ETHOX CHEMICALS LLC. - Executive Summary |
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Ethox Chemicals LLC. Risk Management Plan Executive Summary EXECUTIVE SUMMARY Ethox Chemicals LLC. ( Ethox ) is committed to operating in a manner that is safe for its employees, the public, and the environment. As part of this commitment, Ethox established a system to ensure safe operation of the processes at this facility. Part of this system is a Risk Management Program that helps manage potential risks at Ethox and that complies with the requirements of the Environmental Protection Agency's (EPA) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One requirement of the rule is to submit a Risk Management Plan (RMP) describing the risk management program at Ethox. This document is intended to satisfy the RMP requirements of the RMP rule and to provide the public with a description of the risk management program at Ethox. 1. Accidental Release Prevention and Emergency Response Policies Ethox is committed to empl oyee, public and environmental safety. A comprehensive accidental release prevention program is in place that covers areas such as the design, installation, operating procedures, maintenance, and employee training associated with the processes at the facility. It is Ethox policy to implement appropriate controls to prevent possible releases of regulated substances. However, if such a release does occur, Ethox is completely coordinated with Donaldson Center Fire Department which provides trained emergency response personnel to assist in the control and to mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled The facility's primary activity is the manufacturing of Surface Active Chemicals. There are two regulated substances present at the facility: Ethylene oxide [Oxirane] (EO) and Propylene oxide [Oxirane, methyl-] (PO). EO and PO are used for manufacturing detergents, emulsifiers and wetting agents. The maximum inventory in any one ves sel of EO or PO at this facility is 170000.00 lbs. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), include administrative controls and mitigation measures to limit the distances for each reported scenario Ethox performed an offsite consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. The OCA consists of evaluating both worst-case scenarios (WCS) and alternative release scenarios (ARS). An ARS represents a release that might occur during the lifetime of a facility like Ethox. An ARS helps the LEPC improve the community emergency response plan. The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance. At a distance less than the endpoint distance, the effects would be greater ; at distances greater than the endpoint distance, the effects would be less. When considering the release of a toxic substance, most people at the endpoint distance would be able to walk away from the exposure without any long-term health consequences, although some short term consequences (e.g., strong eye or throat irritation) are likely. People who are particularly susceptible to the substance released could be incapacitated. To perform the required offsite consequence analysis for the facility, Ethox has used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. Worst-case Release Scenarios The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from a rail car. The scenario involves the release of 170000 lb. of Ethylene oxide [Oxirane] in a gaseous form over 10 minutes. Under worst case weather conditions, namely Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 11 miles is obtained corresponding to a toxic endpoint of 0.090 mg/L. Alternative Release Scenarios One alternative release scenario will be submitted for each toxic substance present in Program 2 and Program 3 processes cumulatively. The alternative release scenario for EO involves a release from the relief valve opening on an EO Rail Car. The release rate is 6,000 lb/hr. This release rate is set by the relief valve flow capacity. The duration is 5 minutes. The alternative release scenario is based on the relief valve opening from over pressurization due to excess nitrogen flow to the rail car. In accordance with Ethox response procedures, plant personnel will quickly stop the nitrogen flow , allowing the relief valve to re-close. The elevation is 13 feet to the top of an EO rail car. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.090 mg/L is 0.37 miles. The alternative release scenario for PO involves a release from the relief valve opening on a PO Rail Car. The release rate is 6,000 lb/hr. This release rate is set by the relief valve flow capacity. The duration is 5 minutes. The alternative release scenario is based on the relief valve opening from over pressurization due to excess nitrogen flow to the rail car. In accordance with Ethox response procedures, plant personnel will quickly stop the nitrogen flow, allowing the relief valve to re-close. The elevation is 13 feet to the top of an PO rail car. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.090 mg/L is 0.37 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps The 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. This facility was designed and constructed in accordance with (N FPA-58 Standard, 1967 Edition). A number of processes at the facility are subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program that are in place at Ethox. Process Safety Information Ethox maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis The facility conducts comprehensive studies to ensure that hazards associated with processes are identified and controlled efficiently. The methodology used to carry out these analyses is Leader 2.3 process sections and deviations. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of three years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purpo ses of safely conducting activities within the covered processes, Ethox maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved with the processes. Training Ethox has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least annually and more frequently as needed. Mechanical Integrity Ethox carries out documented maintenance checks on process equipment to ensure proper functions. Process equipment e xamined by these checks include pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Ethox to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Ethox. These reviews are conducted to c onfirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Ethox conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Ethox promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of five years. Employee Participation Ethox believes that process safety management and accident prevention is a team effort. Company employees are encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, employees have access to all information created as part of the facility's implementation to the RMP rule in particular information resulting from process hazard analyses. Contractors On occasion, the company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Ethox has a policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Ethox has had an excellent record of preventing accidental releases over the last 5 years. Due to release prevention policies, no releases of EO have occurred from Ethox in the last five years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage or environmental damage off site. 6. Emergency Response Plan Ethox has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, the emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Greenville County LEPC is the Local Emergency Planning Committee with which the emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of the accidental release prevention program. Ethox is currently in the process of installing a Digital Control System to Ethoxylation and Propoxylation reactor systems. This added layer of hard and soft wired interlocks will greatly increase the safety of operations. These changes are currently being implemented with expected completion by December 1999. |