Kerr-McGee Pigments (Savannah), Inc. - Executive Summary

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Kerr-McGee Pigments (Savannah), Inc. owns and operates a chloride-based Titanium Dioxide (TiO2) manufacturing plant located at One Kerr-McGee Road in Savannah, Georgia, 31404.  Kerr-McGee's Chloride TiO2 process is subject to section 112(r) EPA's rules for accidental release prevention because of the presence of Chlorine (Cl2) and Titanium Tetrachloride (TiCl4) in greater than threshold amounts.   The 112(r) rules require that Kerr-McGee prepare a Risk Management Plan (RMP) complying with Program 3 level requirements since the process is also subject to OSHA's Process Safety Management standard. 
It is Kerr-McGee's policy to operate its Savannah, Georgia plant in a manner that minimizes Cl2 and TiCl4 emissions and best protects its employees, the public, and the environment should a release occur.   
Kerr-McGee uses Cl2 gas to produce TiCl4, an intermediate product in the process.  The TiCl4 is purified and used to produce TiO2 and byproduct Cl2.  The byproduct Cl2 is recycled to the b 
eginning of the process as the primary Cl2 feedstock.  Virgin Cl2 is the source of the small fraction of the total Cl2 feed that is not recycled Cl2.   
Virgin Cl2 is supplied and stored in 90-ton railcars as a refrigerated liquid.  The liquid Cl2 is vaporized to Cl2 gas before being brought into Kerr-McGee's process and there is no usage or storage of liquid Cl2 within Kerr-McGee's process equipment.  TiCl4 is a liquid at ambient conditions with a boiling point of 136.4 ?C (277.5 ?F).  It is present in the process as both a liquid and a heated gas. 
Either Cl2 or TiCl4 can form a toxic gas cloud containing highly corrosive vapors when released to the atmosphere in sufficient quantity.  For purposes of this RMP, the worst-case release scenario involves the complete release of the contents of a 90-ton Cl2 railcar over a 10-minute period under worst case meteorological conditions. EPA's RMP*Comp computer model indicates for this scenario that off-site Cl2 concentrations greater the RMP t 
oxic endpoint would extend to 14 miles.   However, such an extreme release is highly unlikely.   
The RMP alternative release scenario for Cl2 is based on the largest recorded release from the process.  This occurred on April 21, 1998 when 1,360 pounds of about 2 % Cl2 gas were released from a 200-foot stack over 85 minutes due to a process upset caused by operator error.  The RMP*Comp computer model indicates that the toxic end point for this scenario would be at 0.1 miles and thus concentrations above the toxic end point would not extend off site 
The alternative release scenario for TiCl4 is based on a March 31, 1998 release of 300 pounds over 45 minutes from a Still Reboiler Pump's packing.  The cause of the release was a combination of worn packing and loss of the nitrogen purge to the packing gland.  The liquid TiCl4 at this point is at 150 ?C, which is higher than the normal boiling point of 136.4 ?C, and thus is a liquefied gas under pressure.  Since the TiCl4 is liquefied gas  
under pressure, its release was modeled as a gas release. The RMP*Comp computer model indicates that the toxic endpoint for this scenario would be at 0.1 miles under normal weather conditions and thus concentrations above the toxic end point would not extend off site. 
There have been three instances over the last five years where on-site personnel received medical attention due to exposure to a Cl2 release.  There was also one instance where personnel received medical attention due to exposure to a TiCl4 release.  There were no deaths, property damage or off-site impacts associated with these releases. 
Kerr-McGee has an OSHA PSM program in place that satisfies the requirements under the 112(r) rules for a program to prevent accidental releases of Cl2 and TiCl4.  The fourteen elements of the PSM program include employee participation, process safety information, process hazard analysis, operating instructions, training, contractors, pre-startup safety review, mechanical integrity, hot 
work permits, management of change, incident investigation, emergency planning and response, and trade secrets.  The Engineering, Plant Technical Services, Safety, and Environmental Departments provide considerable support to the Production and Maintenance Departments in the implementation of the PSM program. 
Kerr-McGee's accidental release prevention program includes among other things:  Cl2 and HCl gas detectors; automatic and manual shutoff valves; excess flow shutoff valves on railcars; multistage scrubber systems; adherence to industry design standards and Chlorine Institute standards; an active mechanical integrity program; Hazard and Operability Analysis (HazOp) for all new or modified equipment to identify and correct potential safety problems; DCS computer process control; continuous computer and operator monitoring of processes; controlled entry and work in and around process equipment (work permit system); contractor safety program; and emergency shutdown procedures 
McGee also has emergency response procedures in place for dealing with toxic releases, fires, bomb threats, and hurricanes.  Among other things, these procedures address public notification and emergency medical care.  Kerr-McGee coordinates its responses to toxic releases with the Savannah Fire Department. 
Kerr-McGee emergency response program includes among other things:  written plant emergency plans and drills; a trained incipient Fire Brigade; emergency response equipment, including full fire fighting apparatus, located throughout the plant; C-Kits for stopping Cl2 railcar valve leaks; joint training and response with Savannah Fire Department; on-site Medical Department; trained first responders on duty 24-hours a day; gas detectors with alarms; plantwide notification system; emergency shutdown systems and procedures; response by Savannah Fire Department within minutes; an Emergency Operations Center; and a SAFER computer system that can predict impacted areas on and off site.   
Kerr-McGee has an ongoing program to upgrade its chlorination and oxidation scrubber systems within the Chloride TiO2 process to reduce the potential for releases due to process upsets and emergency conditions such as power failures.  Kerr-McGee is also upgrading the Cl2 detection sensors at its Cl2 railcar unloading facility.
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