Uniroyal Chemical Company - Geismar Facility - Executive Summary |
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1433 LDEQ FACILITY ID NUMBER GENERAL Uniroyal Chemical - Geismar began operations in 1962 and has grown from that first production unit to 11 units today. The diversity of products produced range from EPDM rubber, rubber additive products such as those to keep rubber flexible or aid in its vulcanization, anti-oxidants, to agricultural products. Recognizing the growing public concern with chemical exposure, Uniroyal Chemical - Geismar "signed on" to the Ascension Parish CAER ( Community Awareness and Emergency Response ) program in 1985. This organization is part of an on-going effort to maintain communications between industry and the general public with the appropriate law enforcement, emergency response personnel, and environmental agencies. This program integrates well with the existing Geismar Plant Emergency Response Procedures which are contained in the Geismar Policy Manual and include: Disaster Notification, Release Reporting Procedures, Emergency Planning and Response, Emergency Assistance and Notification for Serious Injury, Gas Release Procedure, Hurricane Preparedness, Geismar Mutual Aid, Plant Fire Brigade, Hazwoper Safety and Health Plan, and Unusual Incident Reporting The requirements in the new RMP regulation to prevent accidental releases are being met at the Geismar facility by established programs which include: Operator training and certification, Work Permits, Hazard Communications, Management of Change for Process and Equipment, Process Hazard Analysis, Reports of Unsafe Conditions, Safety Orientations, Emergency response training, Routinely updated operating procedures, Computers and computerized control systems, Emergency control / shutdown devices / interlocks, Equipment / piping safety controls, Warning alarms, Regular safety checks, and Equipment inspections. The company corporate position has been a nd continues to be one of maintaining the safety of its employees and the general public. As part of this continuing improvement, the Geismar Plant is embarking on a program to become registered to the ISO 14001 international environmental standard. RMP REPORTABLE CHEMICALS Of the 140 RMP chemicals, the Geismar Facility handles threshhold quantities of 9 of these chemicals (7 toxic and 2 flammable) with 15 covered processes identified. Whenever possible, chemicals are handled by pipeline to reduce the impact in the event of a leak rather than stock-piling large amounts in storage tanks. This is especially true in the handling of the "worst case" toxic chemical, chlorine, where a pipeline is preferably used over bulk storage with a 90-ton rail car. This exposure is only allowed for a few days every 3 to 5 years when the pipeline must be taken out of service for maintenance and/or inspection. The first 14 identified processes are Program 3 PSM processes which deal with raw mater ial receiving, storage and handling and as such are controlled by all of the above mentioned "prevention" and "emergency response" programs. These chemicals of concern are: Chlorine - Toxic Process #1: A 90-ton rail car of liquid chlorine is brought in and spotted near production unit 61 and is piped to a distribution manifold to provide chlorine for the manufacturing of specialty chemicals in production unit 61 and production unit 80. This covered process is only used in the event that both Processes #2 & #3 are not available for use. Process #2: This covered process consists of a 2" line which transports liquid chlorine from the property line to production unit 80. The line is constructed following the guidelines outlined by the 'Chlorine Institute' and as such is provided with expansion chambers, approved materials of construction, and the appropriate safety devices to allow for safe operation. In addition, the line is equipped with emergency isolation valves which ar e routinely "exercised" to verify performance. Process #3: This covered process consists of a 2" line which transports liquid chlorine from the property line to production unit 61. The line is constructed following the guidelines outlined by the 'Chlorine Institute' and as such is provided with expansion chambers, approved materials of construction, and the appropriate safety devices to allow for safe operation. In addition, the line is equipped with emergency isolation valves which are routinely "exercised" to verify performance. Hydrazine (as hydrazine hydrate) - Toxic Process #4: This covered process consists of a storage tank containing a maximum of 271,500 pounds of 35% hydrazine as a hydrazine hydrate - water solution. The hydrazine solution is either loaded into this tank via a tank truck or from a dilution tank (process #5). The level in this tank is monitored by an unloading technician during this operation. The tank is vented through a refrigerated water vent condenser and is located within a dike capable of containing the entire contents of the tank. Pumps are used to transfer the hydrazine solution to production unit 39. Process #5: This covered process consists of a storage tank containing a maximum of 217,000 pounds of 35% hydrazine as a hydrazine hydrate - water solution. The hydrazine solution is unloaded into this tank as a 55% hydrazine solution and further diluted with water to 35%. The level in this tank is monitored by an unloading technician during this operation. The tank is located within a dike capable of containing the entire contents of the tank. Once diluted, this material may be pumped as needed to process #4 or process #6 storage tanks. Process #6: This covered process consists of a storage tank containing a maximum of 271,500 pounds of 35% hydrazine as a hydrazine hydrate - water solution. The hydrazine solution is either loaded into this tank via a tank truck or from a dilution tank (process #5). The level i n this tank is monitored by an unloading technician during this operation. The tank is vented through a refrigerated water vent condenser and is located within a dike capable of containing the entire contents of the tank. Pumps are used to transfer the hydrazine solution to production unit 61. Cyclohexylamine - Toxic Process #7: This covered process consists of a storage tank containing a maximum of 100,000 pounds of cyclohexylamine. The cyclohexylamine is loaded into this tank from a tank truck. The level in this tank is monitored by an unloading technician during this operation. The tank is located within a dike capable of containing the entire contents of the tank. A pump is used to transfer the cyclohexyamine to production unit 80. Carbon Disulfide - Toxic Process #8: This covered process consists of a storage tank containing a maximum of 240,000 pounds of carbon disulfide. The carbon disulfide may either be unloaded into this tank by a rail car (process #9 ) or by a tank truck. The level in this tank is monitored by an unloading technician during this operation. The tank is also equipped with redundant level indicators and a high level alarm. The tank is located within a dike which has a dedicated quantity of water kept in it in order to maintain a hydraulic seal in the event of a spill. The special dike is large enough to contain the entire contents of the tank along with the seal water. Process #9: A rail car containing 109,000 pounds of carbon disulfide is brought in and spotted to unload to the process #8 storage tank. Ammonia, anhydrous - Toxic Process #10: This covered process consists of a storage tank containing a maximum of 120,000 pounds of anhydrous ammonia. The liquefied ammonia is loaded into this tank from a tank truck via a compressor. This tank is supplied with redundant relief valves. This operation is monitored by an unloading technician. This ammonia is then transferred primarily to production unit 39 and production unit 37. Ammonia, as aqueous 24% - Toxic Process #11: This covered process consists of a storage tank containing a maximum of 41,000 pounds of 24% aqueous ammonia. Process water is added to the tank to maintain a prescribed level (generally 50%) and anhydrous ammonia from the process #10 storage tank is added to maintain the desired concentration. This dilute ammonia is then pumped to production unit 37. The storage tank is equipped with level control, high level, low level, and temperature alarms, pH control and a density alarm. It is also located within a dike capable of containing the entire contents of the tank. 1,1-Dimethylhydrazine - Toxic Process #12: This covered process is only operated 2 or 3 months of the year and consists of a storage tank containing a maximum of 104,000 pounds of 1,1-dimethylhydrazine. The 1,1-dimethylhydrazine is unloaded into this tank by a tank truck. The level in this tank is monitored by an unloading technici an during this operation. The tank is equipped with a vent seal pot and scrubber and level indicators. Operating technicians are certified annually for this operation. The tank is located within a dike capable of containing the entire contents of the tank. 2-Methylpropene - Flammable Process #13: This covered process consists of a storage tank containing a maximum of 240,000 pounds of liquefied 2-methylpropene. The 2-methylpropene is unloaded into this tank either by a rail car (process 14) or a tank truck. The tank is equipped with redundant relief valves, level and pressure indication, and a remote activated emergency shut-off valve. Even though any leaks would immediately vaporize, the tank is bermed and equipped with a deluge system and water curtain. Process #14: A rail car containing 160,000 pounds of liquefied 2-methylpropene is brought in and unloaded into the process #13 storage tank. The unloading operation is monitored by a technician. The unloading spot is equipped with a deluge system. Propylene - Flammable Process #15: The last identified process is a refrigeration unit which handles a reportable quantity of propylene (a flammable) as the refrigerant. Although it is not a raw material and subject to significant handling, all of the same "prevention" and "emergency response" programs still apply. GENERAL PROCESS USE TOXIC: Anhydrous Ammonia and Hydrazine are unloaded into storage tanks and together with chlorine are used in the manufacture of products which produce the foaming action in sponge products. Hydrazine, aqueous Ammonia, and 1,1-Dimethylhydrazine are also unloaded into storage tanks and used to produce agricultural products. Carbon Disulfide and Cyclohexylamine are brought into storage tanks and together with chlorine are used in the production of products used in the rubber vulcanization process. FLAMMABLE: 2-Methylpropene is unloaded in a storage tank and is used in the production of an anti-oxidant. Pro pylene, where significant levels are accumulated, is used as a refrigerant in the synthetic rubber manufacturing units. 5 YEAR ACCIDENTAL RELEASE HISTORY There has been one on-site reportable injury associated with chlorine inhalation in the past 5 years. The release was determined to be less than 10 pounds and had no impact off-site. The recommendations and resolution of this incident included: Revision of the Standard Operating Procedure, Removal of a non-essential piece of equipment, Review of the incident with appropriate personnel, and Replacement of a defective check valve. In the event of an emergency situation, the Geismar plant has a nurse, a certified team of medical first responders and on-site response tools to handle an environmental situation as per 1910.120(q). Also, in place, are fully equipped fire brigade personnel who are regularly drilled to handle fire fighting situations. RELEASE SCENARIOS "WORST CASE" Toxic Release Process #1 : Chlorine Release of the entire contents of a 90 ton rail car in 10 minutes with the distance to toxic endpoint of 14 miles. Mitigation and Control measures - A rail car would be brought in as a last resort only if the pipeline was not available due to maintenance or an inspection. No other passive controls are considered for this case. In the event a rail car is used, a process review is conducted prior to the car being brought on site and the car would be monitored during use. "ALTERNATE CASE" Toxic Releases Process #2 : Chlorine Normal chlorine supply to Area 80 via pipeline fails due to gasket failure at a flange resulting in a 50 pound per minute release eventually emptying the entire 5,000 pounds contained within the line in 100 minutes. The distance to toxic endpoint would be 0.1 mile. Mitigation and Control measures - No passive controls are considered. Since the entire line is regularly ultrasonically thickness inspected and monitored for corrosion rate, l arger release rates as the result of corrosion were deemed unlikely. The main emergency automated valve is also exercised weekly to verify proper operation. Process #3 : Chlorine Normal chlorine supply to Area 61 via pipeline fails due to gasket failure at a flange resulting in a 50 pound per minute release eventually emptying the entire 6,000 pounds contained within the line in 120 minutes. The distance to toxic endpoint would be 0.1 mile. Mitigation and Control measures - No passive controls are considered. Since the entire line is regularly ultrasonically thickness inspected and monitored for corrosion rate, larger release rates as the result of corrosion were deemed unlikely. The main emergency automated valve is also exercised weekly to verify proper operation. Process #5 : Hydrazine An unloading hose fails on an undiluted water solution of 55% hydrazine. 860 pounds per minute of this solution is released for 10 minutes before the appropriate valving is closed and the flow can be stopped. The distance to toxic endpoint would be 0.19 miles. Mitigation and Control measures - There are no passive controls considered with this portion of the process. The unloading technicians are present during this operation to monitor the transfer. Process #7 : Cyclohexylamine The storage tank is overflowed at 726 pounds per minute for 10 minutes before the release can be detected and stopped. The distance to toxic endpoint would be 0.2 miles. Mitigation and Control measures - The tank is contained within a dike capable of holding the entire contents of the storage tank. Other mitigating factors include the installation of a hydrocarbon detector in the area, unloading technicians monitoring the operation, and a foam applicator available in the area to minimize evaporation. Process #8 : Carbon Disulfide A leak develops in the transfer line between the storage tank and the process area which releases 30 pounds per minute for 60 minutes before i t is discovered, isolated and stopped. In this case the distance to toxic endpoint would be 0.1 mile. Mitigation and Control measures - The storage tank is contained in a dike maintained with a level of water in it capable of completely 'enclosing' the total contents of the tank. There are also process area dikes and trenches with multiple hydrocarbon detectors to detect and contain releases. Process #10 : Ammonia, anhydrous The relief valve on the storage tank relieves either due to overfilling or from a malfunction and relieves at its capacity of 393.6 pounds per minute. 10 minutes is allowed to detect and stop the release. The distance to toxic endpoint would be 0.2 miles. Mitigation and Control measures - A 'back-up' relief valve is installed and if needed in the event of failure,it would be activated by a valve. Process #11 : Ammonia, 24% aqueous The storage tank overflows at 76.7 pounds per minute due to a malfunctioning level control and releases 767 pounds be fore the operating technician responds and valves off the make-up water. The distance to toxic endpoint would be 0.1 mile. Mitigation and Control measures - The tank is provided with level control and alarms to alert to high and low level conditions. The tank is also contained within a dike. The level is also inspected and logged daily with checks once per shift. Process #12 : 1,1-Dimethylhydrazine The unloading hose fails releasing 650 pounds per minute for 0.5 minutes before the emergency valve can be closed. The distance to toxic endpoint would be 0.7 miles. Mitigation and Control measures - The tank truck is unloaded on a diked pad capable of containing the entire truck contents. An unloading technician monitors the truck during the unloading operation and the truck is equipped with a quick-closing internal valve. "WORST CASE" Flammable Release Process #13 : 2-Methylpropene Release of the maximum 240,000 pounds from the storage tank within 10 minutes to produce a vapor cloud explosion which generates a 1 psi pressure endpoint at a distance of 0.5 miles. Mitigation and Control measures - No passive mitigation considered. The storage tank is provided with its own containment dike, deluge protection and hydrocarbon detection. The tank level is inspected and logged routinely. "ALTERNATE CASE" Flammable Release Process #15 : Propylene The maximum possible capacity of 140,000 pounds of propylene refrigerant is released from the refrigeration unit in 10 minutes and produces a vapor cloud which generates a 3% yield vapor cloud explosion. The distance to a 1 psi overpressure would be 0.2 miles. Mitigation and Control measures - No passive mitigation considered. The refrigeration unit is equipped with a deluge system and hydrocarbon detector. Operating conditions and levels are monitored and recorded routinely during the day. |