Degussa-Huls Corporation - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Degussa-Huls has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. Degussa-Huls has a nine-point policy guiding the accidental release prevention program. These are: 1) Use applicable design safety codes and standards as the basis for design, construction, operation, and maintenance in our facilities. 2) Evaluate facilities, equipment and processes for safety and health concerns. 3) Use multiple safeguards to provide layers of protection in the design, construction and operation of facilities, in order to prevent a sin gle failure from escalating into a catastrophic event. 4) Document the safety and health evaluation. 5) Inspect and evaluate process equipment against the design specifications. 6) Maintain current and complete documentation of the process and equipment throughout the lifetime of the process. 7) Develop a Management of Change procedure to control minor changes to process technology, operation and maintenance that may affect the safety of the process. 8) Review all changes to process equipment, procedures and practices to ensure the continued safety of employees and facilities. 9) Develop inspection and maintenance programs that ensure the continued integrity of facilities. Degussa-Huls has a nine-point policy guiding the emergency response program. These are: 1) Determine what potential emergency situations could occur, i.e., employee injury, fire, explosion, flood, cold weather, loss of electrical power, gas/chemical release, etc. 2) Develop written procedures for potential emergen cies outlining personnel responsibilities, emergency information and equipment. 3) Assign personnel to the emergency positions or tasks specified in the written procedures. 4) Provide appropriate emergency response equipment and ensure that it is periodically inspected. 5) Train emergency personnel to respond to emergencies in accordance with the written procedures. 6) Periodically conduct simulated emergency drills. 7) Review emergency procedures with all employees at least annually. 8) Review emergency procedures whenever there are significant changes in personnel, operations, or plant layout; or at least annually and update as necessary. 9) Document emergency procedure reviews and updates, including the date of the review. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. DESCRIPTION OF THE STATIONARY SOURCE AND REGUL ATED SUBSTANCES Degussa-Huls Mobile Plant is located in the Theodore Industrial Park in Theodore, Alabama on a 753-acre site. This facility employs 786 personnel. Eight production areas produce 15 products in a continuous production schedule, operating 24 hours per day, 7 days a week. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: acrolein, ammonia, chlorine, epichlorohydrin, formaldehyde, hydrocyanic acid, methyl mercaptan, propylene, trichlorosilane, and trimethylamine. RELEASE SCENARIOS The worst-case scenario (WCS) associated with substances in Program 3 processes at the site is a catastrophic failure of one storage tank containing 400,000 pounds of chlorine over a 10-minute period forming a vapor cloud. Administrative procedures and equipment interlocks prevent the chlorine storage tank from containing over this amount. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this scenario. According to EPA's model RMP*Comp, the release would reach offsite endpoints such as public and environmental receptors. The WCS associated with a release of flammable substances in Program 3 processes at the site is a catastrophic failure of one storage tank containing 400,000 pounds of propylene over a 10-minute period forming a vapor cloud which subsequently explodes. Administrative procedures and equipment interlocks prevent the propylene storage tank from containing over this amount. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this scenario. According to EPA's model RMP*Comp, the 1 psi overpressure boundary from the explosion would reach offsite but would not reach any public or enviro nmental receptors. The alternative case scenario (ARS) for acrolein is ?" hole in a 2" transfer line at operating pressure and ambient temperature. The hole results from a partial gasket failure or line damage resulting in a release of 1,100 pounds of gas over a 15-minute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release has the potential to reach offsite endpoints including public and environmental receptors. The ARS for ammonia is ?" hole in a 2" transfer line at operating pressure and ambient temperature. The hole results from a partial gasket failure or line damage resulting in a release of 1,600 pounds of gas over a 15-minute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measur es were taken into account in evaluating this scenario. This release does not have the potential to reach offsite endpoints above the toxic endpoint defined by EPA. The ARS for chlorine is ?" hole in a 2" transfer line at operating pressure and ambient temperature. The hole results from a partial gasket failure or line damage resulting in a release of 2,200 pounds of gas over a 15-minute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release has the potential to reach offsite but the only public or environmental receptors that would be reached are the adjacent industrial plants. The ARS for epichlorohydrin is ?" hole in a 2" transfer line at operating pressure and ambient temperature. The hole results from a partial gasket failure or line damage resulting in a release of 30 pounds of liquid over a 15-mi nute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and transfer the spilled material into containment. Passive mitigation systems, dikes and sumps, were used and included in the analysis of ARS. This release does not have the potential to reach offsite endpoints above the toxic endpoint defined by EPA. The ARS for formaldehyde is ?" hole at the storage tank outlet valve at operating pressure and 75 ?C. The hole results from a partial gasket failure or line damage resulting in a release of 300 pounds of liquid over a 15-minute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and transfer the spilled material into containment. Passive mitigation systems, dikes, were used and included in the analysis of ARS. This release does not have the potential to reach offsite endpoints above the toxic endpoint defined by EPA. The ARS for hydrogen cyanide is ?" h ole in a 2" transfer line at operating pressure and 3 ?C. The hole results from a partial gasket failure or line damage resulting in a release of 1,500 pounds of gas over a 15-minute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release has the potential to reach offsite but would not reach any public or environmental receptors. The ARS for methylmercaptan is ?" hole in a 2" transfer line at operating pressure and ambient temperature. The hole results from a partial gasket failure or line damage resulting in a release of 1,400 pounds of gas over a 15-minute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release has the pot ential to reach offsite but would not reach any public or environmental receptors. The ARS for propylene is ?" hole in a 2" transfer line at operating pressure and ambient temperature. The hole results from a partial gasket failure or line damage resulting in a release of 1700 pounds of gas over a 15-minute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release does not have the potential to reach offsite endpoints. The ARS for trichlorosilane is ?" hole in a 2" transfer line at operating pressure and ambient temperature. The hole results from a partial gasket failure or line damage resulting in a release of 829 pounds of liquid over a 15-minute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigat ion measures were taken into account in evaluating this scenario. This release does not have the potential to reach offsite endpoints. The ARS for trimethylamine is ?" hole in a 2" transfer line at operating pressure and ambient temperature. The hole results from a partial gasket failure or line damage resulting in a release of 537 pounds of liquid over a 15-minute period. The 15-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release does not have the potential to reach offsite endpoints. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The prevention program used by the facility is consistent with the Occupational, Safety and Health Administration's Process Safety Management Standard. The standard includes management systems elements involving safety information, hazard evaluations, operating procedures, employee trai ning, contractor programs, mechanical integrity, pre-start up safety reviews, incident investigations, safe work practices and emergency response. There are a number of chemical specific prevention steps used at the facility including release detection equipment, release containment, and release control equipment. FIVE-YEAR ACCIDENT HISTORY Degussa-Huls has an excellent record of accident prevention over the past 5 years. We have no incidents in the last five years that meet the RMP reporting requirements. EMERGENCY RESPONSE PROGRAM INFORMATION Degussa-Huls maintains a written emergency response program. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first aid, medical treatment, evacuation plans, and notification of local emergency response. The overall emergency response program for Degussa-Huls is coordinated with the Mobile Fire Department and the Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. Degussa-Huls has around-the-clock communications capability with 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. In addition to periodic LEPC meetings, Degussa-Huls conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. PLANNED CHANGES TO IMPROVE SAFETY Degussa-Huls resolves all findings from process hazard analysis, some of which resu lt in modifications to the process. The following types of changes are planned: increase process controls & modify procedures |