Dow Chemical, Allyn's Point Plant - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Dow Chemical, Allyn's Point Plant are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. However, if a release were to occur, our employees are trained in emergency response to control and mitigate the effects of the release. In addition, our emergency response plan is coordinated with Gales Ferry, CT Fire Department, which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompa ss Plastics Manufacturing.. We have 3 regulated substances present at our facility. These substances include 1,3-Butadiene, Acrylonitrile [2-Propenenitrile] and Ethyl chloride [Ethane, chloro-]. The regulated substances at our facility are involved in several uses. 1,3-Butadiene is used for manufacturing liquid latex emulsion polymer. Acrylonitrile [2-Propenenitrile] is used for for manufacturing ABS plastic pellets. Ethyl chloride [Ethane, chloro-] is used for manufacturing of polystyrene foam housing insulation. The maximum inventory of 1,3-Butadiene at our facility is 1050000.00 lb. while Acrylonitrile [2-Propenenitrile] and Ethyl chloride [Ethane, chloro-] are present at our facility in quantities of 641000.00 lb. and 220000.00 lb. respectively. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To e valuate the worst case scenarios, we have used the EPA's OCA Guidance Reference Tables or Equations and Areal Locations of Hazardous Atmospheres [ALOHA(R)]. For alternative release scenario analyses we have employed Areal Locations of Hazardous Atmospheres [ALOHA(R)] and ALOHA. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Magnum. In this scenario 176,000 lb. of Acrylonitrile [2-Propenenitrile] is spilled. The toxic liquid spill is assumed to form a 1 cm deep pool from which evaporation takes place. The ALOHA model limits the duration of the release to 60 minutes. 86853 lb. of Acrylonitrile [2-Propenenitrile] is estimated to evaporate over 60 minutes. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 2.5 miles is obtained corresponding to a toxic endpoint of 0.076 mg/L. The alternative release scenario for Acrylonitrile [2-Propenenitrile] involves a release from Magnum. The scenario involves the spill of 465000 lb. of Acrylonitrile [2-Propenenitrile]. Passive mitigation controls such as a dike are taken into account to calculate the scenario, having the effect of limiting the surface area of the spill to 3036 square feet. The ALOHA model limits the duration of the release to 60 minutes. 4108 lb. of Acrylonitrile [2-Propenenitrile] is estimated to evaporate over 60 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.076 mg/L of Acrylonitrile [2-Propenenitrile] is 0.5 miles. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Latex. In this scenario 1050000 lb. of 1,3-Butadiene is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explos ion. Under worst case weather conditions, the calculated distance of 0.81 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Latex. The release is assumed to result in a Vapor Cloud Fire. The scenario involves the release of 221774 lb. of 1,3-Butadiene in 60 minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint is 0.1 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with generally accepted good design practices and engineering standards. The following sections briefly describe the elements of the release prevention program that is in place at our stationary sour ce. Process Safety Information Dow Chemical, Allyn's Point Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes, including material safety data sheets, equipment specifications, and reactive chemicals tests. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. Methodologies used to carry out these analyses are Checklist, HAZOP, Dow Chemical Exposure Index, and Reactive Chemicals/Process Hazard Analysis. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of at least every 5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 06/22/1998. Operating Procedures For the purposes of safel y conducting activities within our covered processes, Dow Chemical, Allyn's Point Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Dow Chemical, Allyn's Point Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed. Mechanical Integrity Dow Chemical, Allyn's Point Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks , piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified personnel carry out maintenance operations with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Dow Chemical, Allyn's Point Plant to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Dow Chemical, Allyn's Point Plant. The most recent review was performed on 05/04/19 99. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Dow Chemical, Allyn's Point Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 06/22/1998. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Dow Chemical, Allyn's Point Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years Employee Par ticipation Dow Chemical, Allyn's Point Plant truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance, construction, and other activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Dow Chemical, Allyn's Point Plant has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are informed of all the procedures for emergency response should an accidental release of a regulated substance occur. Contractors are also required to inform The Dow Chemical Company of any hazards the contractor may introduce at the site. 5. Five-year Accident History Dow Chemical, Allyn's Point Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, we have had only one accidental release as defined by the RMP rule of regulated substances during this period. There has been only one accidental release of a regulated substance from our facility within the last 5 years. This release took place on 04/05/1999 and involved 9200 lb. of Hydrogen chloride (anhydrous) [Hydrochloric acid] and 9600 lb. of Hydrogen fluoride/Hydrofluoric acid (conc. 50% or greater) [Hydrofluoric acid]. We do not store these hazardous substances on our site. The hazardous substances were combustion products from a fire that consumed extruded polystyrene foam insulation stored at our site. The fire was caused by a brush fire that spread fr om land bordering our site. No deaths or injuries occurred offsite as a result of this accident. There was no damage to property offsite. As a precaution, the community emergency response of shelter-in-place was initiated. Onsite, there were no deaths or injuries. There was some onsite property damage. 6. Emergency Response Plan Dow Chemical, Allyn's Point Plant carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Ledyard LEPC is the L ocal Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The addition of fire hydrants that are tied into the town's fire hydrant system and the addition of a town siren system are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 04/01/2000. |