Gaylord Chemical Corp., Bogalusa Plant - Executive Summary
Gaylord Chemical Corporation has prepared a Risk Management Plan, in compliance with Louisiana Department of Environmental Quality (DEQ) requirements, for its Bogalusa, Louisiana plant, which registered with the DEQ as facility number 7365. |
- Accidental release prevention and emergency response policies at facility.
Gaylord Chemical's accidental release prevention program is based on the OSHA Process Safety Management system, and includes regularly scheduled process hazards analyses. Its emergency response program includes a written response plan with specific actions to be taken by Gaylord Chemical personnel and information to be provided to responders and the public in the event of an incident. Gaylord Chemical also works with local emergency response agencies and members of the community to review and improve its emergency response program.
- Facility and regulated substances handled.
At its Bogalusa plant, Gaylord Chemical makes two products---DMS (dimethyl sulfide) and DMSO
(dimethyl sulfoxide)--and sells and ships them to customers in 22 countries around the world. Gaylord Chemical makes DMS by combining sulfur with organic wood by-products obtained from a near-by paper mill. DMS is used for a variety of purposes, including as a safety odorant in natural gas. Gaylord Chemical sells some of the DMS it manufactures and combines the remainder with oxygen and nitrogen tetroxide (N2O4), to make DMSO. DMSO is used in the manufacture of pharmaceuticals and agricultural chemicals. N2O4 is a regulated substance under Louisiana regulations.
- Worst-Case and alternative release scenarios, including administrative controls, mitigation measures, and off-site impact.
Following DEQ guidelines, Gaylord Chemical has assessed the off-site consequences of a hypothetical "worst-case scenario" in its Risk Management Plan. Based on the DEQ requirements, the worst-case scenario was assumed to be the release as a gas of the entire contents of a one-ton N2O4 container in
ten minutes. DEQ guidelines do not allow active mitigation efforts to be taken into account when modeling the results of the worst-case scenario.
DEQ guidelines further provide that the release must be estimated to an "endpoint" which the DEQ has defined for N2O4 as a concentration of two parts per million. Gaylord Chemical is not aware of any convincing data supporting the use of this concentration value in this context.
Accordingly, Gaylord Chemical believes that the conditions assumed for this "worst-case" scenario are unrealistic and unlikely to occur. Further, the United States Environmental Protection Agency has stated that "the distance to the endpoint estimated under worst case conditions should not be considered a zone in which the public would likely be in danger."
Gaylord was also required to assess the consequences of a hypothetical alternative scenario. The alternative scenario involves a release of liquid N2O4 from a broken hose between a one-ton N2O4 cylinder and t
he DMSO process. However, the effects of any release would be mitigated because this hose is contained within a building. In addition, in the event of such a release, Gaylord Chemical's response procedures include deluging the release with water, thereby suppressing the fumes and limiting the release. This mitigation capability has again not been taken into account under the DEQ modeling guidelines in analyzing the consequences of the alternative release.
Gaylord Chemical's off-site analysis, using a computer modeling program called DEGADIS, predicts that the worst case and alternative scenarios described above may likely have some off-site consequences. Because of the unrealistic assumptions and methods employed, however, Gaylord does not necessarily vouch for or endorse the accuracy of theses analyses. Gaylord believes these analyses to be of limited value, particularly for purposes of emergency response planning. As EPA has noted in connection with preparation of worst case an
alyses for risk management plans, the estimated distances are intended to provide only a basis for a discussion among interested parties, not a basis for any specific actions.
- General accidental release prevention program and chemical-specific prevention steps.
Gaylord Chemical already complies with the DEQ's Risk Management Plan rules and with the accidental release protection steps required under the OSHA Process Safety Management (PSM) program intended to protect workers from accidental releases. The P.M. program includes process hazards analyses, operating procedures, training, preventive maintenance, incident investigations, pre-startup reviews, and management of change. Periodic audits assure compliance.
- Five year accident history.
Gaylord Chemical's five year accident history includes the failure of a railcar containing contaminated N2O4, which occured on October 23, 1995. This incident resulted in litigation that is currently in progress. Gaylord does not believe t
hat the claims asserted by the plaintiffs in this litigation for damages allegedly arising from this event have merit. Some of the information reported in section 6 of the Risk Management Plan, including the information concerning on-site and off-site impact, was derived from preliminary reports of investigating agencies. Gaylord Chemical does not necessarily agree with that information, but provides it in compliance with DEQ requirements.
Since the accident, Gaylord Chemical has revised its operating procedures so that it no longer receives N2O4 in rail tank cars. Instead, N2O4 is transported, stored, and used directly from one-ton steel cylinders.
- Emergency response program.
Gaylord Chemical's emergency response program is set forth in its written Emergency Plan and includes actions to be taken by Gaylord Chemical personnel in the event of many types of emergencies. Gaylord Chemical coordinates emergency preparedness measures with local emergency response agencies including t
he Bogalusa Police Department, Bogalusa Fire Department, and the Washington Parish Local Emergency Planning Committee.
In addition, Gaylord Chemical has developed a written Emergency Handbook to augment its strigent training program for all plant employees. The Emergency Handbook sets forth actions to manage, control, and respond to emergency situations. For example, the Emgergency Handbook covers responses to such situations as fires, spills, releases, utility failures, emergency shutdown, hurricanes, personal injury, and civil disturbances.
Emergency preparedness training for plant employees includes first aid, CPR, hazardous materials awareness and emergency notification procedures, and fire safety training. Gaylord Chemical also maintains a list of qualified emergency hazardous materials contractors available to assist in emergencies requiring specialized expertise. Finally, Gaylord Chemical has chemical monitoring instruments to warn of leaks and an emergency alarm system, wh
ich is tested weekly.
In addition to Gaylord Chemical's internal Emergency Plan, Gaylord Chemical works with the City of Bogalusa and Washington Parish under its emergency preparedness plan that includes coordinated public safety and emergency response measures for Bogalusa and the surrounding area, including the following: a city-wide siren system; a traffic alert system for Willis Avenue, the street adjacent to the plant; an emergency alert system for local radio stations and cable TV override; coordination with police, sheriff, fire, local hospitals, and doctors; and a telephone ring-down notification system.
- Planned changes to improve safety.