Nalco Chemical Company - Executive Summary |
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1.0 Accidental Release Prevention and Emergency Response Policies At Nalco Chemical Company's Garyville facility, 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 regulation A summary of results from our assessment of the potential off site 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 emergency 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 The certifications that EPA's RMP rule requires us to provide 2.0 Stationary Source and Regulated Substances Our facility produces a wide variety of specialty chemicals using a variety of chemicals and processing operations. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release: Toxics Acrylonitrile Ammonia Epichlorohydrin Flammables Dimethylamine 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. 3.0 Key Offsite Consequence Analysis Scenarios EPA's RMP rule requires that w e provide information about the worst-case release scenarios 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 Ammonia The worst case scenario involves failure of the storage tank containing 58,000 pounds of ammonia. Using the weather conditions specified by USEPA (10 minute release, Class F stability, 25 degrees C, 1.5 meters per second wind), the OCA Guidance estimates that the ammonia could travel 3.6 miles before dispersing enough to no longer pose a significant hazard to the public. Within the potentially affected area are: one school (Garyville Mt. Airy Math and Science Magnet School); the communities of Garyville, Mt. Airy and Wallace (total affected population - 3,100); and several industrial facilities (Stockhausen, Marathon - A shland, LaRoche, Kaiser, CII, and Epsilon). No active mitigation measures are allowed to be considered under this scenario. Alternative Release Scenarios Regulated Toxic Chemicals Ammonia The alternative case scenario involves failure of an unloading hose releasing 500 pounds of ammonia. Using typical weather conditions specified by USEPA ( Class D stability, 25 degrees C, 3.0 meters per second wind), the OCA Guidance estimates that the ammonia could travel 0.3 miles before dispersing enough to no longer pose a significant hazard to the public. Within the potentially affected area are portions of the community of Mt. Airy (total affected population - 20) and one industrial facility (Stockhausen). Active mitigation measures considered under this scenario include the excess flow valves installed in the ammonia transfer piping system. Acrylonitrile The alternative case scenario involves failure of an unloading hose releasing 8,310 pounds of acrylonitrile. Using typical weath er conditions specified by USEPA ( Class D stability, 25 degrees C, 3.0 meters per second wind), the OCA Guidance estimates that the acrylonitrile could travel 0.5 miles before dispersing enough to no longer pose a significant hazard to the public. Within the potentially affected area are: one school (Garyville Mt. Airy Math and Science Magnet School); portions of the community of Mt. Airy (total affected population - 50); and one industrial facility (Stockhausen). Active mitigation measures considered under this scenario include the automated shutoff valves installed in the acrylonitrile transfer piping system; passive mitigation measures considered under this scenario include the drains and sump under the unloading area. Epichlorohydrin The alternative case scenario involves failure of an unloading hose releasing 7,300 pounds of epichlorohydrin. Using typical weather conditions specified by USEPA ( Class D stability, 25 degrees C, 3.0 meters per second wind), the OCA Guidance e stimates that the epichlorohydrin could travel 0.2 miles before dispersing enough to no longer pose a significant hazard to the public. Within the potentially affected area is one industrial facility (Stockhausen). Active mitigation measures considered under this scenario include the automated shutoff valves installed in the epichlorohydrin transfer piping system; passive mitigation measures considered under this scenario include the drains and sump under the unloading area. Worst-case Release Scenario Regulated Flammable Chemicals Dimethylamine The worst case scenario involves failure of the storage tank containing 162,000 pounds of dimethylamine. The OCA Guidance estimates that, if the release were to result in a vapor cloud explosion, it would affect the area within 0.4 miles of the tank. Within the potentially affected area are: one school (Garyville Mt. Airy Math and Science Magnet School); portions of the community of Mt. Airy (total affected population - 30); and on e industrial facility (Stockhausen). No active mitigation measures are allowed to be considered under this scenario. Alternative Release Scenario Regulated Flammable Chemicals Dimethylamine The alternative case scenario involves failure of an unloading hose releasing 7,400 pounds of dimethylamine. The OCA Guidance estimates that, if the release were to result in a vapor cloud explosion, it would affect an area within 0.06 miles of the tank. This area would be contained within the confines of the Nalco facility. Active mitigation measures considered under this scenario include the automatic shut off valves installed within the dimethylamine piping system. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 4.0 General Accidental Release Prevention Program and Chemical-Specific 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 Training Mechanical integrity Management of change Pre-startup review Compliance audits Incident investigation Employee participation Hot work permit Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Installation of deluge systems around storage tanks containing acrylonitrile and dimethylamine; Installation of deluge systems around unloading areas handling epichlorohydrin and dimethylamine; Installation of chemical specific sensors controlling automatic shutoff valves in the acrylonitrile, dimethylamine and epichlorohydrin unloading areas; Installation of chemical specific sensors to detect leaks in the acrylonitrile, ammonia, dimethylamine and epichlorohydrin storage and processing areas; A preve ntive maintenance program to inspect all chemical hoses used in the plant. These inspections include the transfer hoses used for unloading acrylonitrile, ammonia, dimethylamine and epichlorohydrin. Written procedures to address unloading, leak detection and spill reporting in the acrylonitrile, ammonia, dimethylamine and epichlorohydrin unloading and storage areas. 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 our own high standards for accident prevention. 5.0 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: There have been no accidental chemical releases involving these materials above their Regulated Quantity (RQ) at our facility in the last five years. There have been several small releases of dimethylamine. None of these resulted in injuries to employees, nor did any affect the community or environment. After each of these incidents, we conducted formal incident investigations to identify and correct the root causes of the event. None of these incidents met the requirements to be reported under EPA's RMP. 6.0 Emergency Response Plan We maintain a contingency 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 response plan. 7.0 Planned Changes to Improve Safety The following is a li st of improvements that we are considering at the facility to help prevent and/or better respond to accidental chemical releases: 1) Include specific emergency instructions in the D/3 computer "notebook" used to control production processes; 2) Purchase drain covers to improve spill control within the plant drainage system; 3) Train and equip the existing plant HAZMAT team to perform air monitoring in the surrounding community during a release; 4) Convert existing Emergency Plans to an Integrated Contingency Plan; 5) Upgrade/develop facility maps for fire systems; evacuation, drainage and equipment locations. 8.0 Certifications For all covered processes, the undersigned also certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RMPlan is true, accurate, and complete. Guy E. Blackmar II Plant Manager June 11, 1999 |