular safety training and employee input is solicited on every aspect of safety improvement. Failure to follow safety policies is grounds for dismissal.
If a release were to occur, trained facility personnel would control and contain the release. The standard procedure is to technically evaluate each situation, identify potential on-site and off-site impacts, evacuate wor
kers as necessary, contain the release and contact the local fire department to provide the necessary emergency response services.
DESCRIPTION OF STATIONARY SOURCE
The Cognis Corporation Charlotte, NC facility is a chemical manufacturing facility located at 3300 Westinghouse Boulevard. The facility operates a variety of processes to produce many specialty chemicals for the textile, paper and coatings industries. The facility has a broad range of manufacturing capabilities, including proprietary blending and complex esterification and ethoxylation reactions. Built in the early 1970's, the 63-acre facility has undergone a $20 million upgrading and modernization program since 1987 which has helped to make the facility a leader in productivity, process control and environmental stewardship.
The facility has a 1.39 million-gallon biological wastewater pretreatment system that is able to process the wastewater generated throughout the facility.
The facility is subject to numerous
environmental, health and safety regulations and is regularly inspected by agency representatives. The following activities are specifically regulated: (1) Air Emissions: Regulated by various air permits issued by Mecklenburg County Department of Environmental Protection; (2) Wastewater; Discharge regulated by permit issued by Charlotte-Mecklenburg Utility Department;
(3) Storm water Discharge regulated by permit issued by NC Department of Environment, Health, and Natural Resources; (4) Hazardous Waste Generation Activity under ID# NCDO62567623; (5) Process Safety Subject to OSHA Process Safety Management Rule; (6) Emergency Planning Subject to SARA 311/312 Reporting; (7) Release Reporting Subject to SARA 313 (ID #28241HNKLC3300W).
DESCRIPTION OF REGULATED SUBSTANCES
The facility handles two substances regulated by the RMP rule in sufficient quantities to be covered by the RMP rule: epichlorohydrin and ethylene oxide (EO). The RMP rule classifies these chemicals as toxic su
bstances. There are no regulated flammable substances at the threshold quantity at this facility. Since epichlorohydrin and ethylene oxide are used in the following processes, these processes are covered by the RMP Rule:
Process Program Level Regulated Substance
Ethoxylation 3 Ethylene Oxide
UV Esters Production 3 Epichlorohydrin
OFFSITE CONSEQUENCE ANALYSIS
Following EPA guidance, the facility performed an offsite consequence analysis (OCA) to determine the potential for an accidental release of a regulated substance that could have an impact on the public or the environment. The OCA consists of evaluating both worst-case scenarios (WCSs) and alternate release scenarios (ARSs). Based on facility design and prevention programs, the facility does not believe the worst-case release scenario could ever occur. Although it is also highly unlikely that the ARS would occur, the ARS represents a release that is more likely to occur during the lifetime of a facility like
the Charlotte facility.
The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The concentration at the endpoint represents the maximum concentration below which nearly all people can be exposed for up to one hour without experiencing irreversible or serious health effects or symptoms which could impair the ability to take protection action.
WORST-CASE RELEASE SCENARIOS
The worst-case scenario (WCS) at the Charlotte facility is a catastrophic failure in the ethylene oxide (EO) storage tank resulting in a release of 290,600 pounds of EO over a 10-minute period. The EO tank is surrounded by a dike. In the event of a release, the dike would contain the released EO, which would evaporate, forming a vapor cloud. The maximum distance to the toxic endpoint is 6.34 miles. EPA defines the toxic endpoint as that point where the concentration of EO is 50
ppm (0.090 milligrams per liter). Although the facility has numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or active mitigation measures were taken into account when calculating the distance to the endpoint. In other words, the facility has provided the worst case estimate of the impact area.
The facility has modern, redundant systems designed to prevent this scenario from ever happening. These systems are described in further detail in the section on Chemical Specific Prevention Steps.
ALTERNATE RELEASE SCENARIOS
The alternative release scenario (ARS) for EO is a failure of the seal in the loading arm boom attached to the rail car during the EO unloading process, resulting in a release of 1044 pounds over 60 minutes. The 60-minute release duration is the approximate time needed to identify and stop the release. Failure of the seal was chosen as the potential release because, historically, seals have been a r
elease point for operations of this type in the chemical industry. The maximum distance to the endpoint of 50 ppm (0.090 milligrams per liter) is 555 feet.
The ARS for epichlorohydrin is a leak in the tank outlet line resulting in a release of approximately 1000 pounds over a 15-minute period. The 15-minute release duration is the approximate time needed to identify and stop the release. A leak in the line was chosen as the potential release because, historically, line leaks have been a release point for operations of this type in the chemical industry. The tank is surrounded by a dike, which would contain the release. A diked area of approximately 1000 ft was taken into account as a mitigation measure to control the release. The maximum distance to the endpoint of 20 ppm (0.076 milligrams per liter) for this ARS is 323 feet.
FIVE YEAR ACCIDENT HISTORY
The Charlotte manufacturing facility has an excellent record of accident prevention. The RMP rule requires facilitie
s to report all significant releases from regulated substances during the last 5 years. The following summarizes the 5 Year Accident History:
1994: No RMP Events with On-Site or Off-Site Effects
1995: No RMP Events with On-Site or Off-Site Effects
1996: No RMP Events with On-Site or Off-Site Effects
1997: No RMP Events with On-Site or Off-Site Effects
1998: No RMP Events with On-Site or Off-Site Effects
1999 year to date: No RMP Events with On-Site or Off-Site Effects
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The Charlotte facility has invested extensive time and resources into developing programs to prevent accidental chemical releases. Collectively, these programs prevent accidental releases caused by equipment failure or human error. Following is a summary of the general accident prevention program at the facility:
The Charlotte facility understands that employee involvement is crucial to the success of an accident prevention program.
The facility aggressively encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation include updating and compiling technical documents, reviewing chemical safety information, and participating in process hazard analyses (PHAs). Employees have access to extensive process and chemical safety information. Employee involvement in safety programs is documented in the facility's Process Safety Manual.
Process Hazard Analysis (PHA)
Safe operation of a process starts with a detailed identification of the hazards associated with the process. The Charlotte facility has a comprehensive program to help ensure that hazards associated with each process are identified and controlled. To do this, each process at the facility is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.
The facility primarily uses the hazard and operability (HAZOP) analysis
technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of trained personnel who have operating and maintenance experience as well as engineering expertise. The team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.
PHA team findings are submitted to the plant manager for resolution. Implementation of mitigating options in response to PHAs is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is docum
ented and retained.
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the facility periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained.
Process Safety Information
In order to operate a process safely, facility personnel need accurate, detailed information about the process and any associated hazards. The Charlotte facility maintains extensive technical information about the safe operation of its processes. These documents address chemical properties and associated hazards, limits for key process parameters and specifi
c chemical inventories, and equipment design basis/configuration information. Specific departments within the facility are assigned responsibility for maintaining up-to-date process safety data. A table summarizing the reference documents and their location is readily available in the Process Safety Section of the PSM Manual.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) within the batch cards and operating procedures. The facility ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).
The facility also maintains numerous technical documents that provide information
about the design and construction of process equipment. The information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Operating personnel have complete access to the information described above.
To ensure that personnel operate equipment in accordance with all safety precautions, the facility maintains detailed written operating procedures. The procedures describe the safety considerations unique to specific operating modes, e.g
- unit startup,
- normal operations,
- temporary operations,
- emergency shutdown,
- normal shutdown, and
- initial startup of a new process.
These procedures are used as a referen
ce by experienced operators and provide a basis for consistent training for new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change (MOC) process that is explained in greater detail in a subsequent section.
In addition, the facility maintains batch cards and operating procedures that provide guidance on how to respond to upper and lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.
To complement the written procedures for process operations, the facility has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic
training in facility operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate adequate knowledge to perform duties and tasks in a safe manner on their own, they can work independently. Refresher training for all operators is conducted every 3 years. Each training program includes a method of verifying that the operator understood the training through verbal confirmation and written tests. All training is documented.
The facility uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors:
- perform their work in a safe manner,
- have the appropriate knowledge and skills,
- are aware of the hazards in their workplace,
- understand what they should do in the event of an em
- understand and follow site safety rules, and
- inform facility personnel of any hazards that they find during their work.
This is accomplished by providing contractors with:
- a process overview,
- information about safety and health hazards,
- emergency response plan requirements, and
- safe work practices prior to their beginning work.
In addition, the facility evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Reviews (PSSRs)
The facility conducts a PSSR for any new process or process modification that requires a change in process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are prepared before placing the equipment into service. This review provides one additional check to make sure construction is
in accordance with design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that process safety management and accident prevention program requirements are properly implemented.
The facility has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include:
- conducting training,
- developing written procedures,
- performing inspections and tests,
- correcting identified deficiencies, and
- applying quality assurance measures.
In combination, these activities form a system that maintains the mechanical integrity of the process equipment.
personnel training includes an overview of the process, safety and health hazards, applicable maintenance procedures, emergency response plans, and applicable safe work practices. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service. If the required parts or equipment are not available, an MOC team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment until the required deficiency can be corrected. The equipment will not be placed back into service unless the MOC team can adequately address the modifications required for the safe operation of th
Another integral part of the mechanical integrity program is quality assurance. The facility incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that the new equipment is suitable for its intended use and that proper material and spare parts are used when repairs are made.
Safe Work Practices
The Charlotte facility has long-standing safe work practices to ensure employee and process safety. Examples of these include:
- control of the entry/presence/exit of support personnel,
- a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance,
- a procedure for safe removal of hazardous materials before process piping or equipment is opened,
- a permit and procedure to control spark-producing activities (i.e., hot work), and
- a permit and procedure to ensure those adequate precautions are in place before entry into a confined space.
These procedures (and others), along with traini
ng of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
Management of Change
When making a change to a process, a facility must be careful that it does not inadvertently introduce any unanticipated hazards or disrupt any control or safety system. To prevent such mistakes, the Charlotte facility has a comprehensive system to manage changes to processes. This system requires that changes to process equipment, chemicals, technology and procedures be properly reviewed and authorized before being implemented. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with the necessary training on the change.
The facility promptly investigates all incidents that resulted in, or could have resulted in, a serious situation, e.g. a fire or explo
sion, a toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation results are sent to the facility manager for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are completed. The final resolution of each finding or recommendation is documented, and the investigation results reviewed with all employees (including contractors) who could be impacted by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.
The help ensure that the accident prevention program is functioning properly, the Charlotte facility periodically conducts an audit to determine whether the procedures and practices required by
the accident prevention program are being implemented. Compliance audits are conducted a least every 3 years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to the facility manager for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent reports are retained.
CHEMICAL SPECIFIC PREVENTION STEPS
In addition to the general accident prevention program described above, the Charlotte facility has installed specific safety features on many units to help:
- quickly detect a release
- contain or control a release, and
- reduce the consequence of (mitigate) a release.
The following types of safety features are used in various processes:
- Chemical detectors with alarms
- Process alarms
Release Containment and Control
- Scrubber to neutralize chemi
- Valves to permit isolation of the process (manual or automated)
- Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
- Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank)
- Curbing or diking to contain liquid releases
- Redundant equipment and instrumentation
- Fire suppression and extinguishing systems
- Deluge system for specific equipment
- Trained emergency response personnel
- Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)
- Blast-resistant buildings to help protect control systems and personnel
EMERGENCY RESPONSE PROGRAM INFORMATION
The Charlotte facility maintains a written emergency response program, which is in place to protect workers, public safety, as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a f
ire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the facility has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as policies that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based upon modifications made to the facility processes or other facility changes. The emergency response program changes includes informing and/or training affected personnel in the modifications.
The overall emergency res
ponse program for the Charlotte facility was submitted to the Mecklenburg County Local Emergency Planning Committee (LEPC). This organization coordinates emergency response in the Charlotte area. This includes periodic meetings of the committee with local emergency response officials, local government officials, and industry representatives. The emergency response plan has provisions so that immediate communication can be established with the appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. The facility conducts periodic emergency drills that involve emergency response organizations, and the facility provides refresher training to local emergency responders regarding the hazards of regulated substances in the facility.
PLANNED CHANGES TO IMPROVE SAFETY
The Charlotte facility constantly strives to improve the
safety of the processes through periodic safety reviews, the incident investigation program, and incorporating safety suggestions from the workers. The following types of changes are planned:
- Upgrade process control systems to distributed control
- Increase radio equipment
- Added safety equipment at railcar loading stations
- Upgrade epichlorohydrin feed system