DuPont Dow Elastomers - Chambers Works - Executive Summary |
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Executive Summary Risk Management Plan (RMP) DuPont Dow Elastomers L.L.C. - Chambers Works Introduction DuPont Dow Elastomers L.L.C. (DuPont Dow) is a global supplier of specialty elastomers with headquarters in Wilmington, Delaware. DuPont Dow is a 50/50 joint venture between certain assets of the E. I. Du Pont de Nemours & Co., Inc. (DuPont) and the Dow Chemical Company (Dow). The joint venture was formed on April 1, 1996, to consolidate the specialty elastomers' resources, production facilities, technical expertise, and business skills from both companies. With approximately 1,500 employees worldwide, DuPont Dow offers a wide variety of specialty elastomers with end-use applications in automotive systems, wire and cable, construction, chemical processing, the general rubber industry, and in high-performance parts with excellent temperature, oil, and chemical resistance. Examples of the end products made with DuPont Dow specialty elastomers include: 7Coatings - from rainwear to li ners for roofs and tanks; 7Automotive products - from power steering pressure hoses to high-performance timing belts; 7Wire and cable insulation - from electrical wiring to power transmission cable; and 7Industrial applications - from protective gloves,O-rings, and gaskets to microwave door enclosures and chemical-resistant hoses. The 1990 Clean Air Act Amendments established a statutory framework for assessing the risks to public health and the environment arising from the use of certain chemicals. Regulations specifying what facilities must conduct these risk assessments, how to assess the risk, and what data to report were promulgated by the U.S. Environmental Protection Agency. These regulations are known as the Risk Management Plan (RMP) rule and are published in Part 68 of Title 40 of the Code of Federal Regulations (40 CFR 68). The DuPont Dow Elastomers Chambers Works facility (facility) must comply with applicable sections of 40 CFR 68. This Executive Summary satisfies the RM P rule section 40 CFR 68.155 requirements by providing a brief overview of the comprehensive risk management activities implemented at the facility. Topics include: 7the facility's accidental release prevention and emergency response policies; 7a facility description and a list of the substances regulated under the RMP rule; 7a summary of the worst-case and the alternative release scenario(s), including administrative controls and mitigation measures; 7the general accidental release prevention program and chemical specific prevention steps; 7a five-year history of the facility's accidental releases of the regulated substance; 7a description of the facility's emergency response program; 7a list of the facility changes planned to improve safety; and 7a legal certification attesting to the truth, accuracy, and completeness of the information submitted by the facility as required by the Risk Management Plan rule. Accidental Release Prevention and Emergency Response Policies The DuPont Dow Chambers Works facility is committed to operating and maintaining its manufacturing processes in a safe and responsible manner. Corporate and facility goals are to prevent all employee injuries, accidental releases and process safety incidents. The facility has both corporate and local programs, procedures and management practices in place to support these goals. Performance against these goals is constantly assessed and communicated to employees. Achievement of these goals is recognized and rewarded. Failure to attain them is regarded as unacceptable performance and treated accordingly. The DuPont Dow Chambers Works facility emergency response policy is to coordinate emergency response activities with DuPont's Chambers Works plant on-site emergency response personnel and fire department. Should an accidental release occur, appropriate emergency response actions would be taken to minimize the impact on employee safety, public health and the environment. Site Identification and Regulat ed Substances The DuPont Dow Chambers Works facility manufactures VITON and KALREZ specialty elastomers that are used in industrial, automotive and aerospace applications. The facility occupies a small portion of DuPont's Chambers Works site located on Route 130 in Deepwater, New Jersey within Salem County. The facility was owned and operated by DuPont prior to the joint venture formation. Because of its DuPont heritage at Chambers Works, DuPont Dow has a broad base of knowledge for, and experience in, handling toxic and flammable substances at the facility in a safe and environmentally responsible manner. The DuPont Dow Chambers Works facility presently has 103 employees. Three of the substances listed under the RMP regulation are handled at the facility. These substances are: Toxics: Hydrogen Chloride - Anhydrous (AHCL) Flammables: Vinylidene Fluoride (VF2) Tetrafluoroethylene (TFE) Worst-case Release Scenario(s) and Alternative Release Scenario(s) The RMP rule requires that the worst-case release scenario(s) and alternative release scenario(s) be communicated to the public for toxic and flammable substances listed in the regulation and present at the facility above a threshold quantity. The EPA defines the worstcase scenario as the hypothetical release of the largest quantity of a regulated chemical in a 10minute period. The worst-case scenario assumes the entire quantity is released, even if it is impossible to do so. Since worst-case scenarios are very improbable, they are not good cases to focus on for emergency response planning with the community. To make emergency response planning more effective, alternative release scenarios are used to provide a more realistic picture of what could actually happen if facility safety systems fail. The scenarios described below were developed using the EPA Offsite Consequence Analysis (OCA) guidance reference tables or equations. Similar scenario analysis and dispersion modeling has also been used for many years as a routine part of the facility Process Safety Management (PSM) practices. The worst-case toxic release scenario is for Hydrogen Chloride. It assumes the release of the entire storage tank contents (43,000 pounds) with no mitigation. This release has an off site impact per EPA OCA guidelines,. This release scenario is unlikely due to the design and construction requirements of the storage tank, and its fitness-for-service inspection program. The first alternative-case release scenario for Hydrogen Chloride is the discharge from pressure relief devices due to excess pressure build up within the storage tank. This scenario assumes approximately 1,000 pounds of HCL is released in a 15 minute period. This release does not have an off site impact per EPA OCA guidelines. Administrative controls and mitigation measures for this scenario include: a storage tank refrigeration system to control tank pressure; control room monitoring of storage tank pressure; storage tank excess pressure alarms; tank refrigeration system failure alarms; storage tank insulation to limit pressure build up rate; controlled venting through a environmental scrubber; and increased process consumption from the tank. The second alternative-case release scenario for Hydrogen Chloride is the discharge from a leak in a tank trailer unloading hose. This scenario assumes approximately 960 pounds of HCL is released in a 30 minute period. This release does not have an off site impact per EPA OCA guidelines. Administrative controls and mitigation measures for this scenario include: requirements for operating personnel to be physically present during tank trailer liquid unloading; leak detection monitors surrounding the unloading area; unloading hose design, construction, and fitness-for-service program; and emergency response planning for this and similar release scenarios. The worst-case flammable release scenario is for Vinylidene Fluoride. It assumes the release of the entire contents (22,000 pounds) of a tube trailer with no mitigation, and the presence of an ignition source. This release does not have an off site impact per EPA OCA guidelines. This scenario is unlikely due to the design, construction and inspection requirements for over-the-road tube trailers. The alternative-case release scenario for Vinylidene Fluoride is the discharge from trailer tube pressure relief device due to excess pressure build up caused by tube overfilling. This scenario assumes 3500 pounds would be released. This release does not have an off site impact per EPA OCA guidelines. Administrative controls and mitigation measures for this scenario include: reduced loading densities during warmer months; procedural trailer pressure monitoring upon arrival and prior to connection for unloading; individual tube isolation until unloading occurs. Accidental Release Prevention Program DuPont Dow has employed the concepts of accidental release prevention and process safety management since its formation. Site pra ctices that incorporate these concepts include the following: 7Thorough understanding of process technology, including the safe limits of the processes and the proper materials of construction for equipment 7Proper design and installation of equipment 7Systematic process hazard reviews to identify and address process hazards 7Written operating and maintenance procedures 7Extensive training for all persons who operate or maintain chemical process equipment 7Mechanical integrity testing for detection of potential equipment problems and preventive maintenance to avoid releases 7Mechanical quality assurance programs to ensure that the correct spare parts are installed whenever maintenance is performed 7Procedures to identify and manage both obvious and subtle changes in technology, equipment, and personnel, that could have an effect on the site's safety and environmental performance 7Pre-startup safety reviews for newly installed or modified equipment 7Compliance audits to ensure that pro cess safety management principles, procedures, and regulations are effective and properly implemented 7Investigation of actual and potential incidents to identify and implement corrective actions 7Participation of all employees in the process safety management system 7Documented safe work practices, including hot work procedures requiring the issuance of hot work permits 7Contractor safety management system to ensure that work done by contractors is performed safely and in compliance with DuPont Dow standards In addition to the practices described above, we have designed our processes to include multiple layers of safeguards. Examples of these include: 7Computer display and control of process parameters; 7Interlocks to automatically shut down processes for certain process deviations; 7HCL monitors in the storage tank area that provide an alarm when a leak is detected; 7Isolation valves which can be operated remotely from the process control system; 7Check valves to prevent cross con tamination of chemicals; 7Camera surveillance of process areas in central control rooms; 7Fire prevention activities like electrical grounding, inerting flammables with nonflammable gases and hot work permitting; and 7The mechanical integrity of the TFE/HCL and VF2 supply lines is verified by periodic visual inspections and by annual thickness measurements. 7Flexible unloading hoses that connect the railcar to the chlorine supply line are replaced annually. 7When hoses are disconnected from the TFE/HCL trailers, the free ends are covered to keep moisture out of the line. Five Year Accident History In the past five years, there were no accidental releases of regulated chemicals from the facility resulting in on-site deaths, injuries, or significant property damage, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. DuPont Dow Elastomers first began operating the Chambers Works facility on April 1, 1996. Prior to that date, D uPont operated the facility. Emergency Response Program In addition to the accidental release prevention effort, the DuPont Dow Chambers Works facility has developed and implemented an emergency response program which includes all the elements necessary to satisfy the federal, state and local regulatory requirements. In the case of a chemical release from the facility, DuPont Dow personnel contact the DuPont Chambers Works on-site emergency response personnel and fire department to coordinate emergency response activities. The DuPont emergency responders are thoroughly trained and properly equipped to respond to releases of any chemical used at Chambers Works. The site also maintains an emergency response brigade comprised of specially trained operators that can lend additional support if necessary. The DuPont Dow Chambers Works facility conducts emergency drills to simulate potential accidental releases and test emergency response plans. Drill critiques are performed to evaluate emergency response plan adequacy and implementation effectiveness. The DuPont Chambers Works site conducts practice drills with the local community and emergency response organizations. Chambers Works also supports a siren system in the local community that would provide early warning for a potential release. This system is coordinated with the Salem County Office of Emergency Response. In addition to these on-site activities, DuPont Chambers Works also maintains transportation emergency response capability to respond to off site chemical transportation incidents. Planned Changes to Improve Safety As part of the facility's process hazards review procedures, all of the processes are thoroughly studied on a periodic basis to identify risk reduction opportunities. All recommendations resulting from the studies conducted to date have been completed. In addition, the following changes are planned to further improve the safety of the DuPont Dow Chambers Works facility: 7Using an upgrade d fabrication and installation code for the as needed replacement of piping in the TFE/HCL system 7Improving preventive maintenance inspections and procedures 7Improving training programs 7Conducting audits to identify any deficiencies in our process safety management systems 7Implementing the use of new DuPont corporate standards for highly hazardous service unloading hose construction and inspection 7Replacing existing TFE/HCL tank trailers with new trailers utilizing the DuPont Anhydrous Hydrogen Chloride Safety Committee state of the art design standards |