Crompton Taft Plant - Executive Summary |
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Witco Taft RMP Executive Summary 2706 LDEQ Facility ID Number 1. Accidental release prevention and emergency response policies at Witco Taft. Taft is committed to ensuring the safety of St. the Charles Parish Community by the rigorous implementation of the best safety management practices. These practices focus on accident prevention and accident management. 2. Regulated Substances Handled at the Witco Taft Facility. Witco Taft employs 273 people who live and work in the St. Charles Parish area. Witco has been in business at the same location since 1966. The facility produces plastic additives including processed vegetable oils, metal soaps, tin and sulfur compounds. Our products are used in Louisiana and globally in the production of plastics and polymers used on a daily basis. Witco Taft has three toxic chemicals in threshold quantities affected by the RMP rule - ammonia (anhydrous and aqueous), methyl chloride and carbon disulfide. 3. Worst Case release scenario and altern ative release scenario. The RMP rule requires the development of accidental release scenarios. For example, anhydrous ammonia was selected as the toxic chemical of concern because it has the greatest area of potential impact in the community. A worst-case scenario and an alternative release scenario are designed to calculate the potential impact on the community. A worst-case scenario is defined as the complete release of the largest inventory of the chemical over 10 minutes under weather conditions that would allow the chemical to travel as far as possible at ground level. It also assumes that none of the site's mechanical controls or safety systems are operational. A worst-case scenario is highly unlikely to occur. Given the severe guidelines of a worst-case scenario, more realistic planning scenarios, or alternative release scenarios, were also developed to more closely simulate a real world event. These scenarios involve smaller releases and allow safety systems to be inclu ded in the calculations. The alternative release scenarios will be useful to local government and industry to prepare emergency response plans. As required by the rule, the facility has prepared the above scenarioes and entered into an active and open dialogue with the local Department of Emergency Preparedness concerning response to the above scenarioes, especially the more likely alternate case scenarioes. The facility places the greatest premium on accident prevention for managing a worst case scenario. This scenario is an Anhydrous Ammonia rail car rupture. Here prevention is the key: Anhydrous Ammonia rail cars are equipped with pressure relief safety valves should fire threaten to catastrophically rupture the rail car. In addition, unloading emergencies are unlikely to result in catastrophic release as the unloading system has emergency unloading equipment shutdown, is under camera surveillance and is subject to mechanical integrity inspection (unloading hoses are inspected p rior to use and replaced as required or every six months, which ever comes first). Furthermore this scenario is unlikely to impact large sectors of the St. Charles Parish Community as the plant will use fire protection equipment to knock down the ammonia cloud to minimize release and communication link to off-site responders primarily DEP/LEPC to order road closures, sheltering in place or evacuation. Alternative Release Scenario's. These involve failure of a railcar unloading hoses, transfer pipeline failure and pressure relief valve venting. Using average weather conditions these releases would impact not more than 2 miles per EPA RMP*Comp computer program. 4. Accident Release Prevention Program and chemical-specific prevention steps. The facility implements OSHA Safety Management rules to minimize chemical process accidents. The key to these process management practices are process hazard analysis studies conducted by the employees, mechanical integrity testing of the pro cess equipment and operator training. 5. Five year accident history. Witco Taft is required to compile an accident release history for the RMP listed chemicals for the past five years. According to the RMP rule, an accidental release is defined as one that resulted in death, injuries, significant property damage, evacuations, shelter-in-place, or environmental damage. Witco has had zero RMP releases over the past five years. 6. Emergency Response Program. The key to the facility response program is the dedicated phone system tied to the St. Charles Parish Department of Emergency Preparedness (DEP). This Department can call in assistance from the Parish Police, Fire Department, Hospitals and adjacent chemical facilities to mitigate and control emergency situations. The Department can also alert the community as to the steps to take in response to emergency situations. 7. Planned Changes to improve safety. At this time Witco Taft is planning to receive anhydrous ammonia by pip eline rather than by rail car. While both forms of delivery are safe and practical, pipeline delivery does not involve the manual connection of transfer hoses and as such is intrinsically safe when a mechanical integrity program monitors the pipeline. |