Atofina Chemicals, Inc. - Riverview, MI - Executive Summary
A Risk Management Program has been implemented at Atofina Chemical's Riverview Plant for the reduction of accidental releases of hazardous materials. This Risk Management Plan summarizes
the management, administrative, procedural, and technological controls that work together to
minimize the risk to the community of hazardous chemical releases. The Plan summary is organized to correspond with specific EPA RMP definitions and requirements, including:
Atofina Chemical's policies to protect health, environment, and safety;
Five-Year Accident History;
Emergency Response Plan;
Planned changes to improve safety; and,
Clean Air Act Amendments Title V Permit Status.
Atofina Chemical's Policies for Health, Environment, and Safety
Risk management and safety have been important concerns at Atofina Chemical for many years; this RMP formalizes and documents these activities. Atofina Chemi
cal is committed to conducting itsoperations in a safe, responsible manner and to reducing risks to health and the environment.
This commitment to health, environment, and safety (HES) starts with the CEO. Senior management routinely dedicates time to a review of HES matters, including safety. This emphasis on safety is carried through to the facility level, where the management team and the Safety Champions Committee regularly review safety performance, take corrective actions, and strive for continuous improvement. The success of Atofina Chemical's HES programs is also reflected by a strong commitment to safety by employees and contractors.
Atofina Chemical's HES programs include policies, procedures, standards, and guidance materials
designed to fulfill Atofina Chemical's commitment to health, environment, and safety. These materials include Risk Management Program guidance to help our facilities prevent and/or reduce the risk of accidents.
The safety of Atofina Chemical emplo
yees and area residents is OUR FIRST PRIORITY. We are
committed to responsible chemical processing and handling. As an example of our commitment the plant and the Paper, Allied-Chemical & Energy Workers Union, Local 6-0591 have joined together to implement the Triangle of Prevention (TOP) Program to further enhance safety, health, and protection of the environment.
Atofina Chemical's Policies for Health, Environment, and Safety (Continued)
Atofina Chemical takes pride in our commitment to protect the environment. We are dedicated to
continuous reduction of waste, and have a comprehensive program called AWARE (Atochem Waste And Release Elimination) designed to promote recycling and waste minimization. We have substantially reduced waste and emissions in recent years. Our Plant goals also support reductions of waste and emissions.
Atofina Chemical also participates in the Chemical Manufacturers Association Responsible Care
initiative. Through Responsible Care, our company a
nd our industry demonstrate our continuing
commitment to health, safety, and the environment.
Facility Identification and Regulated Substances in Covered Processes
The Atofina Chemical Riverview Plant is located at 17168 West Jefferson Avenue, Riverview, Michigan. The facility manufactures industrial chemicals, primarily amines and acids. Our products are used to produce a wide variety of products including photographic products, pharmaceuticals, electronics, cosmetics, paints, cleaners, tires, water treatment products, and agricultural chemicals.
Certain substances used and produced within the facility are regulated under 40 CFR Part 68, the
EPA Risk Management Program (RMP) Rule. These substances are present at or above the
minimum threshold for RMP applicability. These substances and the approximate maximum
quantities handled at any one time are:
Ammonia (anhydrous) 750,000 lbs.
Chlorine 4,300,000 lbs.
Dimethylamine 420,000 lbs.
amine 930,000 lbs.
Ethylene oxide 930,000 lbs.
Ethyl mercaptan 38,000 lbs.
Furan 130,000 lbs.
Isopropylamine 500,000 lbs.
Methylamine 250,000 lbs.
Methyl mercaptan 1,000,000 lbs.
Propane 255,000 lbs.
Propylene oxide 138,000 lbs.
Facility Identification and Regulated Substances in Covered Processes (Continued)
Ammonia, chlorine, dimethylamine, ethylene oxide, ethyl mercaptan, furan, isopropylamine,
methylamine, methyl mercaptan, and propylene oxide are used as process feedstocks. Ethylamine is produced as a product and is also used as a process feedstock. Propane is used as a back-up fuel for the plant steam boilers.
The EPA regulations specify that facilities include in their RMP an analysis of a worst case accident (one where all safety systems fail at the same time) for listed toxic chemicals and for listed flammables. The regulations also specify that alternative accidents (ones that
are more realistic) be included.
Hazard Assessment - Worst Case Scenario
The toxic worst-case accidental release scenario is a catastrophic failure of a chlorine railroad tank car containing 180,000 pounds. This quantity was assumed to be released over 10 minutes in the worst-case scenario. Hazard assessment modeling shows that, under worst-case weather conditions, the worst-case toxic release could produce a chlorine plume that could travel more than 25 miles before dispersing enough to no longer pose a hazard to the public.
The flammable worst-case accidental release scenario is a catastrophic failure of a propane tank
containing 130,000 pounds. This quantity was assumed to be released instantly in the worst case
scenario resulting in a vapor cloud explosion. Hazard assessment modeling shows that the worst-case flammable release could produce a vapor cloud explosion that could impact an area at distances up to 0.41 miles, at a force up to 1.0 pound per square inch.
ld be noted that the worst-case scenarios are extremely unlikely events. For a worst-case
scenario to occur, all of these would have to happen:
Everything held in the largest vessel is released;
All of the chemical in the vessel is released very quickly/instantaneously;
All safety controls fail at once;
There is no strong wind or moderate breeze to dilute vapors; and
No mitigating action is taken.
This Risk Management Plan includes information on mitigation and prevention measures
implemented by Atofina Chemical to reduce the risk of these types of events.
Worst-Case Release Mitigation Measures
The multiple layers of preventive measures make it very unlikely that a significant chlorine or
propane release will occur. In addition, in the unlikely event that a release occurs Atofina Chemical has an array of mitigation measures to reduce any potential impacts.
Active mitigation systems cannot be considered in modeling worst-case scenario impacts, but
significant investment that Atofina Chemical has made in active mitigation measures should effectively reduce the risk associated with an RMP incident. These include:
Installed chlorine leak detectors at the chlorine railroad unloading station to provide early
warning of a potential release;
Chlorine unloading is under continuous observation by operators to provide early warning
of a potential release;
Chlorine railroad tank cars are equipped with excess flow shut-off valves which will activate
in the event of a pipeline or hose rupture; and
Propane tanks and piping are frequently inspected by operators and supervisors to detect
Hazardous Assessment - Alternative Release Scenario
One alternative scenario for each regulated toxic substance was modeled in the hazard assessment. A description of each of these scenarios and the modeled distance of potential impacts follows: The Alternative Release Scenario for anhydr
ous ammonia is a railroad tank car unloading line leak, and the ammonia plume was estimated to go 0.24 miles before dispersing enough to no longer pose a hazard to the public. The Alternative Release Scenario for chlorine is railroad tank car unloading line hose rupture, and the chlorine plume was estimated to go 1 mile before dispersing enough to no longer pose a hazard to the public. The Alternative Release Scenario for ethylene oxide is a tank overfill, and the ethylene oxide plume was estimated to go 0.2 miles before dispersing enough to no longer pose a hazard to the public. The Alternative Release Scenario for furan is a tank truck unloading line leak, and the furan plume was estimated to go 0.5 miles before dispersing enough to no longer pose a hazard to the public. The Alternative Release Scenario for methyl mercaptan is a railroad tank car unloading line leak, and the methyl mercaptan plume was estimated to go 0.28 miles before dispersing enough to no longer pose a hazard
to the public. The Alternative Release Scenario for propylene oxide is a railroad tank car unloading line leak, and the propylene oxide plume was estimated to go 0.05 miles, which does not extend beyond the plant property.
Hazardous Assessment - Alternative Release Scenario (Continued)
One alternative scenario representing all regulated flammable substances was selected and modeled in the hazard assessment. A description follows: The Alternative Scenario selected is for a release of dimethylamine from a railroad tank car unloading line failure causing a vapor cloud explosion. The distance impacted by the explosion is 0.05 miles, which does not extend beyond the plant property.
The Alternative Release Scenarios described are somewhat more likely than a Worst-Case Scenario, but are still very unlikely events. The Risk Management Plan includes information on mitigation and prevention measures implemented by Atofina Chemical to reduce the risk of these types of events.
ative Release Scenarios: Mitigation Measures
While the Alternative Release Scenarios are, by definition, more likely than the Worst-Case
Scenario, they are still very unlikely given the facility's prevention program. If a release should
occur, Atofina Chemical has an array of mitigation measures to reduce any potential impacts. Examples of mitigation measures that would lessen the impacts of the Alternative Release Scenarios are listed below.
Installed chemical specific leak detectors in certain areas of the facility, including certain
railroad tank car unloading stations to provide early warning of a potential release;
Installed flammable gas leak detectors in many additional areas of the facility to provide
early warning of a potential release;
Certain loading operations and vessels are equipped with high level alarms to alert personnel
and to prevent/lesson overfills;
Loading and unloading operations are under continuous observation by oper
ators to detect
any problems and to quickly respond;
Railroad tank cars and other systems are equipped with excess flow shut-off valves which
will activate in the event of a pipeline or unloading hose rupture;
Storage tanks are diked to contain a potential release and allow the release to be covered with
water or neutralizing materials to reduce the release of vapors;
Many areas of the facility are equipped with sprinkler systems for fire protection. Sprinkler
systems can also be activated to reduce the release of vapors and to protect against a potential
Alternative Release Scenarios: Mitigation Measures (Continued)
There are fire alarm stations and fire extinguishers located throughout the facility. Fire alarm
tests are done twice per week. Employees are routinely trained in the use of fire
There is an on-site facility Emergency Response Team on duty 24 hours per day, 365 days
per year. The team receives over 40 hours of training per year including response to and
mitigation of releases and fires. The team also performs frequent emergency response drills
to ensure a rapid, well coordinated and effective response.
General Accidental Release Prevention Program
Atofina Chemical has a prevention program in place to minimize the risk of hazardous chemical releases in accordance with the Occupational Health and Safety Administration (OSHA) Process Safety Management (PSM) standard (29 CFR 1910. 119) and the EPA Risk Management Program. This prevention program covers those processes that handle covered chemicals above the threshold quantity of either the PSM or RMP rules.
The prevention program provides a structured approach to preventing accidents. Some of the
specific activities in the prevention program include:
In-depth process hazard analyses are completed every five years by qualified personnel using
techniques approved under the OS
HA PSM standards;
Written operating procedures (kept up-to-date) are used for training and directing the work
of operators, who receive refresher training every three years;
Operators, mechanics, and contractor personnel are qualified, trained in the general hazards
in the facility, and informed of any temporary situations affecting safety;
A safety work permit system assures that work is done safely and properly;
A management system is in place to ensure that changes are managed safely;
Critical equipment, including instruments, is inspected on a planned, periodic basis to assure
proper operating condition;
Pre-startup reviews are done to insure that conditions for safe operation have been satisfied
prior to starting new or modified equipment;
Incidents, including near-misses, are investigated and actions are taken as part of a
continuous improvement effort;
General Accidental Release Prevention Program (Continued)
Routine audits are conducted to assure that safe practices are being followed; and,
Weekly managers' walkabouts are conducted; routine safety meetings are held where
managers and hourly participate.
This systematic approach to process safety involves employees and strives for continuing
improvements in accident reduction. The training, qualifications, and safety awareness of our
operations, maintenance, and emergency response personnel are a key element in reducing and
Chemical-Specific Prevention Steps: Worst-Case Scenarios
Measures that would prevent the worst-case scenarios, a chlorine railroad tank car failure and a
propane storage tank failure, include:
These tanks are pressure vessels which are designed and constructed in accordance with
industry pressure vessel standards using industry-standard materials of construction;
As part of the Mechanical Integrity program, and per DOT requirements (chlorine railroad
k cars) pressure vessels are periodically inspected and tested;
Over-pressure is prevented by a system of pressure relief valves;
Tanks are located in areas with no overhead construction or equipment that could fall and
impact a tank;
Access to the facility is restricted through security barriers and trained security personnel,
thereby minimizing the risk to the tanks of vehicular damage or sabotage;
Fire hazards are controlled through procedures, training, and the hot work permit system
Tanks are frequently visually inspected to ensure they are in good condition.
Chemical-Specific Prevention Steps: Alternative Release Scenarios
The alternative scenarios selected for anhydrous ammonia, chlorine, dimethylamine, furan, methyl mercaptan, and propylene oxide were a railroad tank car or tank truck unloading line (or flexible hose) connection leaks. Prevention measures for these scenarios include:
Rail car and tan
k truck stops (or wheel chocks) to prevent movement of a rail car or tank
Signage that indicates rail car unloading;
Careful control of the switching of rail cars, including proper training and procedures that
prohibit hooking up to a car that is still connected;
Replacing flexible hose connections on a frequent basis to ensure hoses are always in good
Frequent inspection of unloading lines to ensure the lines are in good condition; and
Control of fire hazards through procedures, training, and the hot work permit system
The alternative release scenario for ethylene oxide is an overfilled process tank during a transfer
from another tank. Prevention steps for this scenario include:
Standard operating procedures on tank transfers and periodic reviews (training) of
Visible tank level indicator;
High level indicator and alarm system;
Periodic inspections of the l
evel indicator and alarm system; and
Radio communication between the control room operator and tank farm operator to minimize
the likelihood of tank overfilling.
Five-Year Accident History
There have been no accidents/releases of regulated substances from Atofina Chemical covered processes in the last five years that meet EPA criteria for the Five-Year Accident History. These EPA criteria are focused on serious accidents with either on-site deaths, injuries, or significant damage; or known off-site deaths, injuries, property damage, or environmental damage. Atofina Chemical realizes that the community may also be interested in smaller releases of regulated chemicals that do not meet EPA criteria for the Five-Year Accident History. We have been diligent in reporting releases of hazardous materials and in internally investigating and correcting the causes of such releases.
Emergency Response Plan
A written emergency response plan is maintained at the Atofina Chemi
cal facility. The plan was
developed in cooperation and was coordinated with the community emergency response plan
developed under 42 U.S.C. 11003. The Wayne County Local Emergency Planning Committee, local fire departments, and other emergency responders have copies of these plans.
The emergency response plan includes procedures for notifying civil authorities and the public in
the event of an incident. The plan also includes documentation of proper first-aid and medical
treatment necessary to treat accidental human exposures; procedures for the use of emergency
response equipment and for its inspection and testing; a description of the training program for
employees in relevant emergency response procedures; and procedures for review and update of the emergency response plan to reflect changes at the facility, and to ensure that employees are informed of these changes.
Atofina Chemical also has an on-site Emergency Response Team which performs regular emergency
ls and critiques of the drills. Some drills are done with the local fire and police
departments and critiqued by members of the community. Atofina Chemical on-site emergency
equipment includes a fully equipped fire truck with fire fighting foam capability and a 2,000 gallon vacuum truck for quickly collecting spills. There are first-aid trained personnel on each shift and a Plant Nurse on-site on the day shift. The Atofina Chemical Emergency Response Team receives over 40 hours of annual emergency response training.
Planned Changes to Improve Safety
The Atofina Chemical risk management program has been extended to cover chemical transportation and storage within certain areas of the facility where a vessel is not specifically connected to a process. For example, rail transportation and storage is now covered under the program at any time that a rail car containing a covered material is not being transported under active DOT shipping papers. This extends requirements of the p
revention program throughout additional areas of the plant.
Clean Air Act Amendments Title V Permit Status
The Atofina Chemical Riverview Plant has applied for a Title V Air Permit. The permit has not yet been issued. Therefore, Section 1.,element 12.C. of the Risk Management Plan (CAA Title V) has been checked, but no air permit ID number has been entered.