DuPont Chambers Works - Executive Summary

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Accidental Release and Emergency Response Policies 
 
     At DuPont Chambers Works, we are committed to operating and maintaining all of our processes in a safe and responsible manner.  We follow the DuPont Corporate philosophy that the "goal is zero".  This means we constantly strive for zero process safety incidents, zero environmental incidents and zero injuries.  We have programs, procedures and management practices in place to support this goal of zero.  We constantly assess our progress against this goal of zero and take corrective actions to get back on track whenever necessary. 
 
     Our primary focus is on prevention of any accidental releases.  However, we have strong emergency response capabilities to back-up our prevention activities.  We use this combination of prevention programs and emergency response capability to help ensure the safety of our employees and the public as well as protection of the environment.  
 
     This document provides a brief overview of the compr 
ehensive risk management activities that we have designed and implemented, including: 
 
-   A description of our facility and use of substances regulated by New Jersey's Toxic Catastrophe Prevention Act (TCPA)  Risk Management Program regulation; 
-   A summary of results from our assessment of the potential off-site consequences from accidental chemical releases; 
-   An overview of our accidental release prevention programs; 
-   An overview of our emergency response program; 
-   A five-year history of accidental releases of chemicals regulated by the TCPA rule; 
-   An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment; 
 
 
Stationary Source and Regulated Substances 
 
     The DuPont Chambers Works facility first opened in the early 1900's as a dye manufacturing plant.  We now produce in excess of 500 different products using a variety of chemicals and processing 
operations.  Our products are used to make clothing and textiles, computer chips, personal care products, agricultural chemicals and paint.  We also make unique types of rubber, greases and oils to meet the special needs of other manufacturing industries.    
 
         In our processes, we use the following chemicals that TCPA has identified as having the potential to cause significant off-site consequences in the event of a substantial accidental release: 
 
Toxics 
Ammonia 
Carbon Disulfide 
Chlorine 
Dichlorodimethyl silane 
Ethylene Oxide 
Hexafluoroacetone (NJ only chemical) 
Hydrogen Chloride 
Hydrofluoric acid greater than 70 % strength (NJ only chemical) 
Nitric acid greater than 80% strength 
Oleum 
Phosgene 
Titanium Tetrachloride 
 
Flammables: 
Vinylidene Chloride 
Ethylene 
 
Key Off-site Consequence Analysis Scenarios 
 
     To help with understanding the potential impact on the community due to a release of chemicals from DuPont Chambers Works, we have provided information about the worst- 
case release scenarios and alternative release scenarios for our facility.    
 
     These scenarios were developed using the guidance and technical data supplied by the EPA.  Scenario information similar to that described below has been used on Chambers Works for many years as part of our process safety management program.  In the past we have modeled potential releases and analyzed the results to help us continuously improve our processes and reduce risk.  We continue to do these assessments as part of our internal process safety management systems. 
 
     The EPA defines the worst case scenario as a hypothetical release of the largest quantity of a regulated chemical.  The scenario assumes the entire quantity is released in ten minutes, even if it is impossible to do so. 
 
     Using the methods described by the EPA, the worst case release of a flammable chemical from Chambers Works would be the release of the entire contents of our vinylidene chloride storage tank in a 10-minute pe 
riod.  The scenario assumes the cloud would ignite, resulting in a vapor cloud explosion of the released material.  The pressure wave generated from the explosion would barely leave the site boundary.   This event would not be expected to expose the public to the amount of pressure of concern to the EPA or NJ, but an explosion like this would be heard and possibly felt off the Chambers Works site. 
 
     Also using the methods described by the EPA, the worst case toxic scenario is the release of the entire contents of a chlorine railcar in a 10-minute period.  Using EPA guidelines, a release like this could significantly impact the public off  the Chambers Works site.  Depending on the wind direction at the time of the release, New Jersey, Delaware, Maryland or Pennsylvania could be effected.   
 
     The worst case scenarios described above underscore the need for very rigorous process safety management systems.  It is important to note however, that none of the prevention and mitigat 
ion equipment, practices, and procedures that have been put in place by DuPont Chambers Works to prevent or respond to releases such as these are taken into account for these worst case scenarios.   
 
     In order to facilitate emergency response planning with the community, TCPA and the EPA has included the requirement for companies to report alternate case scenarios.  These alternate case scenarios provide a realistic picture of what could actually happen if the safety systems used by a facility were to fail. 
 
     TCPA requires that companies include one alternate release scenario for regulated flammables as a group and one for each regulated toxic chemical.  This is because the impact of a flammable scenario on the public is expected to be similar for all the different types of flammables.   The toxic chemicals can vary in their effects and so must be reviewed individually.  In the data elements section of this report you will find a detailed description of all these alternate re 
lease scenarios. 
 
     The alternate case for flammables on Chambers Works is the complete, catastrophic failure of an unloading flex hose while transferring vinylidene chloride to the storage tank.  In this scenario, 419 pounds of vinylidene chloride is released and ignited, resulting in a flash fire.  This scenario has an impact distance of about 300 feet and does not extend off-site.  Of course, we still have accident prevention activities in place to protect our employees from injury. 
 
     In addition to all we do to prevent releases, we maintain a highly trained and equipped emergency response department around the clock.  They are able to respond to any releases we might have and mitigate the impact.  To address a situation like the oleum storage tank, Chambers Works has an emergency response and fire truck equipped with chemical resistant foam.  This foam can be sprayed over the spill and smother the fume release. 
 
The next section contains more information about our release  
prevention activities.                                       
 
                                                                                                                                                                Accidental Release Prevention Program 
 
For many years, employees at DuPont Chambers Works have applied rigorous process safety management practices to all our processes, not just those covered by regulations.  These practices include: 
 
-    A thorough understanding of our process technology including the safe limits of the processes and the proper materials of constriction for equipment; 
-    Proper design and installation of equipment; 
-    Systematic process hazard review studies to identify and manage process hazards; 
-    Written operating and maintenance procedures; 
-    Extensive training for all individuals involved in operating or maintaining a chemical process; 
-    Mechanical integrity testing and preventive maintenance to detect potential equipment problem 
s early; 
-    Mechanical quality assurance programs to ensure the correct spare parts are installed every time maintenance work is done; 
-    Procedures to assess and manage the safety and environmental impact of changes to the process technology or equipment; 
-    Pre-startup safety reviews for equipment that is newly installed or modified; 
-    Compliance audits to ensure process safety management procedures are effective and implemented properly; 
-    Investigation of actual and potential incidents to identify and implement corrective actions; 
-    Participation of all employees in the process safety management system; 
-    Documented safe work practices, including hot work permits; and 
-    A contractor management system to ensure work done by contractors is done safely and meets DuPont quality standards. 
 
     In addition to the practices described above, we have designed our processes to include multiple layers of safeguards.  Examples of these include: 
-    Automatic valves for 
rail cars, which isolate the supply of materials form the rail car in event of a process upset; 
-    Computer display and control of process parameters; 
-    Process alarms to warn operators of process deviations; 
-    Interlocks to automatically shut down processes for certain process deviations; 
-    Low concentration chemical detectors that either provide alarms to operators or automatically isolate leaks if the chemical is detected; 
-    Relief valves to prevent over-pressuring of equipment; 
-    Emergency scrubbers to prevent emissions from emergency systems from reaching the environment; 
-    Excess flow valves that close automatically if the chemical flow rate indicates a potential line leak; 
-    Deluge systems built into the process to quickly suppress chemical fumes or fires; 
-    Check valves to prevent cross contamination of chemicals; 
-    Camera surveillance of process areas in central control rooms;  
-    Fire prevention activities like electrical grounding, inerting fl 
ammables with nonflammable gasses and hot work permitting; 
-    100% operator surveillance during transfer of hazardous materials from shipping containers; and 
-    Minimization of hazardous material storage inventories, including manufacturing some highly hazardous materials only when we can immediately consume them to make products. 
 
     All of these individual elements of our prevention program work together to prevent accidental chemical releases. 
 
                                                                                                                                                            Emergency Response Program 
 
     In addition to all we do to prevent potential accidental releases, DuPont Chambers Works is committed to maintaining strong emergency response capabilities to back-up our prevention activities. The site has an on-site emergency response and fire department, staffed 24 hours a day.  The emergency responders are thoroughly trained and properly equipp 
ed to respond to releases of any chemicals used on our site.  The site also maintains an emergency response brigade comprised of specially trained operators that can lend additional support if necessary.   
 
     Chambers Works conducts practice drills with the local community and their emergency response organizations.  These drills simulate potential accidental releases and test emergency response plans.  Chambers Works also supports a siren system in the local community that would provide early warning for a potential release.  This system is coordinated with the Salem County Office of Emergency Response. 
 
     In addition to these on-site activities, Chambers Works also maintains transportation emergency response capability, which allows the site to respond to chemical transportation incidents outside the Chambers Works site. 
 
 
            Five-year Accident History 
 
     There have been no off-site injuries, evacuations, sheltering in place, property damage or environmental damage due to the accidental release of regulated substances from the DuPont Chambers Works plant in the past 5 years. 
 
     However, Chambers Works did have one internal incident in the past 5 years that meets the criteria for reporting.  In October of 1996, two operators were injured by nitric acid when one of the operators removed the end cap on an acid drain line.  The drain line cracked at the base of the pump, spraying both operators with the acid.   
 
     As a result of this incident, equipment has been upgraded, operating and maintenance procedures have been revised, and additional training was provided. 
 
 
Planned Changes to Improve Safety 
 
As part of our process hazards review procedures, all of our processes are thoroughly studied on a periodic basis to identify risk reduction opportunities.   As a result of these studies, w 
e are currently implementing, or are in the planning stages to implement, the following risk reduction activities: 
 
-  Installation of more chemical specific monitors for early leak detection; 
-  Upgrading the materials of construction of some process equipment; 
-  Improving the control of the process by installing better instrumentation, more automatic process shutdown interlocks, and upgraded computer control systems; 
-  Improving preventive maintenance inspections and data analysis;  
-  Improving our training programs; and 
-  Conducting process safety audits to identify any deficiencies in our management systems.
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