Great Lakes Chemical Newport Plant - Executive Summary |
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Risk Management Plan Executive Summary for The Great Lakes Chemical Newport Plant Newport Tennessee 1. Accidental Release Prevention and Emergency Response Policies We at Great Lakes Chemical Newport Plant are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Newport/Cocke County Emergency Management which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facil ity's primary activities encompass organic chemical synthesis. We have six regulated substances present at our facility. These substances include bromine, hydrazine, phosphorous oxychloride [phosphoryl chloride], phosgene [carbonic dichloride], propylene oxide [oxirane, methyl-], and sulfur dioxide (anhydrous). The regulated substances at our facility are used for chemical synthesis. 3. The Worst Case Release Scenario and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required off-site consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Off-site Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from the Vydate process. The scenario involves the r elease of 4000 lb. of phosgene [carbonic dichloride] in a gaseous form over 10 minutes. Passive mitigation controls such as enclosures are also taken into account to calculate the scenario. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 22 miles is obtained corresponding to a toxic endpoint of 0.00081 mg/L. One alternative release scenario has been submitted for each toxic substance present in Program 3 processes cumulatively. The alternative release scenario for phosgene [carbonic dichloride] involves a release from the phosgene storage area in the Vydate process. The scenario involves the release of 10 lb. of phosgene [carbonic dichloride] in a gaseous form over 10 minutes. Passive mitigation controls such as enclosures are taken into account to calculate the scenario. The release from the phosgene storage cylinder would be sited inside the enclosure, which is a building vented under vacuum to two large caustic scrubbers to destroy phosgene. Other active mitigation measures are the implementation of emergency shutdown procedures and the application of emergency capping kits to stop the release by emergency personnel. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.00081 mg/L of phosgene [carbonic dichloride] is 0.44 mile. The alternative release scenario for bromine involves a release from the bromine storage area in the PE-68 and the DBB processes. The scenario involves the release of 10 lb. of bromine. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 11.53 minutes. Passive mitigation controls such as dikes are taken into account to calculate the scenario. The release is also assumed to be controlled by active mitigation measures that include a sprinkler system, water blanket and neutralization. Under neutral weather conditions, the maximum distance to the toxi c endpoint of 0.0065 mg/L of bromine is 0.10 mile. The alternative release scenario for hydrazine involves a release from the hydrazine storage area in the PE-68 and the DBB processes. The scenario involves the release of 169 lb. of hydrazine. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 256.32 minutes. Passive mitigation controls such as enclosures are taken into account to calculate the scenario. The release is also assumed to be controlled by the active mitigation measure of neutralization. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.011 mg/L of hydrazine is 0.09 mile. The alternative release scenario for phosphorous oxychloride [phosphoryl chloride] involves a release from the phosphorous oxychloride storage area in the NH-1197 process. The scenario involves the release of 4000 lb. of phosphorous oxychloride. Toxic liquid is assumed to be released from a pool at one pound per minute evaporation rate. Passive mitigation controls such as dikes are taken into account to calculate the scenario. Active mitigation measures such as operator intervention and process controls are taken into account. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0030 mg/L of phosphorous oxychloride [phosphoryl chloride] is 0.22 mile. The alternative release scenario for propylene oxide [oxirane, methyl-] involves a release from the propylene oxide storage area in the PE-68 process. The scenario involves the release of 100 lb. of propylene oxide [oxirane, methyl-]. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 5.53 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.59 mg/L of propylene oxide [oxirane, methyl-] is <0.06 mile. The alternative release scenario for sulfur dioxide involves a release from the sulfur dioxide storage area in the Stadis process. The scenario involves the release of 10 lb. of Sulfur dioxide in a gaseous form over 10 minutes. The release is also assumed to be controlled by active mitigation measures such as implementation of emergency shutdown procedures and the application of emergency capping kits to stop the release by emergency personnel. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of sulfur dioxide is 0.1mile. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our 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 state building codes. A number of processes at our facility are subject to the OSHA PSM standard unde r 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. We also have an air operating permit under Title V of the Clean Air Act. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Great Lakes Chemical Newport Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses are HAZOPs and what if checklists. 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 five years. Any findings related to the hazard analysis are a ddressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Great Lakes Chemical Newport Plant 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 in the processes. Training Great Lakes Chemical Newport Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training for process operations is provided at least every three years and more frequently as needed. Emergency response refresher training is done annually in accordance to OSHA HAZWOPER 1910.120 and includes tabletop, field limited, and full scale simulated HAZMAT drills with the community. Mechanical Integrity Great Lakes Chemical Newport Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; 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 Great Lakes Chemical Newport Plant 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 m ade aware of and re-trained 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 Great Lakes Chemical Newport Plant. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Process operators are provided refresher training before start-up of any new process or re-start of existing process Compliance Audits Great Lakes Chemical Newport Plant 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 Great Lakes Chemical Newport Plant 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 5 years. Employee Participation Great Lakes Chemical Newport Plant truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Training employees for the worst case and alternate case scenarios have been conducted historically every year during annual refresher training and will continue. Contractors On occasion, our 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. Great Lakes Chemical Newport Plant has a strict 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. Contractors participate in our annual hazmat drills. 5. Five-year Accident History Great Lakes Chemical Newport Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, the number of accidental releases has been reduced to a minimum. There have been 4 accidental releases of regulated substances reportable under 40 CFR 68 from our facility within the last 5 years. The first release took place on 06/10/94 and involved 0.1 lb. of bromine. The incident was a result of equipment failure. No deaths or injuries occurred off-site as a result of this accident. On-site, there were 2 injuries. There was some on-site property damage. Another release, of 2 lb. of bromine, occurred on 11/30/94 due to equipment failure. No deaths or injuries occurred off-site as a result of this accident. On-site, there was 1 injury. Another release, of 5 lb. of bromine, occurred on 03/18/95 due to equipment failure. No deaths or injuries occurred off-site as a result of this accident. On-site, there was 1 injury. There was some onsite property damage. Another release where 475 lb. Of phosphorous oxychloride was released to the air occurred on 09/11/95 due to equipment failure. Due to this accident, one person off-site received medical treatment. Several evacuations were issued. On-site, there were thirteen injuries. There was some property damage on-site. 6. Emergency Response Plan Great Lakes Chemical Newport Plant carries 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. Included are specific procedures for RMP regulated chemicals.. To ensure proper functioning, our 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. The Cocke County Emergency Management Agency (EMA) director has been issued a copy of the Contingency Plan and been reviewed on the key elements. The EMA director works closely with the Cocke County Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safe ty Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The Great Lakes Chemical Newport Plant plans to continuously improve and update operating procedures, replace or maintain equipment to original specifications or design codes and develop and implement safety improvement capital projects. These are some of the major steps we have taken to improve safety at our facility: An additional water monitor (cannon) was installed before startup of the DBB process in Building 21 This addition was determined during a table top drill performed before the startup of the process and affords improved control of bromine vapor in the event of a release. A water "blanket" is maintained in the secondary concrete dikes which contain the bromine storage tanks. A bromine release will sink through the water layer and evaporation will be greatly minimized. At the Vydate process, a building was constructed arou nd the cylinders of phosgene which are piped to the process vessels. Scrubbers were installed over 100 times the size needed for routine emissions to capture and destroy the release. These changes have been implemented by 12/31/98. As part of planning for any additional RMP regulated chemicals that are not currently stored at the Newport Plant, Great Lakes Chemical Corporation will conducted detailed examination of new processes to include passive mitigation structures and measures to minimize or stop releases. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Alan Doty Signature:_____________________________ Title: Plant Manager Date signed:___________________________ Name: Michael A. Ponzio Signature:_____________________________ Title: Environmental Mgr / RMP Coordinator Date signed:_____________ ______________ |