Witco Corporation Harahan Louisiana Plant - Executive Summary

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Witco Corporation 
 
Harahan Plant 
 
RISK MANAGEMENT PLAN - EXECUTIVE SUMMARY 
 
1.    Introduction 
 
Witco Corporation is committed to operating in a manner that is safe for our employees, contractors, the public and the environment.  As part of this commitment, Witco Corporation has established a system to help ensure the safe operation of chemical processes at this facility.  One part of this system is a risk management program (RMP) that is required by the USEPA's Accidental Release Prevention Requirements (RMP Rule) in Title 40 of the Code of Federal Regulations Part 68. One of the requirements of the RMP Rule is to submit a Risk Management Plan (RMP Plan), which describes the risk management programs at the facility for review by the USEPA and the public. 
 
2. Accidental Release Prevention and Emergency Response Policies 
 
Witco Corporation is committed to the safety of its employees, contractors, the public and the environment through the prevention of accidental releases of hazardous subs 
tances. In the unlikely event of a significant accidental release our personnel will respond to control and contain the releases.  In most foreseeable circumstances releases could be controlled by shutting down operations and/or by applying generous quantities of water to absorb and dilute the release since all of the regulated chemicals are water soluble. If necessary, Witco will evacuate onsite personnel and contact the local emergency planning committee (LEPC), fire department and police to help handle the emergency and to help warn the public. 
 
3. Facility Description and Regulated Substance Handled 
 
The Harahan Plant stores regulated substances for use in two chemical processes. In each process the regulated substances are chemically transformed into less hazardous products. The oxylation processes make products that are used as ingredients in detergents for laundry and personal care, and additives used in the agricultural and petroleum industries. 
 
The following is a list of the  
regulated chemicals handled in each process and the largest amount of each chemical stored in a single container: 
 
Process        Regulated Substances    Largest Container 
 
Oxylation        Ethylene Oxide         25,600 gallons 
           Propylene Oxide        13,000 gallons 
 
 
 
 
4.    Offsite Consequence Analysis 
 
Witco performed an offsite consequence analysis (OCA) to estimate the potential impact on the public environment if an accidental release of a regulated substance to affect the public or the environment.  The OCA consists of evaluating both the worst case release scenario and an alternative release scenario for releases of regulated substances.  The worst case scenario is not expected to occur over the life of the facility.  An alternative release scenario represents a release that might be a reasonable scenario to consider for emergency planning purposes. 
 
The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public if an accidental release should hap 
pen. This distance is called the endpoint.  
 
4.1    Worst Case Toxic Release Scenario 
 
The worst case release scenario for Ethylene Oxide is the release of the entire contents from a 25,600 gallon railcar in 10 minutes, which is the worst case scenario defined by the USEPA. The maximum distance to the toxic endpoint concentration is approximately 9.9 miles.  The population within this 9.9-mile radius of the plant is approximately 669,000 people. 
 
The USEPA models were used to determine the distance to the toxic endpoint. 
 
4.2    Alternative Toxic Release Scenarios 
 
The alternative release scenarios for all of the toxic substances were assumed to be leaks with no steps taken to mitigate the release. Water sprays onto leaks should be highly effective in knocking down vapors to reduce the impact of the leak since all of the regulated chemicals are water-soluble. 
 
For ethylene oxide, the distance to the toxic endpoint would be 0.3 miles.  There are not any residences, but there are other industr 
ial and commercial neighbors within the 0.3-mile radius. 
 
For propylene oxide the distance to the toxic endpoint would be 0.1 miles.  There are no residences, but there are other industrial and commercial neighbors within the 0.1-mile radius.   
 
4.3    Worst Case Flammable Release Scenario 
 
The worst case scenario for a regulated flammable substance is not required as there is not sufficient quantities to present to exceed any thresholds.  
 
 
 
4.4    Alternative Flammable Release Scenario 
 
The alternative case scenario for a regulated flammable substance is not required as there is not sufficient quantities to present to exceed any thresholds.  
 
Ethylene oxide and propylene oxide are flammable in addition to being toxic and Witco is taking precautions to manage the fire and explosion risks of these substances as well as the toxicity hazards. 
 
5.    General Accidental Release Prevention Program and Chemical Specific Prevention Steps 
 
The following is a summary of the general accident prevention p 
rogram in place at Witco Harahan Plant: 
 
5.1    Employee participation 
 
Witco encourages and insists upon employee participation in process safety management.  Knowledgeable operators write operating procedures, review new or modified product recipes, and are included in process hazard analyses.  Employees attend safety meetings, which are held about 6 times per month to provide ample opportunities for employees to attend. All meetings throughout the company (other than safety meetings) must begin with a safety topic to increase safety awareness and employee involvement. Several operators have been pulled off of regular duties for extended periods to review and comment on new designs and to help train themselves and others on major process changes before implementation.  
 
5.2    Process Safety Information 
 
The Plant maintains extensive information on its chemical hazards, processes, procedures and equipment, which is used by employees as needed to help them do their jobs safely.  
 
5.3    Proces 
s Hazard Analysis 
 
New and existing processes are examined using formalized methods of hazard analysis.  These methods are designed to help knowledgeable employees recognize process hazards. Recommended actions are tracked until resolution. 
 
5.4    Operating Procedures 
 
The Harahan Plant maintains written procedures that address various modes of operation for the regulated processes, including normal operations as well as emergency and abnormal operations.  Operating procedures are available from document control department and control rooms where operators work. 
 
 
5.5    Training 
 
Safety training is conducted monthly and the topics change each month. Process safety topics are covered during several months of the year.  Initial training is provided to new employees.  Experienced operators train new employees on the proper operating procedures until they believe from direct observation that the newer employee is ready to run the process. Refresher training is conducted periodically. 
 
5.6    Cont 
ractors 
 
The Harahan Plant uses contractors to supplement its work force during periods of increased construction or maintenance activities.  Contractor's safety performance is reviewed before hiring the contractors.  Contractors are given safety training prior to being allowed to work in the plant to help assure that our safety procedures are followed. A permit system is in place, which requires contractors to obtain written approval in the form of a work permit from knowledgeable Plant personnel before work by a contractor commences on a regulated process.  Contractors are informed of the process hazards before written approval to commence work is given. 
 
5.7    Pre-startup safety review (PSSR) 
 
The facility conducts a PSSR before any new or modified process is operated to make sure that the new or modified facilities and the associated procedures are safe to use for operation.  
 
5.8    Mechanical Integrity 
 
The facility has an ongoing system to maintain the process equipment in good worki 
ng order as needed for safe operation. The facility has procedures in place for the testing and inspection of equipment and makes sure that equipment is operated within the safe operating limits. New equipment and installations are inspected before they are operated to make sure they were constructed properly and are safe to operate. Equipment containing regulated toxic or regulated flammable substances are given the highest priority in the mechanical integrity system. 
 
5.9    Safe Work Practices 
 
The facility has training programs and permit systems in place to make sure that hazardous activities such as hot work, lockout/tagout, entering vessels and confined spaces, and opening pipelines are performed safely by requiring that knowledgeable persons from operations and maintenance provide written permission before such work can be performed.  
 
 
 
 
 
5.10    Management of Change 
 
The facility has procedures in place to manage changes to procedures and equipment safely.  Operations and engineeri 
ng management personnel assure that changes are not authorized until it is safe to do so and the necessary safety requirements are met. 
 
5.11    Incident Investigation 
 
The facility has procedures in place that require the reporting and investigation of incidents that result in or could reasonably resulted in a fire explosion or toxic release. Any urgent  recommendations resulting from the incident investigation are addressed promptly and other recommendations are tracked until they are resolved.  A file is maintained to record the incident history for review and for consideration in the next process hazard analysis. 
 
5.12    Audits 
 
Audits are conducted every 3 years by the Corporate Safety, Health and Environmental Departments and reports are written to which the facility must respond.  The status of recommendations is tracked until resolution. 
 
6. Chemical Specific Prevention Steps 
 
The hazards of the processes operated at the facility are managed safely with the help of the programs prev 
iously described. The following is a description of chemical specific accident prevention steps: 
 
6.1    Ethylene Oxide and Propylene Oxide 
 
Witco Corporation has had a special safety committee for oxylation safety since the 1970s.  This committee has met regularly to discuss ways to improve oxylation safety.  Members from several operating units and corporate safety personnel participate in the committee meetings.  
 
The ethylene oxide and propylene oxide suppliers have well developed product stewardship programs and periodically visit the site to provide assistance in the safe handling of oxides and special training materials are provided. 
 
Process controls now in place include numerous sensors, alarms and interlocks to detect and prevent hazardous upset conditions. Automatic shut off valves prevent the oxide from being added unless the process conditions are safe. Leak sensors provide alarms if leaks are detected and deluge systems are provided for tank unloading area to absorb leaks.   
Dikes are provided for the storage tanks to contain spills and leaks.  All of the vessels are protected with self-closing relief valves and all of the vessels are maintained under an inert atmosphere.  
 
 
7. Five Year Accident History 
 
The Witco Harahan Plant has not had any releases that have resulted in deaths, injuries or significant property damage on site or known offsite injuries, evacuations or sheltering in place or environmental damage. 
 
8. Emergency Response Program 
 
The facility has a written emergency response plan.  The emergency response plan was submitted to the Jefferson Parish Department of Emergency Management (LEPC).  The plant periodically conducts drills to train personnel and to test the plan.  
 
9. Planned Changes to Improve Safety 
 
The Harahan facility continues to evaluate and employ safe work practices in all aspects of its operations, making changes in policies and procedures when required to maintain a safe and healthy workplace. 
 
The existing facilities, alth 
ough they have operated safely for about 30 years, will be taken out of oxylation service after the new facilities at the Houston Plant are fully operational and have ramped up on the learning curve sufficient to meet customer demands. Safety improvement was a major justification for this large project since existing units at this location currently provide most of the production capacity of the new units.
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