Dow Chemical Company Torrance California Site - Executive Summary

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Dow Chemical Torrance, CA Site 
General Executive Summary 
January, 2001 
 
 
Section 1.  Accidental Release Prevention and Emergency Response Policies 
 
The Dow Chemical Company ("Dow") has a long-standing commitment to worker and public  
safety.  This commitment is demonstrated by the resources invested in accident prevention,  
such as training personnel and considering safety in the design, installation, operation, and  
maintenance of our processes.  Our policy is to implement reasonable controls to prevent  
foreseeable releases of regulated substances.  However, if a release does occur, our trained  
personnel will respond to isolate and deny entry and control the release to the extent possible.    
Dow personnel will also notify the Torrance Fire Department who will assume command of the  
incident, if necessary, until the release is stopped. 
 
 
Section 2.  Description of the Stationary Source and Regulated Substances 
 
The Dow facility, located in Torrance, CA, primary activities are the ma 
nufacturing of  
polystyrene plastic and polystyrene foam products.  Acrylonitrile is the only regulated  
substance present at our facility, and is used to manufacture ABS (Acrylonitrile-Butadiene  
Rubber-Styrene Polymer) plastic.  ABS resins have unique chemical resistance, toughness,  
and high temperature properties that make them especially suitable for a number of end uses 
including automotive parts; drain, waste, and vent pipes; small appliances; electronic equipment 
housings; housewares; toys; and many more. 
 
The Torrance Plant is one of many locations in North America and Europe in which Dow produces 
ABS plastic resin.  Dow has been producing ABS resins since the early 1960s and remains today 
one of the largest producers worldwide. 
 
Production of ABS in Torrance started in 1972 to meet West Coast demand as well as export  
pportunities.  ABS continues to be a vital component of the portfolio of products offered by Dow to 
its global customers 
 
 
Section 3.  Worst Case Scenario  
 
             Alternative Release Scenario with Administrative Controls and Mitigation Measures   
 
The EPA's RMP regulation covers the acrylonitrile storage tank and tank car unloading process 
and the ABS production process equipment.  This regulation requires Dow to analyze these 
processes to determine the worst case release scenario and an alternative, or more likely, 
release scenario.  The worst case release scenario submitted for these processes involves a  
catastrophic release of 274,000 lb. of acrylonitrile from an acrylonitrile storage tank.  The tank's 
containment dike was considered as a passive mitigation system when evaluating this scenario.   
Passive mitigation systems are those devices, equipment, or technologies that function without  
human, mechanical, or other energy source.  It is assumed that the entire quantity is released  
instantaneously, to form a liquid pool.  The amount of acrylonitrile that vaporizes in this worst case  
scenario forms a mixture in air, which a  
person can be exposed to for an hour, without experiencing  
serious health effects.  This mixture would be experienced beyond the Dow Chemical facility fence 
line 
 
The alternative release scenario involves the acrylonitrile storage tanks, just as in the worst case  
scenario.  In the alternative release scenario, it is assumed that a 2 inch opening develops on one  
of the storage tanks, resulting from the failure of a 2" piping connection to the tank, or a partial  
failure of the tank itself.  The liquid acrylonitrile would be released at rate of 1262 pounds per 
minute into the tank dike forming a contained liquid pool.  It is assumed that the release would last 
for 10 minutes, for a total liquid release amount of 12,620 lbs.  This is a reasonable time frame for 
operations personnel to become aware of the problem and take appropriate actions to stop the  
release.  It is assumed that the release would be detected by the flammable gas detector located 
in the dike, which would sound in an  
alarm audible both inside and outside the control room.  The  
storage tank spill containment was considered as a passive mitigation system when evaluating 
this scenario.  The active mitigation measure for the acrylonitrile storage tank system is the deluge 
fire protection system with fire fighting foam capability.  Fire fighting foam, applied to the surface of 
a liquid pool, reduces the liquid evaporation rate.  Active mitigation systems are the converse of 
passive mitigation systems, in that they require human, mechanical, or other energy sources to 
function. The release is also controlled by monitoring and detection systems including: 
1) flammable gas detectors, and 2) sensors measuring pressure, temperature, and level.  Based 
on the alternative release scenario, the concentration of acrylonitrile in air would be experienced 
beyond the Dow Chemical facility fence line, which a person can be exposed to for an hour, 
without experiencing serious health effects. 
 
The EPA RMP*Comp(TM) met 
hodology, developed by the Environmental Protection Agency  
(EPA), was used to model both the worst case and alternative release scenarios. 
 
 
Section 4.  General Accidental Release Prevention Program 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.  All facilities at the Dow Torrance, CA  
site were designed and constructed in accordance with the Uniform Building Code, Uniform Fire  
Code, and all other applicable codes and standards in place at the time of construction.  A  
number of processes at our facility are subject to the OSHA PSM standard under 29 CFR  
1910.119.  Our facility is also subject to EPCRA Section 302 notification requirements.  We also  
have an air operating permit ID under Title V of the Clean Air Act.  The following sections briefly  
describe the elements of the release prevention program that is in place at our stationary  
source. 
 
a)  Employee Participation 
 
 
Dow 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.  Specific examples of employee  
participation range from writing and updating operating procedures to participating as a member  
of: 1) accident investigation teams, 2) project pre-startup reviews, and 3) process hazard  
analysis (PHA) teams.  All employees are encouraged to report any unsafe conditions and to  
initiate the Management of Change process to correct the condition.  Dow employees are also  
encouraged to intervene in unsafe acts to prevent injury to other employees.  Employees have  
access to all information created as part of the Torrance site Injury and Illness Prevention  
Program.  In addition, the Torrance site has a Site Safety Steering Committee whose function is  
to address overall site process safety and employee safety issues.  The Site S 
afety Steering  
Committee has members from various areas of the plant, including operations, maintenance,  
engineering and plant management. 
 
b)  Process Safety Information 
 
Dow keeps a variety of technical documents that are used to help maintain safe operation of the  
processes located at the Torrance, Ca site.  These documents address chemical properties and  
associated hazards, limits for key process parameters and specific chemical inventories, and  
equipment design basis/configuration information.  Chemical-specific information, including  
exposure hazards and emergency response/ exposure treatment considerations, is provided in  
material safety data sheets (MSDSs).  This information is supplemented by documents that  
specifically address known corrosion concerns and any known hazards associated with the  
inadvertent mixing of chemicals.  Safety-related limits for specific process parameters (e.g.,  
temperature, level, and composition) are maintained in documentation located in t 
he plant  
control room.  Dow ensures that the process is maintained within these limits using process  
controls and monitoring instruments, highly trained personnel, and protective instrument  
systems (e.g., automated shutdown systems).  These reference documents are readily  
available to all employees.  Several of these documents are also supplied to the Torrance Fire  
department, such as MSDSs and site maps, which show location of hazardous materials  
storage.  Specific departments within the facility are assigned responsibility for maintaining  
up-to-date process safety information. 
 
Dow also maintains numerous technical documents that provide information about the design  
and construction of process equipment.  This information includes materials of construction,  
design pressure and temperature ratings, electrical rating of equipment, etc.  This information,  
in combination with written procedures and trained personnel, provides a basis for establishing  
inspection and maintenance 
activities, as well as for evaluating proposed process and facility  
changes to ensure that safety features in the process are not compromised.  
 
c)  Process Hazard Analysis (PHA) 
 
Dow has a comprehensive program to help ensure that hazards associated with the various  
processes are identified and controlled.  Within this program, each process is systematically  
examined to identify hazards and ensure that adequate controls are in place to manage these  
hazards. 
 
Dow primarily uses the Fire and Explosion Index (F&EI) and Chemical Exposure Index (CEI)  
analysis techniques as screening methods to determine the need for more rigorous PHA  
methodologies.  OSHA recognizes F&EI and CEI as effective PHA methodologies.  If the F&EI  
and/or CEI analyses determine that a significant hazard exists from a process unit, then a  
Hazard and Operability (HAZOP) study is completed for the unit.  
 
A HAZOP was completed for the acrylonitrile unloading and storage area, and the ABS plastic 
production uni 
t, in January of 1996, to fulfill the PHA requirement for the California Risk 
Management and Prevention Program (a program eventually replaced by the RMP).  This 
HAZOP is considered to also fulfill the requirements for the Risk Management Plan, since no 
significant modifications were made to these processes. 
 
In all cases, the analyses are conducted using a team of people who have operating an 
maintenance experience as well as engineering expertise.  This team identifies and evaluates 
hazards of the process, and makes recommendations for additional prevention and/or  
mitigation measures as needed.  A relative risk ranking is assigned to the recommendations 
to aid in prioritization of the corrective actions. 
 
The PHA team recommendations are then forwarded to local management for review.  Local  
management prioritizes the recommendations, compiles a corrective action list with responsible  
parties and target completion dates and forwards this to corporate management for final review.   
 
Local management is accountable for the completion and documentation of these items. 
 
To help ensure that the process controls and/or process hazards do not deviate significantly  
from the original design safety features, the Dow facility periodically updates and revalidates the  
hazard analysis results.  These periodic reviews are conducted at least every 5 years and will  
be conducted at this frequency until the process is no longer operating.  The results and  
findings from these updates are documented and retained.  Once again, the team findings are  
forwarded to local management to be prioritized and addressed accordingly.  
 
d)  Operating Procedures 
 
Dow maintains operating procedures written to provide clear instructions for safely conducting  
activities associated with the process.  The operating procedures include the following items. 
 
 * Startup 
 * Normal Operations 
 * Shut down 
 * Emergency Shutdown 
 * Startup following a turnaround or emergency shutdown 
 
These procedu 
res can be used as a reference by experienced operators and provide a basis  
for consistent training of new operators.  The operating procedures are maintained current and  
accurate by revising them as necessary to reflect changes made through the management of  
change process. 
 
In addition, Dow maintains information describing normal operations.  Operating limits, 
consequences of deviation from these limits, and recommended actions that should be taken 
to avoid or correct the deviation are found in the process control computer logic programming  
documentation.  This information, along with written operating procedures, is readily available 
to operators and for other personnel to use as necessary to safely perform their job tasks. 
 
e)  Training 
 
To complement the written procedures for process operations, Dow has implemented a  
comprehensive training program for all employees involved in operating a process.  New  
employees receive basic training in personal safety, plant operation 
s overview, and emergency  
response via the "Minimum Requirements Checklist."  After successfully completing this training,  
a new operator is assigned to a training shift, with a senior training special to learn process-specific 
duties and tasks. 
 
After operating technicians demonstrate (e.g., through oral tests and skills demonstration) the  
knowledge adequate to perform the duties and tasks in a safe manner on their own, they can  
work independently.  During the initial training process, operating technicians only perform those 
tasks that they have demonstrated competency in.  Additionally, all operating technicians  
periodically receive refresher training on plant systems to ensure that their skills and knowledge 
are maintained at an acceptable level.  This refresher training is conducted at least every 3 years.  
All of this training is documented for each operator, including the means used to verify that the  
operator understands the training. 
 
f)  Contractors 
 
Dow uses contr 
actors to supplement its work force during periods of increased maintenance 
or construction activities, and to supplement the manufacturing work force.  Because contractors  
can work with, on, or near process equipment, the plant has procedures in place to ensure that  
contractors: 1) perform their work in a safe manner, 2) have the appropriate knowledge and skills, 
3) are aware of the hazards in their workplace, 4) understand what they should do in the event of 
an emergency, 5) understand and follow site safety rules, and 6) inform Dow personnel of any 
hazards that they find during their work.  This is accomplished by giving each contractor a safety 
orientation, when they come on site, which includes information about: 1) safety and health 
hazards, 2) emergency response plan requirements, and 3) safe work practices prior to their 
beginning work.  A Dow plant representative verifies that these items have been accomplished 
through the safe work permit process, which also includes a revi 
ew of job specific hazards.  In 
addition, Dow evaluates contractor safety programs and performance during the selection of a 
contractor.  Dow personnel periodically monitor contractor performance to ensure that  
contractors are fulfilling their safety obligations. 
 
g)  Pre-startup Audits 
 
Dow conducts a Pre-startup audit for any new facility or facility modification that requires a  
change in the process safety information.  The purpose of the Pre-startup audit is to ensure  
that: safety features, procedures, personnel, and the equipment are appropriately prepared for  
startup prior to placing the equipment into service.  This audit provides one additional check to  
make sure construction is in accordance with the design specifications and that all supporting  
systems are operationally ready.  The Pre-startup audit team uses checklists to verify all  
aspects of readiness.  A Pre-startup audit involves field verification of the construction and  
serves a quality assurance function by 
requiring verification that requirements of all Dow "Safety  
Standards" and "Loss Prevention Principles" are properly implemented. 
 
h)  Mechanical Integrity 
 
Dow has well-established practices and procedures to maintain pressure vessels, piping  
systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown  
systems in a safe operating condition.  The basic aspects of this program include: 1) conducting  
training, 2) developing written procedures, 3) performing inspections and tests, 4) correcting  
identified deficiencies, and 5) applying quality assurance measures.  In combination, these  
activities form a system that maintains the mechanical integrity of the process equipment. 
 
Dow employs contract service companies that perform required pressure vessel and process  
piping integrity thickness testing and inspections, who use procedures developed by the  
American Petroleum Institute (API), and the American Society of Mechanical Engineers  
(ASME).  The 
se companies are required to demonstrate accepted industry qualifications and  
training, in order to perform these tests and inspections.   
 
Dow personnel perform vibration analysis, oil analysis and lubricate pumps and compressors  
per written procedures, to help ensure that equipment functions as intended, and to verify that  
equipment is operating within acceptable limits.  If a deficiency is identified, employees will  
correct the deficiency before placing the equipment back into service (if possible), or an MOC  
team will review the use of the equipment and determine what actions are necessary to ensure  
the safe operation of the equipment.  The qualifications to perform these tests include training  
on: 1) an overview of the process, 2) safety and health hazards, 3) applicable maintenance  
procedures, 4) emergency response plans, and 5) applicable safe work practices to help ensure  
that they can perform their job in a safe manner.  
 
Another integral part of the mechanical in 
tegrity program is quality assurance.  Dow  
incorporates quality assurance measures into equipment purchases and repairs.  This helps  
ensure that new equipment is suitable for its intended use and that proper materials and spare  
parts are used when repairs are made. 
 
i)  Safe Work Practices 
 
Dow has long-standing safe work practices in place to help ensure worker and process safety.  
Examples of these include 1) control of the entry/presence/exit of support personnel, 2) a  
lockout - tagout procedure to ensure isolation of energy sources for equipment undergoing  
maintenance, 3) a procedure for safe removal of hazardous materials before process piping or  
equipment is opened, 4) a permit and procedure to control spark-producing activities (i.e., hot  
work), and 5) a permit and procedure to ensure that adequate precautions are in place before  
entry into a confined space.  Dow also maintains a strictly enforced no-drug policy.  These  
procedures (and others), along with training o 
f affected personnel, form a system to help  
ensure that operations and maintenance activities are performed safely. 
 
j)  Management of Change 
 
Dow has a comprehensive system to manage changes to processes.  This system requires that  
changes to items such as process equipment, chemicals, technology (including process  
operating conditions), procedures, and other facility changes be properly reviewed and  
authorized before being implemented.  Changes are reviewed to: 1) ensure that adequate  
controls are in place to manage any new hazards and 2) verify that existing controls have not  
been compromised by the change.  Affected process safety information, process operating  
limits, and equipment information, as well as procedures, are updated to incorporate these  
changes.  In addition, operating and maintenance personnel are provided any necessary  
training on the change. 
 
k)  Incident Investigation 
 
Dow promptly investigates all incidents that resulted in, or reasonably could h 
ave resulted in, a  
fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury.  
The goal of each investigation is to determine the facts and develop corrective actions to  
prevent a recurrence of the incident or a similar incident.  The investigation team documents its  
findings, develops recommendations to prevent a recurrence, and forwards these results to  
plant management for resolution.  Corrective actions taken in response to the investigation  
team's findings and recommendations are tracked until they are complete.  The final resolution  
of each finding or recommendation is documented, and the investigation results are reviewed  
with all employees (including contractors) who could be affected by the findings.  Incident  
investigation reports are retained for at least 5 years so that the reports can be renewed during  
future PHAs and PHA revalidations. 
 
l)  Compliance Audits 
 
To help ensure that the accident prevention program is functio 
ning properly, Dow periodically  
conducts an audit of our procedures and practices for both accuracy and compliance.  Audits  
are conducted at least every 3 years with both hourly and management personnel as audit  
team members.  The audit team develops recommendations that are forwarded to local  
management for review.  A prioritized corrective action list with responsible parties and target  
completion dates is generated to address each of the audit team?s recommendations.  Local  
management is accountable for the completion and documentation of these items.  The two  
most recent audit reports including corrective actions are retained at all times.  Compliance  
audits are conducted for the areas of: 1) Reactive Chemicals, 2) Process Safety, 3) Personal  
Safety, 4) Industrial Hygiene, 5) Hazardous Materials Transportation, and 6) Security.   
 
 
 
Section 5.  Chemical Specific Prevention Steps 
 
The Dow Acrylonitrile storage tank, tank car unloading, and ABS production processes must 

e managed to ensure continued safe operation.  The prevention programs summarized 
previously help prevent potential accident scenarios that could be caused by equipment 
failures and human errors. 
 
In addition to the prevention program activities, these processes have safety features to 
help: 1) quickly detect a release, 2) contain/control a release, and 3) reduce the  
consequences of (mitigate) a release.  The following types of safety features are used in  
various processes: 
 
Release Detection: 
 
? Flammable gas detectors with alarms 
 
? 100% attendance during entire tank car unloading process 
 
? Sensors measuring pressure, temperature, and level deviations 
 Release Containment / Control 
 
? Valves to permit isolation of the process (manual or automated) 
 
? Automated shutdown systems for specific process parameters (e.g., high level, high pressure) 
 
? Diking to contain liquid releases 
 
? Fire fighting foam to minimize evaporation 
 
? Redundant equipment and instrumentation (e.g. 
, uninterruptible power supply for 
 process control system, backup firewater pump) 
 
? Pressure relief devices 
 
Release Mitigation 
 
? Fire suppression deluge systems with fire fighting foam capability 
 
? Emergency response trained to First Responder Operations level and Incident Commander 
 
? Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 
 
The Dow Acrylonitrile storage tank and tank car unloading process must be managed to  
ensure continued safe operation.  The prevention programs summarized previously help  
prevent potential accident scenarios that could be caused by equipment failures and human  
errors. 
 
 
Section 6.  Five-Year Accident History 
 
There have been no releases of acrylonitrile which have resulted in a fire, injury, or adverse impact to the environment, or had any off site impact during the last 5 years. 
 
 
Section 7.  Emergency Response Program Information 
 
The Dow facility maintains a written emergency response pl 
an, which is in place to protect  
worker and public safety as well as the environment. The plan consists of procedures for  
responding to a release of hazardous materials including acrylonitrile.  Included in these  
procedures is the possibility of a fire or explosion if a flammable substance is accidentally  
released.  The procedures address evacuation plans and accounting for personnel after an  
evacuation, notification of local emergency response agencies, and post incident cleanup and  
decontamination requirements.  In addition, Dow has procedures that address maintenance,  
inspection, and testing of emergency response equipment.  Employees receive training in these  
procedures as necessary to perform their specific emergency response duties.  The emergency  
response plan is updated when necessary based on modifications made to plant processes or  
other.  The emergency response program changes are administered through the MOC process,  
which includes informing and/or training affec 
ted personnel in the changes. 
 
The overall emergency response program for the Dow facility is coordinated with the Torrance  
Fire Department.  This coordination includes periodic tours, training and Hazardous Material  
incident drills.  Dow can notify the Torrance Fire Department 24 hours/day via 911.  This  
provides a means of notifying the public of an incident, if necessary, as well as facilitating quick  
response to an incident.  The Dow facility also conducts drills periodically with the Torrance Fire  
Department to facilitate training of their personnel. 
 
 
Section 8.  Planned Changes to Improve Safety 
 
 ? The Dow facility plans to complete a revalidation of Hazard and Operability (HAZOP) study,  
    and correcting any noted deficiencies.  
 ? Evaluate building a acrylonitrile tank car containment dike within the Styrene storage tank 
   containment to reduce Toxic Endpoint distance, in the event of a release. 
 ? Addition of foam fire suppression capability to the existing 
ABS plastic production structure 
   deluge system. 
 ? Evaluate feasibility of adding an automatic emergency block valve on the acrylonitrile tank 
    car unloading hose. 
 
The expected completion date for these changes is January, 2002 
 
       
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