ANGUS CHEMICAL CO.-STERLINGTON PLANT - Executive Summary |
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ANGUS CHEMICAL COMPANY STERLINGTON, LA RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 2694 LDEQ Facility ID Number ANGUS Chemical Company owns and operates an organic chemical manufacturing (NAICS 325199) plant in Sterlington, Louisiana. The plant is situated adjacent to the Ouachita River and Louisiana Highway 2 in northeast Ouachita Parish. The plant employs approximately 260 full time personnel. The facility operates continuously 24 hours per day, 365 days per year. Sterlington is a small community with a population around 3300, located approximately 10 miles north of Monroe, Louisiana. The ANGUS facility consists of six (6) separate manufacturing operations including a nitroparaffins plant, nitric acid plant, nitroparaffin derivatives plant, derivatives crystals plant, isopropyl hydroxylamine (IPHA) plant and a hydrogen plant. In addition ANGUS operates and maintains a shipping facility in support of the process plants for both the distribution of incoming raw materials and o utgoing manufactured products and a pilot plant to scale up the manufacture of new products and to enhance the production of existing commercial products. ANGUS' processes at Sterlington are covered by 29 CFR 1910.119, OSHA's Process Safety Management standard. Process hazard analysis of all covered processes have been completed and several process studies have been revalidated in conformance with specified hazard review requirements. REGULATED (68.130) SUBSTANCES HANDLED: ANGUS Chemical Company handles the following materials that are regulated by EPA's Risk Management Plan at the Sterlington facility: MATERIALS CLASSIFIED AS TOXIC: Sulfur Dioxide - 7446-09-5 A chemical used in our nitroparaffin process, maximum amount stored = 106,100 lbs. Formaldehyde - 50-00-0 Raw material for nitroparaffin derivative process, maximum amount stored = 250,000 lbs Chlorine - 7782-50-5 Water treatment additive, maximum amount stored = 5 tons Ammonia - 7664-41-7 Raw material for the n itric acid process, maximum amount on site = 2600 lbs FLAMMABLE MATERIAL: Propane - 74-98-6 Raw material for the nitroparaffin process, maximum amount on site = 657,296 lbs DETONABLE MATERIAL: In addition to the above regulated materials, ANGUS also produces and handles a detonable material, Nitromethane, We are reporting this material under the General Duty Requirements. This material and the process where it is produced are managed under our Process Safety Management Program. Nitromethane - 75-52-5 A product of the nitroparaffin process, maximum amount on site = 100,000 lbs. ANGUS CHEMICAL COMPAN Y'S ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE STRATEGIES: ACCIDENTAL CHEMICAL RELEASE PREVENTION STRATEGY: ANGUS Chemical Company's strategy for the prevention of accidental chemical releases encompasses the benefits available from current process control technologies, personnel training, and a responsible chemical plant operator. To this end we utilize continuous process controls such as high level, high pressure, and high flow alarms with interlocking logic, redundancy and uninterrupted power sources to monitor and control our critical processes. Personnel are thoroughly trained in operating procedures and are well versed in the consequences of process deviations and the specific steps necessary for implementation when a process imbalance is detected. As a responsible chemical process operator, it is incumbent to make the prevention of accidental chemical releases a high priority goal and an accountable concern. All of our processes are subjected to process safety analysis. These are completed on five (5) year cycles. All changes to processes are controlled through a comprehensive management of change process. We will maintain a goal to prevent accidental chemical releases from occurring, and we maintain a proactive attitude toward that end. EMERGENCY RESPONSE STRATEGY: ANGUS Chemical Company's Sterlington Plant recognizes that in addition to preplanning to reduce the frequency and magnitude of incidents, a well prepared and timely response to accidental chemical releases is necessary to effectively mitigate problems when they occur and to help minimize potential adverse affects to our facility, our personnel and the community. To this end, our strategy for managing emergencies is to incorporate emergency response actions into all of our process operating procedures, procure necessary personal protective and emergency response equipment, initiate Incident Command Systems and thoroughly educate and train all of our operating personnel i n appropriate actions to minimize the effects from an accidental chemical release. Our contingency capabilities are tested at least four times per year to help ensure the operational readiness of our personnel to respond to plant emergencies. WORST CASE SCENARIOS: TOXIC: Sulfur Dioxide. Failure of our storage tank containing maximum capacity would release 100,000 lbs of sulfur dioxide. It is assumed that the entire contents are released as a vapor over a ten (10) minute period. Assuming a wind speed of 1.5 meters/second with F stability and using specified levels of concern and estimating tables established by the Environmental Protection Agency (as contained within EPA's "Dense Gas Distances to Toxic Endpoints" - Urban tables from EPA's Offsite Consequence Guidance document), the level of concern of 0.0078 mg/L would have an endpoint greater than 25 miles from the point of release. To limit this distance ANGUS utilizes administrative controls to normally maintain the storag e vessel at 50% or less, conducts annual audits of the systems, maintains the storage and handling equipment in sound mechanical condition, and utilizes employee training and comprehensive operating procedures to ensure that the material transfers are conducted in a consistent manner. FLAMMABLE: Propane. Failure of our storage sphere could release up to 588,000 pounds of propane. It is assumed that the entire contents are released as vapor which finds an ignition source resulting in a vapor cloud explosion. Assuming an ambient temperature of 85 deg F, 50% humidity with wind at 3 meters/second from the south, stability class D and using data generated from a release modeling program AARCHIE?, the level of concern of 1 psi over pressure would have an endpoint distance of 0.66 miles. To limit this distance ANGUS Chemical Company utilizes administrative controls to normally limit the amount of propane stored in the sphere to less than 70% capacity, conducts annua l audits of the system, maintains the storage and handling equipment in sound mechanical condition and utilizes employee training and comprehensive operating procedures to ensure that the material transfers are conducted in a consistent manner. To detect release at an early stage, gas detection is utilized at the storage sphere. Gas detectors are set to sound an audible alarm and automatically trip a high density water deluge system to dilute potential escaping gas and/or to protect the sphere. DETONABLE: Nitromethane. Detonation of a storage tank containing nitromethane would involve up to 50,000 pounds of this material. It is assumed that the entire contents of the storage tank is detonated. Assuming an ambient temperature of 85 deg F, 50% humidity with a wind speed of 3 meters/second from the south, stability class D and using blast pressure wave/crater depth calculations, the level of concern would have an endpoint distance of 0.31 miles. To limit this distance, ANGUS Chemi cal Company employs strict control on all process vessel and equipment that are in nitromethane service. These include mandatory use of detonation traps on all lines, use of pressure relief devices on any portion of a NM line that could be valved off and entrap NM, utilization of fixed deluge and/or water spray system on all exposed NM piping, tanks are mounded, and continuous air separation between NM process equipment and NM storage. In addition, administrative controls have been implemented including annual audits of all NM systems, mechanical integrity on all process equipment, extensive personnel training on NM hazards and special handling requirements, comprehensive operating procedures, and controls to prevent and/or safely contain vessels that have the potential to accumulate detonable mixtures of NM. ALTERNATIVE CASE SCENARIOS: TOXIC: Sulfur Dioxide. Leak at sulfur dioxide weigh tank from a one sixteenth inch hole releases 5.1 pounds of materials per minute for 60 minut es. Using release modeling program AALOHA ? and assuming an ambient temperature of 85 deg F, 50% humidity with wind speed at 3 meters/second, and stability class D, the levels of concern for the IDLH (immediately dangerous to life and health) of 100 ppm would result in a distance of 0.041 miles and 0.28 miles to the toxic endpoint (1/10th of IDLH) of 0.0078 mg/l. To limit this distance, ANGUS utilizes administrative controls to normally maintain the storage vessel at 50% capacity or less, conducts annual audits of the systems, maintains the storage and handling equipment in sound mechanical condition, and utilizes employee training and comprehensive operating procedures to ensure that the material transfers are conducted in a consistent manner. Ammonia. Relief valve fails open releasing material at ground level at a rate of 199 pounds per minute for 10 minutes. Using release modeling program AALOHA?and assuming an ambient temperature of 85 deg F, 50% humidity with wind speed at 3 meters/second, stability class D would result in levels of concern for the IDLH (immediately dangerous to life and health) of 300 ppm at a distance of 0.17 miles and 0.20 miles to the toxic endpoint (1/10th of the IDLH) of 0.14 mg/l. To limit this distance, ANGUS utilizes mechanical integrity programs to ensure that the ammonia line is mechanically sound, conducts annual audits of the ammonia line and all associated equipment, and utilizes employee training and comprehensive operating procedures to ensure that the material transfers are conducted in a consistent manner. Chlorine. Failure of the liquid valve on a one ton cylinder releases 6.6 pounds of material for 10 minutes. Using release modeling program AALOHA? and assuming an ambient temperature of 85 deg F, 50% humidity with a wind speed of 3 meters/second, stability class D would result in levels of concern for the IDLH (immediately dangerous to life and health) of 10 ppm at a distance of 0.165 miles and 0.31 miles to the toxic endpoint (1/10th of the IDLH)of 0.0078 mg/l. To limit this distance, ANGUS utilizes comprehensive training of personnel on the hazards of chlorine and proper procedures necessary to connect and disconnect chlorine gas cylinders. Chlorine repair kits are maintained on site and personnel are trained in the effective application techniques to properly use these kits. Formaldehyde. Leak develops at formaldehyde filters releasing product at the rate of 24 pounds per minute for 10 minutes. Basing calculations on formaldehyde fraction of product and using release modeling program AALOHA? and assuming ambient temperature of 85 deg F, 50% humidity with a wind speed of 3 meters/second, stability class D would result in levels of concern for the IDLH (immediately dangerous to life and health) of 20 ppm at a distance of 0.19 miles and 0.27 miles to the toxic endpoint (1/10th of the IDLH) of 0.012 mg/l. To limit this distance, ANGUS has trained operating personnel in the hazards of fo rmaldehyde and utilizes mechanical integrity to ensure that the formaldehyde handling equipment is maintained in sound condition. Standard operating procedures are utilized to ensure that material transfers are conducted in a consistent manner appropriate for formaldehyde. FLAMMABLE: Propane. Material leaks from the nitration section at a rate of 200 pounds per minute for 10 minutes. Using release modeling program AARCHIE? and assuming ambient temperature of 85 deg F, 50% humidity with a wind speed of 3 meters/second, stability class D would result in levels of concern for the IDLH (immediately dangerous to life and health) of 2100 ppm at a distance of 0.041 miles and and an end point of 5 kw/sq meter for 40 seconds (the thermal dose equivalent to receive a second degree burn) at a distance of 0.03 miles or an area of concern no greater than the immediate area of ANGUS' Sterlington facility. To limit this distance, ANGUS Chemical Company utilizes administrative controls to norma lly limit the amount of propane stored in the propane vaporizer upstream of the nitration section to less than 30% of its capacity, conducts annual audits of the system, maintains the storage and handling equipment in sound mechanical condition and utilizes employee training and comprehensive operating procedures to ensure that the equipment is properly operated and maintained in a consistent manner. To detect release at an early stage, gas detection is utilized at the propanevaporizer. Gas detectors are set to sound an audible alarm and the propane vaporizer is protected by a deluge system. DETONABLE: Nitromethane. Material detonates within a switch tank involving 1000 pounds of material. Using modeling program AARCHIE? and assuming ambient temperature of 85 deg F, 50% humidity with a wind speed of 3 meters/second, stability class D would result in a level of concern of 1 psi over pressure within a radius of 0.10 miles from the switch tank. To limit this distance, ANGUS Chemical Company employs strict control on all process vessels and equipment that are in nitromethane service. These include mandatory use of blast containment bunkers, detonation traps on all lines, use of pressure relief devices on any portion of a NM line that could be valved off and entrap NM, utilization of fixed deluge and/or water spray system on all exposed NM piping, and continuous air separation between NM process equipment and NM storage. In addition, administrative controls have been implemented including annual audits of all NM systems, mechanical integrity on all process equipment, extensive personnel training on NM hazards and special handling requirements, comprehensive operating procedures, and controls to prevent and/or safely contain vessels that have a potential to accumulate detonable mixtures of NM. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS: STAFFING: ANGUS maintains qualified personnel in its engineering, maintenance, pro duction operations and operations support areas to ensure that the plant operates in a safe and productive manner. Staffing is based on production and regulatory needs and personnel are selected on their technological knowledge, experience and abilities to operate and support operations within the facility. A strong cadre of chemical engineers are employed in engineering, production operations and administrative support; mechanical engineers and industrial technologist are involved in plant maintenance programs including mechanical integrity; professional safety personnel are employed to provide oversight and direction on safety issues related to personnel, property protection and process safety management including the maintenance of a full time Process Hazard Analysis function. TRAINING: ANGUS utilizes an extensive training program to educate all plant operators. Our plant operator training program is a key element to the safety of our operation. Each production plant is assig ned a training coordinator to provide continuous training to both new and experienced operators. Training requirements are identified by each department. The Regulatory Affairs and Transportation departments, with assistance from the Training Department, ensure that regulatory training requirements are identified, defined and maintained. Function specific training requirements are identified by each department. The manager, supervisors, and employees of each department determine the function specific training needed for each of the jobs within their departments. The Training Department and department training coordinator compile these training requirements for each job a job curriculum. Each job curriculum identifies all of the training requirements for each job and is maintained by the Training Department. These requirements are reviewed annually with needed changes made to ensure that they remain accurate and up to date. FIRE PREVENTION PROGRAM ANGUS Chemical Company maint ains stringent controls to prevent fires in the Sterlington facility. A number of controls and procedures are in place to prevent the ignition of flammable and combustibles. These controls are carried out through various practices and all employees and contractors are expected to comply and adhere to the requirements. These controls include restrictions on the use of ignitors, prohibited vehicle use within the plant, mandatory hot work permits for all heat and spark producing operations, detection systems, and stringent compliance with electrical classification requirements. PROCESS SAFETY MANAGEMENT SYSTEM: To effectively implement and maintain a safe manufacturing plant, ANGUS has developed and maintains a comprehensive process safety management system. Each element of OSHA's PSM standard and EPA RMP program has been assigned to a responsible individual to monitor and to steward to ensure that the intent of the element is met and maintained. Our Process Safety Management progr am includes functioning procedures and activities addressing the following process safety elements: Process safety information Process hazard analysis Operating procedures Training Mechanical Integrity Management of change Pre-startup safety review Compliance audits Incident Investigation Employee Participation Hot work permit Contractors In our release prevention efforts, we have implemented the following chemical specific prevention steps: SULFUR DIOXIDE Limited quantities kept on hand (reduced utilization of available capacity) Hazardous material audits Mechanical integrity on storage and handling systems Management of Change Standard Operating Procedures Employee Training Process Hazard Analysis PROPANE Limited amount on hand (reduced utilization of storage capacity) Specific designed vaporizer Deluge spray protection Mechanical integrity on handling systems Hazardous material audits Management of Change Standard Operating Procedures Employee Training Process Hazard Analysis NITROMETHANE Limited amount on hand (reduced storage capacity) Detonation traps Prohibition from heavy confinement through comprehensive use of pressure relief devices. Water spray protection Mandatory NM safety education Mechanical integrity on handling systems Hazardous material audits Management of Change Standard Operating Procedures Employee Training Process Hazard Analysis AMMONIA Limited amount on hand (no storage maintained on site) Gas monitoring Mechanical integrity on handling system Hazardous material audits Management of Change Standard Operating Procedures Employee Training Process Hazard Analysis FORMALDEHYDE Limited materials on hand ( reduced storage capacity) Process controls Mechanical integrity on handling systems Management of Change Standard Operating Procedures Employee Training Process Hazard Analysis CHLORINE Limi ted amount on site (reduced volume on site) Mechanical integrity Management of Change Standard Operating Procedures Employee Training Process Hazard Analysis FIVE YEAR ACCIDENT HISTORY: PERIOD OF TIME: June 21, 1994 through present ACCIDENTS OF CONCERN: Accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage (40 CFR 68.42 - Five-year accident history). ACCIDENT HISTORY: The following accidental releases occurred from ANGUS Chemical Company's Sterlington Plant covered processes during the above period of time and which meet certain reporting criteria: 1/28/97 Acid line ruptured to nitrator at NP Basic Plant releasing nitric acid and propane gas. Four minor injuries, one OHSA recordable injury due to including a twisted ankle and three first aid cases from minor skin irritation, resulted to plant person nel from this release, outside agencies notified, no offsite response was required. No offsite consequences occurred. Cause of incident: loss of acid feed to nitrator permitted hot propane to condense to liquid and enter acid line where it reacted with acid outside of nitrator. Corrective action: System reconfigured to provide slope of acid feed into nitrator to preclude condensed propane from entering acid line. Acid line equipped with self regulating heat tracing to maintain line temperature within an appropriate range to preclude propane from condensing, EMERGENCY RESPONSE PLAN: ANGUS Chemical Company maintains an Emergency Response Plan for plant emergencies. The plan addresses emergencies in general and provides information for response to specific hazardous materials maintained on site. Our plan involves the notification of personnel for emergencies which include fires, explosions, and chemical releases. The plan contains contingencies for sheltering-in-place, evac uation, personnel accounting and specific guides for addressing emergencies involving hazardous materials handled on site. In addition to our overall plant emergency response plan, each operation maintains specific actions to take in the event of emergencies within their process operations. These actions include the safe shut down of process equipment as well as mitigation steps to control operations. All plant personnel are trained on our emergency response plan and what actions they are to take in the event of an emergency. Plant operators are trained on specific operating response actions. These actions are addressed in plant operating procedures. All plant personnel are trained to recognize hazardous material incidents, Maintenance and operations personnel are trained to respond to chemical releases and incipient stage fires. Our emergency response plan is tested at least four times per year. We involve outside response agencies in at least one drill per year. We emph asis Incident Command and internal/external communication during our contingency drills. Personnel response to chemical releases are tested along with the incident command system during these drills. To improve communication between our facility and the Ouachita Parish Fire Department, plant radios have been provided to the fire department. This enables direct communication between our incident commander and the responding fire department and will inform the responding unit of the nature of the emergency situation and which route to enter the facility. Our Emergency Response Plan is coordinated with outside agencies. These include the Ouachita Parish Fire Department, Ouachita Civil Defense Agency, Ouachita Parish Sheriffs Department, Louisiana State Police and Sterlington Police. We have developed medical protocols for the emergency treatment of individuals adversely exposed to our products and raw materials. These protocols have been approved by our medical consultant. Area ho spitals have been briefed on our emergency plan and medical protocols and have agreed to receive individuals from our facility in the event of an emergency. In the event of an emergency all plant personnel are notified of an emergency through our alert system. This system also notifies selected areas of the Sterlington community that a condition exists within the plant. These notification locations are the Sterlington Town Hall, Sterlington Hospital, Sterlington High School and A.L. Smith Elementary School. The alert system monitors are tested each week along with our routine plant alarm system test. In addition, when an actual emergency occurs, telephone contact is made with the alert center locations as well as businesses and apartment complexes in close proximity of our facility. To assure direct communication between our plant and the two schools, direct plant telephone lines are maintained between ANGUS and The Sterlington High School and A.L. Smith Elementary School. PLANNED CHANGES TO IMPROVE SAFETY: ANGUS has implemented a comprehensive Process Safety Management system to ensure that our process operations are maintained and operated in a safe manner. Implementation of process safety management provides inherent safeguards to ensure that our processes are operated within limits that are suitable for the materials that we process. ANGUS continually ensures the safety of its operations through the use of PSM activities involving Process Hazard Analysis of all production, utilities, and shipping operations; strict conformance with Management of Change procedures; use of Standard Operating Procedures; comprehensive training of plant personnel, with special emphasis on initial and refresher process operator training; Mechanical Integrity programs utilizing predictive and preventive maintenance to ensure operating equipment is properly functioning and maintained to effectively handle intended materials; a comprehensive contractor safety program for all contractor personnel working within ANGUS' chemical processes; an active Employee Participation program that involves process operators in PSM activities to gain their insight into our process operations. Incidents, including near misses are investigated to determine the cause, and corrective action is implemented to prevent reoccurrences to assist in the safety of our operations ANGUS Chemical Company is committed to maintaining our operations in a safe manner and provides the necessary resources in personnel and capital to ensure that our processes are well designed, engineered, constructed, maintained and operated. CERTIFICATION: To the best of my knowledge, information and belief formed after reasonable inquiry, the information submitted in this Risk Management Plan is true, accurate and complete. N. Courtney Salway G lobal Operations Leader July 7, 2000 |