DuPont - Fayetteville Works - Executive Summary
ACCIDENT RELEASE PREVENTION & EMERGENCY RESPONSE POLICIES |
At DuPont Fayetteville Works, we are committed to operating and maintaining our process in a safe and
responsible manner. We use a combination of accidental release prevention programs and emergency
response planning programs to help ensure the safety of our employees, the public and the environment.
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 our goal of zero. Our Site Safety, Operating and Emergency Response Procedures are available to all site employees through hard copies and via electronic copies on computers placed through out the plant.
The DuPont Fayetteville Works site consists of approximately 2200 acres, located on the Bladen and Cumberland County line along Highway 87, approximately 1
5 miles south of Fayetteville, North Carolina. About 200 acres are currently used for manufacturing with the remainder set aside for wildlife habitat and future manufacturing needs.
The Nafion process at the DuPont - Fayetteville Works site is a Program 3 Process. The Nafion process produces a membrane used in the Chloralkali industry. In the production of the Nafion product the following regulated substances are used as raw materials:
* Hydrogen Chloride (received in as TFE/HCl Distillate)
* Sulfur Trioxide
* Tetrafluorethylene (received in as TFE/HCl Distillate)
WORST-CASE TOXIC RELEASE SCENARIO
The worst-case release scenario for a toxic substance involves the failure of a 4" diameter, six foot long section of pipe in the TFE/HCl Distillate storage tank system which releases the total contents of the TFE/HCl Storage tank. No passive mitigation is taken into consideration for this scenario.. This release has an off-sit
e impact, as determined by the use of the EPA's RMP*Comp(TM). This type of release is unlikely due to the routine inspection of the storage tank and assoicated equipment. We are using the information from this scenario to help ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases.
WORST-CASE FLAMMABLE RELEASE SCENARIO
The worst-case release scenario for a flammable substance is the failure of the TFE/HCl Distillate storage tank with no mitigation assumed. This release if ignited, would have no off-site impact as determined by the use of the EPA's RMP*Comp(TM). A total relase of this storage tank is unlikely due to the routine inspection of the storagae tank and associated equipment. Since the Worst-Case Flammable Release Scenario does not impact off site public or the environment, no Alternative Flamable Release Scenarios were necessary.
ALTERNATIVE TOXIC RELEASE SCENARIOS
The Alternative toxic release scenario
for a toxic substance involves the rupture of the transfer hose while unloading the TFE/HCl Distillate trailer into the distillate storage tank. Total loss of the trailer is assumed to take place over a 60 minute period and no mitigation was assumed. This scenario would affect off site residences as determined by the use of EPA's RMP*Comp(TM) and the "Landview" program census data.
The second alternative toxic release scenario for a toxic substance involves a pipe leak in the recirculation line of the Sulfur Trioxide (SO3) storage tank with a response time of 30 minutes to secure the leaking line. The SO3 storage tank is located inside a heated building with a trench to direct any leaks to an outside sump that has an area of 400 sq. ft. This scenario would have an affect on off site residences as determined by the use of EPA's RMP*Comp(TM) and the "Landview" program census data.
ACCIDENTAL RELEASE PREVENTION PROGRAM
The DuPont Fayetteville Works site process follow the requirement
s of DuPont Corporate SHE Standard S21A, "Process Safety Management." This standard includes and embraces the requirements of 29 CFR 1910.119 and 40 CFR Part 68. Our safety programs include guidelines which include a documented process technology system covering the hazards of materials, equipment design basis, and process design basis. It includes the requiremnt to choose materials of construction to provide mechanical integirty and incorporates extensive safety instrumentation such as alarms, interlocks, and gas detectors. It also includes identifying all process safety critical equipment and performing routine inspections to ensure proper operation and mechanaical integrity. A work order and permit system is used to control maintenance work performed, and our maintenance personnel are trained, qualified, and experienced. The guidelines also include the requirement for operators and mechanics to follow approved procedures. Processes are continually monitored by computer control
systems and opertors. These individual elements of our prevention program work together to prevent accidental chemical releases.
FIVE YEAR ACCIDENT HISTORY
There have been no off-site injuries, evactuations, sheltering in place, property damage or environmental damage due to the accidental release of regulated substances from the DuPont Fayetteville Works site in the past 5 years.
EMERGENCY RESPONSE PROGRAM
Our program provides the essential planning and training for effectively protecting the workers, the public, and the environment during emergency situations. An emergency response plan is in place and updated regularly and all employees are trained for their role in the emergency response plan. The plant participates in emergency drills, and critiques are held after drills and actual events. We annually hold mutual aid drills with our surrounding emergency response teams and the plant is a active member of the Bladen and Cumberland County LEPCs.
PLANNED CHANGES TO IMPROVE SAFETY
As part of our process hazards review procedures, our processes are thoroughly studied on a periodic basis to identify risk reduction opportunities. As a result of this we are currently in the planning stages to implement the following risk reduction activities:
- Reduce the total inventory permitted on plant site of regulated substances.
- Replace Hydrogen Chloride, used as part of TFE/HCl Distillate, with a non-toxic substance.
- Continued focus on "The Goal is Zero" for injuries and incidents.
- Improving our training programs
- Conducting process safety audits to identify any deficiencies in our mangement systems.