The Dow Chemical Company - Executive Summary |
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General Executive Summary for The Dow Chemical Company Dalton, Georgia Site 1. Accidental Release Prevention and Emergency Response Policies We at The Dow Chemical Company; Dalton Georgia Site 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 well-trained personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with The Whitfield County Fire and Sheriff Departments, both of whom we would rely upon for additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled The Dow Dalton f acility manufactures latex and Styrofoam* extruded polystyrene board. This facility is located at 1468 Prosser Drive, S.E., approximately 10 miles south of the town of Dalton, Georgia. The facility has two manufacturing plants on site, one for the production of latex which is shipped off-site for use in the paper and carpet industries, and one for Styrofoam* board which is used predominantly in the construction industry as and insulating material. We have 3 regulated substances present at our facility. These substances include 1,3-Butadiene, Vinylidene chloride [Ethene, 1,1-dichloro-] and Ethyl chloride [Ethane, chloro-]. The regulated substances at our facility are involved in several uses. 1,3-Butadiene and Vinylidene chloride [Ethene, 1,1-dichloro-] are used as raw materials for latex production. Ethyl chloride [Ethane, chloro-] is used in the production of Styrofoam*. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrati ve controls and mitigation measures To evaluate the worst case scenarios, we have used Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance. For alternative release scenario analyses, we have employed the equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Butadiene Storage Tank in the Latex Manufacturing process. The scenario involves the release of 682,500 lb. of 1,3-Butadiene. Passive systems such as dikes have been considered when evaluating this scenario. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.70 miles is obtained corresponding to an endpoint of 1 psi. This will break window glass and cause some structural damage to buildings depending upon the quality of construction. One alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Butadiene Rail Car in the Latex Manufacturing. The scenario involves the release of 150,000 lb. of 1,3-Butadiene in 10 minutes. The release is assumed to result in a Vapor Cloud Explosion. Passive mitigation controls such as dikes are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include sprinkler system(s) and deluge system(s). Under neutral weather conditions the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.19 miles. This distance does not go beyond the Dow fenceline. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Vinylidene Chloride Storage Tank in the Latex Manufacturing. Th e release is assumed to result in a Pool Fire. The scenario involves the release of 429,250 lb. of Vinylidene chloride [Ethene, 1,1-dichloro-] in 10 minutes. Passive mitigation controls such as dikes are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include sprinkler system(s). Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 for 40 seconds is 0.01 miles. This distance does not go beyond the Dow fenceline. Styrofoam* Manufacturing classifies as a Program 3 process. The worst case scenario considered for this process involves a flammable substance, namely Ethyl chloride [Ethane, chloro-]. The quantity released in the scenario is assumed to be 252,000 lb. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Passive mitigation considered in the sc enario includes dikes. Under worst case weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.38 miles. 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. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. We also have an air operating permit ID under Title V of the Clean Air Act. Our facility has received a Star/Merit Ranking under OSHA's Voluntary Protection Program. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information The Dow Chemical Company; Dalton Georgia Site maintains a detailed record of safety information that d escribes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis The Dalton facility has an active Process Hazard Analysis program to identify, evaluate, and control the hazards of the processes. Plant management is also responsible for the documentation and follow-up of action items from these reviews. The Dow Environmental, Health and Safety (EH&S) Requirements specify that risk assessment or analysis be used to evaluate hazard potentials of all installations. Dow Hazard Analysis programs were instituted and operational many years prior to the issue of RMP. In particular, the programs listed below constitute the Dow interpretation of a Process Hazard Analysis: * Reactive Chemical Review * Fire & Explosion Index (F&EI) * Chemical Exposure Index (CEI) * Process Hazard Analysis Checklist These studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are reval idated at a regular interval. Any findings are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, The Dow Chemical Company; Dalton Georgia Site 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 The Dow Chemical Company; Dalton Georgia Site has a comprehensive training program in place to ensure that employees who are operating processes or newly assigned to the process are competent in the operating procedures associated with these processes. Refresher training is provided every three years and more frequently as needed. Mechanical Integrity The Dow Chemical Company; Dalton Georgia Site carries out a highly documented Planned Preventative Maintenance Program (PPM) which provides 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 and compressors. 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 The Dow Chemical Dalton facilities require management of all modifications to process equipment, procedures, raw materials and processing conditions other than "like for like", by identifying and reviewing them prior to implementation of changes. Process operators, maintenance personnel or any other employee whose job tasks are a ffected 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 The Dow Chemical Company; Dalton Georgia Site. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits The Dow Chemical Company; Dalton Georgia Site 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 The Dow Chemical Company; Dalton Georgia Site promptly investigates any incident that has resulted in, or could reas onably 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 The Dow Chemical Company; Dalton Georgia Site 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. 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. The Dow Chemical Company; Dalton Georgia Site 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. 5. Five-year Accident History The Dow Chemical Company; Dalton Georgia Site has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there have been no accidental releases as defined by the RMP rule of regulated substances, during this period. 6. Emergency Response Plan The Dow Chemical Company; Dalton Georgia Site 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. 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. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Behavior-based safety training is one of the major steps we plan to implement to improve safety at our facility. Implementation of these changes is expected by December 31, 1999. 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: Rick Emerson Signature: Title: Responsible Care Leader Date Signed: TDCC Page 6 May 1999 |