PPG Industries, Inc., Natrium - Executive Summary |
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EXECUTIVE SUMMARY PPG Industries, Inc., Natrium Facility Accidental release prevention and emergency response policies The PPG Natrium facility complies with OSHA's Process Safety Management Rule (29 CFR 1910.119), applicable Ohio and federal EPA regulations, and applicable Coast Guard and Department of Transportation requirements. PPG also follows the Responsible Care? Codes of Management Practice, including the Responsible Care? Community Awareness Code of Management Practice, and PPG's own Community Awareness and Emergency Response (CAER) Policy to assure emergency preparedness and foster community right-to-know. PPG's CAER Policy requires each manufacturing plant to have a pro-active community awareness and emergency response program to handle emergencies that might happen in that facility. All of these activities form an integral part of PPG's overall Environment, Health and Safety Policy, whose goal is "to manufacture, sell, and distribute products worldwide in a manner tha t is safe and protective of our employees, neighbors, customers and other stakeholders, and the environment." Regulated substances handled The Natrium facility is part of the Chlor-Alkali business group of PPG Industries, Inc. Natrium is a principle producer of chlorine, sodium hydroxide, chlorinated organics, carbon disulfide, sodium sulfide, sodium hydrosulfide, and calcium hypochlorite. Chlorine and sodium hydroxide are produced concurrently by the electrolysis of salt dissolved in water in either a mercury cell or diaphragm cell. Chlorine is used in the purification of drinking water, wastewater treatment, and several household products and as a powerful disinfectant. Chlorine is widely used in the manufacture of many synthetic chemicals such as chlorinated solvents, refrigerants, pesticides, synthetic rubber, and household cleaners. The Natrium facility has four applicable RMP toxic chemicals including chlorine, anhydrous ammonia, sulfur dioxide, and carbon disulfide. Wors t-case and alternative case release scenarios An off-site consequence analysis was performed for the largest quantities of flammable and toxic materials in the facility. The Natrium facility has no RMP applicable flammable chemicals. The guidelines and Off-site Consequence Analysis Guidance as per 40 CFR 68.25 were utilized in this process. Natrium used commercial software titled PHAST Professional, version 5.11, to determine off-site impacts from both the worst-case and alternative release scenarios. EPA rules require that a worst case scenario be analyzed which would involve the highly unlikely release in ten minutes of the entire contents of the largest storage container. Based on dispersion modeling using PHAST 5.11 software and the EPA specified assumptions, off-site concentrations of chlorine would cause off-site impact. Alternative case release scenarios (ACRS) were developed for each of the listed chemicals in the facility. These scenarios followed the guidelines provid ed by EPA and used PHAST software to perform the end-point calculations. The local emergency planning committee and office of emergency planning will utilize the ACRS information in conjunction with PPG experts to develop emergency response plans, train responders, perform practice drills and maintain the appropriate equipment. The ACRS for chlorine evaluated a scenario where a chlorine railcar is moved during loading and a loading line is ruptured. The quantity released of 376 pounds would be limited by check valves and automatic shutoff valves. No off-site impacts result from this scenario. The ACRS for carbon disulfide evaluated a scenario where an overflow of a carbon disulfide railcar occurs during loading. Approximately 500 pounds of carbon disulfide would be released forming a pool and instantaneously evaporates. No off-site impacts result from this scenario. The ACRS for anhydrous ammonia evaluated a scenario where a liquid ammonia unloading hose ruptures during truck u nloading. The amount of ammonia released of 300 pounds would be limited by process check valves and excess flow valves. No off-site impacts result from this scenario. The ACRS for sulfur dioxide evaluated a scenario where a sulfur dioxide line develops a leak in a half inch line instrument fitting. The operator would discover the leak on equipment rounds and isolate the leak. The release rate would be 585 pounds over a 30 minute period. No off-site impacts result from this scenario. General accidental release prevention program and chemical specific prevention steps Trained personnel and environmental, health and safety measures are included in all phases of the Natrium facility operation. Detailed engineering and design standards are used. These standards may include national codes and standards, quality assurance inspections, over pressure protection systems, flammable and toxic gas detectors, emergency shutdown systems, a fire water system and computer controls for the pro cesses. Employees at the facility receive job-appropriate training. Training is an ongoing process that includes periodic retraining, as appropriate. Safety, environmental, operating and training procedures are subject to periodic reviews and updates. Additionally Management of Change (MOC) procedures assure review of proposed changes and ensure that training needs are met. Operators and foreman actively participate with engineers that lead process hazard analyses to review potential hazards and to recommend additional safeguards if needed. The Natrium facility has an array of maintenance and inspection programs to minimize equipment or piping failures. Inspections of equipment are scheduled at a frequency related to the equipment condition, the severity of the service environment, the required reliability or the manufacturers recommended schedule. Equipment inspections utilize procedures such as proof testing where safeguard systems are forced to function in a controlled manne r. This assures that the safeguards will function as intended if needed. Preventive and predictive maintenance programs are utilized and can include vibration monitoring, infrared imaging to detect differences in temperature, inspections by independent experts, inspections by insurance specialists and a root-cause analysis program. Piping systems are inspected and tested with X-rays and/or hydrostatic tests. The piping is monitored by a variety of methods. Training and procedures have been developed for activities that are specific to different types of equipment. Five-year accident history The Natrium facility has had two RMP reportable accident/releases within the five years proceeding the RMP submittal. The incidents involved the release of chlorine and resulted in no off-site impacts. Emergency response program The Natrium facility maintains an Emergency Response Manual which addresses emergency planning and response. Additionally, an Emergency Control Plan for the facil ity is included in the Process Safety Manual. The Natrium facility has a trained on-site Emergency Response Team that is HAZWOPER certified and available for around the clock response to emergency incidents, provide emergency medical attention, fight fires, control chemical releases, and initiate road blocks and/or public emergency procedures. Additionally, Natrium participates in regular monthly meetings with a Community Advisory Panel (CAP) and emergency responders regarding emergency response for the community. There are also community emergency alarm systems in place at the facility to alert the public of an evacuation or shelter-in-place activation. Planned changes to improve safety PPG is committed to the process of continuous improvement. This commitment extends beyond production into the environmental and safety aspects of all operations. For further information, contact Mr. Richard L. Holliday, Works Manager, Natrium Facility at (304) 455-2200. |