Akzo Nobel Functional Chemicals LLC - Executive Summary |
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EXECUTIVE SUMMARY Accidental Release Prevention and Emergency Response Policies Akzo Nobel Functional Chemicals LLC in Gallipolis Ferry, WV is committed to the operation of a safe and productive facility. We will comply with all local, state, and federal rules that regulate our business. From the highest levels of management down throughout our organization, we make a strong commitment to our employees, neighbors and surrounding communities to protect the health and safety of our employees and the public, and to operate our plant in an environmentally sound manner. Regulated Substances at the Akzo Nobel Functional Chemicals LLC Facility The Akzo Nobel Functional Chemicals LLC facility in Gallipolis Ferry, WV produces phosphorus based hydraulic fluids, plasticizers, and flame-retardants. The facility uses various RMP listed substances to produce intermediate chemicals that play a vital safety role for consumer products used daily such as plastic components, automotive and furni shing foams, insulation, and circuit boards. Their key role in the flame-retardant industry is estimated to save 10,000 lives per year and one trillion dollars in property damage annually. In order to produce these life and property saving products, chemicals covered by the Environmental Protection Agency's Risk Management Program are used. These chemicals include phosphorus oxychloride, phosphorus trichloride, epichlorohydrin, propylene, isobutylene, titanium tetrachloride, propylene oxide, ethylene oxide, and chlorine. Since the original RMP submission, bromine has been removed from the facility leaving 9 RMP chemicals. Worst-Case and Alternate Release Scenarios One of the requirements of the Risk Management Program is an Offsite Consequence Analysis. An Offsite Consequence Analysis evaluates potential releases of hazardous chemicals and determines the potential effects to the public and the environment. One part of the Offsite Consequence Analysis is the Worst Case Scenario, which is the worst possible, but highly unlikely, accident that can be imagined at the plant. A second piece to the Offsite Consequence Analysis is the Alternate Release Scenario, for which more likely releases are imagined. For the Worst Case Scenario, Akzo Nobel modeled the rupture of the largest storage vessel and released its contents over a ten-minute period. This was performed for each of the chemicals listed above using a software package provided by the Environmental Protection Agency called RMPCOMP. Under the worst case release conditions, each of our chemicals has potential off-site consequences; however, the degree of consequences varies from one chemical to the next with the range varying from 0.4 miles to 14 miles. The longest distance for the toxic category of 14 miles resulted from the rupture of the chlorine storage tank. The longest distance for the flammable category of 0.40 miles resulted from the rupture of the propylene storage vessel. For the Alternate (o r more likely) Release Scenarios, a release case was chosen from among those listed by the EPA in their writings. These scenarios are listed below: ? Epichlorohydrin - A release scenario in which the transfer hose leaks was performed. The release of epichlorohydrin could involve 221 pounds of chemical and could travel up to 0.20 miles before reaching its endpoint. ? Chlorine - A release scenario in which the transfer hose fails was performed. The release of chorine could involve 6,500 pounds of chemical and could travel up to 6.00 miles before reaching its endpoint. ? Phosphorus Oxychloride - A release scenario in which the transfer line leaks was performed. The release of Phosphorus Oxychloride could involve 65 pounds of chemical and could travel up to 0.60 miles before reaching its endpoint. ? Titanium Tetrachloride - A release scenario in which the transfer line ruptures was performed. The release of Titanium Tetrachloride could involve 202,000 pounds of chemical and could travel up to 2.20 miles before reaching its endpoint. ? Phosphorus Trichloride - A release scenario in which the transfer line leaks was performed. The release of Phosphorus Trichloride could involve 150 pounds of chemical and could travel up to 0.40 miles before reaching its endpoint. ? Propylene Oxide - A release scenario in which the transfer line leaks was performed. The release of Propylene Oxide could involve 4,880 pounds of chemical and could travel up to 0.30 miles before reaching its endpoint. ? Ethylene Oxide - A release scenario in which the transfer pipe leaks was performed. The release of Ethylene Oxide could involve 15,000 pounds of chemical and could travel up to 1.30 miles before reaching its endpoint. ? 2-Methylpropene (Isobutylene) - A release scenario in which the transfer line ruptures was performed. The release of 2-Methylpropene (Isobutylene) could involve 145,000 pounds of chemical and could impact an area up to 0.20 miles before reaching its endpoint. ? Propylene - A release scenario in which the transfer line ruptures was performed. The release of propylene could involve 86,000 pounds of chemical and could impact an area up to 0.20 miles before reaching its endpoint. Mitigation systems and administrative activities are in place to reduce both the potential of the releases and the effects of any release. General and Specific Accidental Release Prevention Program Akzo Nobel Functional Chemicals LLC in Gallipolis Ferry complies with all applicable regulations, including OSHA's Process Safety Management Standard. This 1992 regulation has the purpose of improving workplace safety when using certain highly hazardous chemicals. Akzo Nobel continuously strives to improve the safety of our facility and reduce the potential for incidents involving any chemicals or products through many avenues. Some of the many steps taken to minimize the risks include: ? Design of processes and process modifications using state-of-the-art design tech niques and adherence to applicable codes and industry standards, such as those of the American National Standards Institute (ANSI), National Fire Protection Association (NFPA), American Society of Mechanical Engineers (ASME), Center for Chemical Process Safety (CCPS) of the American Society of Chemical Engineers (AIChE) and the American Petroleum Institute (API) ? Standard Operating Procedures for job tasks in the facility; ? extensive training programs for all employees ( greater than 11,000 hours annually); ? management review before any process changes are made; ? hazard analysis involving operators, mechanics, engineers, safety, and environmental personnel before processes are started to eliminate risk potential; ? a mechanical integrity program to maintain the equipment in proper condition; and, ? reporting and investigation of all incidents in order to identify and correct root causes so that these incidents are not repeated. Akzo Nobel Functional Chemicals LLC also complies with the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, and various federal, state, and local rules. The Five-Year Accident History For the past five-year period, there have been four releases that could potentially have had an off-site impact. Akzo Nobel Functional Chemicals LLC had a release of 3,150 pounds of phosphorus oxychloride in 1998, with no off-site injuries or environmental damage. Akzo Nobel Functional Chemicals LLC had two releases of ethylene oxide during the past five-year period, both in 1999. The largest release was 60 pounds, and the second release was 43 pounds. Akzo Nobel Functional Chemicals LLC had a release of propylene oxide of 633 pounds in 1999. There was no environmental damage and no one off-site was injured during any of these releases; however, as a precautionary measure, shelter in place was called during one of the 1999 ethylene oxide events. The Emergency Response Program Akzo Nobel is very active in the area of emerge ncy response. Longstanding coordination and coordination of emergency response planning and prevention has been made with the Mason County (West Virginia) Local Emergency Response Committee and the Gallia County (Ohio) Local Emergency Response Committee. The facility has developed it's own emergency response team and assists the communities on other off-site releases when asked by local authorities. The facility response team participated in an LEPC sponsored drill on December 8, 2000. Employees are trained to various levels of response capabilities. During a recent offsite train derailment unrelated to Akzo Nobel Functional Chemical LLC's business, the emergency response team was asked to respond. The team was quick to respond and was able to isolate the area, identify the chemicals involved, and begin remediation efforts; the act was well regarded in both Mason County, WV and Gallia County, OH in that the safety of the residents was enhanced by such quick and correct actions. Planned Changes To Improve Safety Akzo Nobel Functional Chemical LLC in Gallipolis Ferry prescribes to the Chemical Manufacturer Association's Responsible Care program that requires continuous improvement in the area of health, safety and the environment. Akzo Nobel Functional Chemical LLC has also greatly reduced the amount of chlorine used at the facility. This reduction greatly shrinks the potential impact zone in the event of a release, and improves the safety for the facility and the surrounding communities. An evaluation of titanium tetrachloride is currently underway to see if other chemical alternatives exist in place of this RMP chemical. |