Solutia W.G. Krummrich Plant - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At Solutia's W. G. Krummrich Plant, we are committed to operating and maintaining
all of our processes (especially those using hazardous substances) 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 and the public as well as protection of the environment. This
document provides a brief overview of the comprehensive risk management
activities that we have designed and implemented, including:
* A description of our facility and use of substances regulated by EPA's RMP
* A summary of results from our assessment of the potential offsite
consequences from accidental chemical releases
* An overview of our accidental release prevention programs
* A five-year accident history for accidental releases of chemicals regulated
by EPA's RMP rule
* An overview of our emer
gency response program
* 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 W.G. Krummrich Plant is the second oldest of the U.S. Solutia Plants, with ~400 employees. In 1917, as part of Monsanto, the site was purchased from the Commercial Acids Company, which had started the plant in 1907 to manufacture sulfuric, muriatic, and nitric acids. Today the plant occupies 311 acres and manufactures a variety of chemical intermediates which include chlorobenzenes, phosphorous pentasulfide, rubber antidegredents, and swimming pool chlorinating agents. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release:
Anhydrous ammonia is shipped in tank t
rucks to the W.G. Krummrich plant by suppliers. Solutia has strict unloading and handling procedures for the material. A maximum of 56,000 pounds of ammonia are stored at the plant as a liquid in a pressurized, above-ground steel tank. Solutia?s W.G. Krummrich Plant uses anhydrous ammonia to make dyes, resins and paints, and in the manufacturing of polyvinyl butyral, a plastic interlayer used in laminated safety glass for automotive and architectural applications.
Aqueous Ammonia is stored at the W.G. Krummrich plant as a recovered material which is reused in one department and stored for off-site sale in the another department. The largest above-ground storage tank of this material holds 250,000 pounds. Solutia?s W.G. Krummrich Plant uses aqueous ammonia to make dyes, resins and paints, and in the manufacturing of polyvinyl butyral, a plastic interlayer used in laminated safety glass for automotive and architectural applications and it is a byproduct in the ma
nufacturing of swimming pool chemicals.
Chlorine gas is shipped in rail cars to the W.G. Krummrich plant by suppliers. Solutia has strict unloading and handling procedures for the material. An average of 26 Railcars of chlorine are stored at the plant. The chlorine is used directly from the cars through state-of-the-art unloading/vaporization systems. Solutia's W.G. Krummrich plant uses chlorine as a raw material in the manufacturing of building block chemicals used to make soaps, dry cleaning agents, moth balls and swimming pool chemicals.
Nitric acid is shipped to the W.G. Krummrich plant in rail cars by the supplier. Solutia has strict unloading and handling procedures for the material. An average of 350,000 pounds of nitric acid are stored at the plant in above-ground metal tanks. Solutia?s W.G. Krummrich Plant uses nitric acid in the manufacturing of nitrochlorobenzenes from chlorobenzenes. Nitrochlorobenzenes are used to make numerous products, in
cluding chemicals that go into non-aspirin pain relievers and rubber chemicals.
Our accidental release prevention programs and our contingency planning efforts
help us effectively manage the hazards that are posed to our employees, the
public, and the environment by our use of these chemicals.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information about the worst-case release
scenario and alternative release scenarios for our facility. The following
are brief summaries of these scenarios, including information about the key
administrative controls and mitigation measures to limit the exposure distances
for each scenario:
Worst-case Release Scenario - Regulated Toxic Chemicals
The scenario selected at the W.G. Krummrich plant involves Nitric Acid. The largest storage tank of Nitric Acid holds a maximum of 375,000 pounds and would assume the entire contents of the tank is released to the environment in 10 minutes. No
administrative controls or mitigation controls are assumed for this worst-case scenario. The resultant plume would have offsite consequences into the greater St. Louis metropolitan area.
Alternative Release Scenarios - Regulated Toxic Chemicals
Chlorine: Three alternative release scenarios were developed for chlorine, all three involve small leaks on the 90 ton rail cars. One scenario is a small leak developing on the rail car relief valve and the other two scenarios involve identical leaks on the rail car unloading valve; the difference being the location of the department, using the rail car, on the site. In all three cases, the leak would yield a slight off-site consequence and would be mitigated by the site?s Hazardous Materials Response Team.
Anhydrous Ammonia: One alternative release scenario was developed for anhydrous ammonia involving a vent line failure on the top of the 56,000 pound above-ground storage tank. The scenario requires the site?s Hazardous Materials
Response Team to close off the valve stopping the leak. This leak would yield a slight off-site consequence.
Aqueous Ammonia: Two alternative release scenarios were developed for aqueous ammonia, one in each of the departments that store the chemical. One scenario involves the inadvertent emptying of a small, 2000 gallon, hold tank during a transfer operation. The other scenario involves a leak on the bottom of a small storage tank, which would be mitigated by the site?s Hazardous Materials Response Team. Either scenario would yield a slight off-site consequence.
Nitric Acid: Two alternative release scenarios were developed for Nitric Acid, one within the department and one involving a rail car being held for use. The scenario within the department involves a failure of a transfer pipeline and the subsequent shutdown and isolation of the pipeline. The rail car scenario would involve a small leak developing on the bottom of the rail car and mitigation by the site?s Hazardous
Materials Response Team. Both scenarios yield an off-site consequence that would impact the immediate area surrounding the plant.
We are using this information to help us ensure that our emergency response plan
and the community emergency response plan address all reasonable contingency
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We take a systematic, proactive approach to preventing accidental releases of
hazardous chemicals. Our management systems address each of the key features of
successful prevention programs including:
* Process safety information
* Process hazard analysis
* Operating procedures
* Mechanical integrity
* Management of change
* Pre-startup review
* Compliance audits
* Incident investigation
* Employee participation
* Hot work permit
As part of our prevention efforts, we have implemented the following
chemical-specific prevention steps:
DESIGNING for Safety?
? Vessels designed and constructed under American Society of Mechanical Engineers (ASME) code standards.
? All systems and components designed to meet or exceed government standards.
? Leak detection systems for instant detection of minute leaks.
? Fail safe and pressure relief valves.
? Secondary containment for storage tanks.
? Flow controller/regulator systems.
? Automatic shutdown devices and alarms for critical control systems.
? Operator interface systems.
? Multiple layers of protection for all safety critical systems.
MAINTAINING our Plant?
? Routine inspection and testing of entire systems by highly skilled and trained maintenance personnel.
? Annual inspection of critical equipment, including automatic shutdown devices.
? Preventive maintenance for all critical vessels, including 100 percent x-ray of all welds and acoustic testing of process vessels.
? Computerized scheduling, tracking, and notification system - Safety Inspection and Maintenance Syste
m(SIAM) - to keep maintenance on schedule.
? Operators are trained on current operating procedures. and the procedures are certified annually under OSHA standards and higher company requirements.
? All site operations continuously monitored and controlled by computer systems that automatically shutdown systems to preserve safety.
? Continually manned control room to oversee the computer system as part of a multiple-level, manual backup system.
? Operators trained on current operating procedures.
? Random drug testing for all personnel in safety critical jobs.
? Written operating procedures and standards based on OSHA, EPA and company wide requirements.
? Procedures certified annually under OSHA standards and higher company requirements.
? Formal hazard analysis studies conducted on critical operations by trained and certified teams according to world class Hazard and Operability Analysis(HAZOP) methodologies.
AUDITING our Operations?
? Awarded 1997 Merit Site in the
OSHA Voluntary Protection Program(VPP).
? Routine external audits by OSHA, EPA, U.S. Department of Transportation and Illinois IEPA.
? Corporate audits conducted every three years by Corporate Safety, Health and Occupation Medicine groups, most recent in 1997.
? Corporate Environmental audit conducted every three years, most recently late 1998.
? Internal audits conducted every three years on our OSHA Process Safety Management(PSM) systems.
? Process Hazard Analysis conducted on all projects and changes and every 5 years per the OSHA PSM standard.
? Routine operations and maintenance audits of equipment and systems.
? Complete investigations of all accidents and incidents.
These individual elements of our prevention program work together to prevent
accidental chemical releases. Our company and our employees are committed to
the standard that these management systems set for the way we do business, and
we have specific accountabilities and controls to ensure that we are meeting
own high standards for accident prevention.
FIVE-YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at
our facility. The following is a brief summary of accidental chemical releases
involving materials covered under EPA's RMP rule during the past five years:
YEAR _______1994 1995 1996 1997 1998 1999
Number of Offsite RMP Releases 0 0 0 0 0 0
Number of Onsite RMP Releases 0 0 0 0 1 1
During the past five years, two U.S. Occupational Safety and Health Administration (OSHA) reportable injuries have occurred, in separate incidents, as a result of very minor on site releases of RMP listed chemicals. No significant on site property damage has occurred during the past five years.
For each of these incidents, we have conducted formal incident investigations to
identify and correct the root causes of the events.
EMERGENCY RESPONSE PROGRAM
We maintain an integrated contingenc
y plan, which consolidates all of the
various federal, state, and local regulatory requirements for emergency response
planning. Our program provides the essential planning and training for
effectively protecting workers, the public, and the environment during emergency
situations. Furthermore, we coordinate our plan with the community emergency
Training and Preparation
? 24-hour on-site Emergency Response Team(ERT), training includes advanced interior and exterior structural fire fighting, hazardous material emergency response, confined space and technical rescue.
? Specialized teams and technical specialists dedicated to off-site response for hazardous material transportation emergencies.
? All personnel in departments handling RMP chemicals trained annually in emergency shutdown procedures.
? Solutia Fire Department trained routinely in cooperation with municipal fire, police and ambulance crews.
? Active participation in St. Clair County Local Emergency Plan
ning Commission and Illinois TRANSCAER (Transportation Community Awareness and Emergency Response Committee).
If a Release Occurs?
? Department operators proceed to shutdown and isolate the entire system.
? ERT alerted and dispatched.
? Operations alerted and dispatched.
? Preplanned release drill scenarios put into action.
? ERT equipment throughout plant activated to minimize release impact.
Community Emergency Response?
? Community Warning Siren sounded in Sauget Industrial area as a long wail; and when clear a short wail.
? Community Alert Network (CAN) activated, calling affected residences and businesses.
? Affected persons follow emergency procedures for sheltering in place, considered a proven method for protecting individuals and families in the event of an accidental release.
PLANNED CHANGES TO IMPROVE SAFETY
Solutia?s W.G. Krummrich plant is committed to the principals of continuous improvement in all areas of safety. This is key to our participation in OSHA?s
Voluntary Protection Program. Our plant is constantly upgrading its operations and safety systems to improve the level of protection. Each area of the plant undergoes a Process Hazard Analysis whenever a new project or change is made and on a five year basis a full hazard analysis is made of each department. These hazard analyses result in many recommendations that lead to a safer facility.