West Oak Plant - Executive Summary

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Executive Summary - Vinings Industries, Inc. 
Plant: Marietta (West Oak), GA 
 
Vinings Industries is a chemical manufacturing company based in Atlanta, GA. Specialty chemicals are produced for several diverse industries including paper manufacturing, pigment mining, textile sizing, paint manufacturing, water treatment and agricultural pest control.  
 
The West Oak facility manufactures products for paper, pigment mining, water treatment and agricultural markets. Plant II, the portion of the plant covered by Risk Management, makes several dithiocarbamate products that are sold to other chemical companies for use in paper manufacturing, pigment mining, agricultural pest control, and water treatment applications. The West Oak plant consists of two operating portions: one portion is covered by OSHA's PSM and EPA's RMP, the other is not. OSHA regulations (Process Safety Management) for several years have required that multiple Layers of Protection be included during design, before startup and  
to continue through operations and training of all employees. These Layers of Protection today are part of our Risk Management Programs. 
 
The West Oak plant uses six materials that are covered under Risk Management:  chlorine, ethylenediamine, carbon disulfide, formaldehyde, methylamine and dimethylamine. EPA lists chlorine, carbon disulfide, ethylenediamine, and formaldehyde as Toxics; methylamine and dimethylamine are listed as flammables. Chlorine is used at West Oak in the pretreatment of waste water prior to a permitted discharge to the Cobb County system. The other materials are used in the production of several different dithiocarbamate products. 
 
Chlorine: 
Yellow-green gas with a bleach-like odor 
The vapor is heavier than air 
Exposure can be irritating to the eyes and throat 
Contact with the skin can cause dermatitis or blistering 
Inhalation can cause the excessive production of mucus and liquid in the lungs 
Prolonged exposure to high concentrations may be fatal 
 
Carbon disulfi 
de: 
   Clear, colorless liquid with a garlic-like odor 
   Flammable in liquid and vapor form 
   Direct contact to skin and eyes will cause irritation.  
   Liquid contact to eyes can result in severe pain.  
   Inhalation of fumes can cause nausea, vomiting and headaches. 
   Prolonged exposure to high concentrations may be fatal 
 
Methylamine: 
   Colorless, flammable liquid with a fishy odor.  
As a liquid  methylamine is much lighter than water  
As a vapor methylamine is slightly heavier than air. 
   Contact with the eyes can result in severe pain and irritation.  
   Contact with the skin can cause burns or blistering. 
   Inhalation of fumes can cause nausea, vomiting and headaches. 
   Prolonged exposure to high concentrations may be fatal 
 
Dimethylamine: 
   Colorless, flammable Liquid with a fishy or ammonia odor 
   As a liquid dimethylamine is lighter than water  
As a vapor dimethylamine is heavier than air 
   Liquid contact with the eyes can result in severe pain and corneal injury.  
   Contact with the skin can ca 
use dermatitis or blistering 
   Inhalation of fumes can cause nausea, vomiting and headaches 
   Prolonged exposure to high concentrations may be fatal 
 
Ethylenediamine: 
   Colorless flammable liquid with a ammonia-like odor 
   As a liquid Ethylenediamine is lighter than water  
As a vapor Ethylenediamine is heavier than air 
Exposure to vapors can be irritating to the eyes and throat 
Liquid contact with the eyes can result in severe pain and irritation 
Contact with the skin can cause chemical burns or blistering 
Inhalation of fumes can cause nausea, vomiting and headaches 
   Prolonged exposure to high concentrations may be fatal 
 
Formaldehyde: 
   Colorless, flammable liquid with a pungent odor 
As a liquid formaldehyde is slightly heavier than water 
As a vapor formaldehyde is slightly heavier than air 
Exposure can be irritating to the skin, eyes and throat and can cause skin and lung allergies 
Contact can cause skin and eye burns 
Inhalation can cause asthma-like allergies and the potential for nasal  
cancer 
Prolonged exposure to high concentrations may be fatal 
 
As part of Vinings' stewardship and safety programs, we recognize that the amines are toxic and that formaldehyde and carbon disulfide are flammable. The design of storage and handling systems take both hazards of each material into consideration. All raw materials handling, from rail car unloading, through storage, reaction, storage and loading of finished product into shipping containers, is closed during normal operating conditions. Venting, when required, is routed through scrubbers designed to minimize emissions to the atmosphere.  
 
Chlorine is added directly to waste water to destroy residual dithiocarbamates in the waste water treatment system. It is used separately from raw materials in a building with sensors designed to detect any loss of material. 
 
Offsite Consequence Analysis:  
Worst Case Scenario - Toxic Chemical (ID#3) -  Analysis of our processes showed the Worst Case Scenario (Toxic) to be the sudden and com 
plete release of three full cylinders (6,000 pounds) of chlorine hooked to a common header. Based on EPA's Offsite Guidance, we estimate chlorine would travel approximately 2.3 miles. This distance is based on the assumption of urban terrain. Within the larger affected area, a population of 23,000 would potentially be affected, including residences, schools, hospitals, recreation areas and commercial and industrial facilities. 
 
Worst Case Scenario - Flammable (ID#2)- Analysis of our processes showed the Worst Case Scenario (Flammable) to be a tank leak discharging 36,000 pounds of methylamine into an uncontained area. Based on EPA's Offsite Guidance, we estimate the evaporated methylamine would explode and the distance to a 1 psi over pressure would be approximately 0.25 miles. Within these areas, a population of 111 would potentially be affected, including residences and commercial and industrial facilities.  
 
Alternative Scenarios:  While the alternative scenarios are still unlikely 
to occur, they are more likely to happen than are Worst Case Scenarios. In these scenarios, we can presume our Layers of Protection, our safety processes, our safety programs, our safety equipment and our people will be available and used. While these scenarios are more likely to happen than the Worse Case, and these are the scenarios that we use for Emergency Planning, our safety systems are designed to prevent them from happening. 
 
Alternative Case Scenario - Toxic (ID#4) - Analysis of our systems indicate that a more likely toxic scenario would be the loss of 1,500 pounds of ethylenediamine over 10 minutes from a one-inch pipe discharging into an uncontained area. Using EPA's Offsite Guidance, we estimate ethylenediamine would travel 0.10 miles before the concentration dispersed to a level considered by EPA to be non-hazardous. Within these areas, a population of 18 would potentially be affected, including residences and commercial and industrial facilities. 
 
Alternative Case Scena 
rio - Toxic (ID#5) - Analysis of our systems indicate that a more likely toxic scenario would be the continuous venting of 95,000 pounds over 60 minutes from the relief valve failure on the carbon disulfide tank. In this case, the storage tank is surrounded by concrete dike containment. The lost material would empty into the secondary containment, limiting the surface area from which carbon disulfide could evaporate.  Using EPA's Offsite Guidance, we estimate carbon disulfide would travel 1.10 miles before the concentration dispersed to a level considered by EPA to be non-hazardous. Within these areas, a population of 4,300 would potentially be affected, including residences and commercial and industrial facilities. 
 
Alternative Case Scenario - Toxic (ID#6) - Analysis of our systems indicate that a more likely toxic scenario wold be the loss of one 2,000 pound cylinder of chlorine when the thermal relief plugs blow due to over pressurization from a fire. Using EPA's Offsite Guidance, w 
e estimate chlorine would travel 0.6 miles before the concentration dispersed to a level considered by EPA to be non-hazardous. Within these areas, a population of 1,200 would potentially be affected, including residences and commercial and industrial facilities. 
 
Alternative Case Scenario - Toxic (ID#7) - Analysis of our systems indicate that a more likely toxic scenario would be the loss of 26,000 pounds of formaldehyde over 10 minutes from a two-inch hole in a tank, discharging into an uncontained area. Using EPA's Offsite Guidance, we estimate formaldehyde would travel 0.20 miles before the concentration dispersed to a level considered by EPA to be non-hazardous. Within these areas, a population of 71 would potentially be affected, including residences and commercial and industrial facilities. 
 
Alternative Case Scenario - Flammable (ID#2) - Analysis of our systems indicate that the more likely flammable scenario would be the release of 11,000 pounds of dimethylamine from a two-inch 
hole in a tank, discharging into an uncontained area. Based on EPA's Offsite Guidance, we estimate the evaporated dimethylamine would explode and the distance to a 1 psi over pressure would be approximately 0.07 miles. Within these areas, a population of 9 would potentially be affected, including residences and commercial and industrial facilities.  
 
Accident history: In the past five years, this facility has had no incidents with RMP regulated materials causing an offsite consequence. We have had one incident with onsite consequences that meet RMP reporting requirements. On August 26, 1996, heat from a welding operation ignited what we believe was methylamine vapors in a process water tank, rupturing the vessel and injuring a contract employee. Following the incident, hot work procedures and the related training programs for both employees and contractors were reviewed and emphasized. We have experienced occasions when citizens have reported objectionable odors coming from the plant. 
We believe these odors to be from materials not regulated under RMP. Regardless, we have an obligation to determine the source(s) of these odors and to take actions to prevent a recurrence.  
 
The goal at Vinings is to produce quality products and to produce them safely. We have systems in place to prevent accidents, to safeguard our employees, our community and our environment. Following is a partial listing of our Layers of Protection that we employ in our everyday activities. 
 
Design: All of our valve systems are designed to fail-safe. This means that in the event of the loss of electrical or air power, valves will return - open or closed as necessary - to the "safe" position. We have concrete dikes (secondary containment) to catch spilled materials. 
 
On a regular schedule, we are required to complete a comprehensive review of the hazards and operability of our entire production system. If we find a valve, pipe, tank or pump that might fail and allow a release or an incident, we wil 
l correct it.   
 
Maintenance: We have a documented maintenance program in place. Our operators will recheck equipment before operating it, after maintenance has been performed on it. Using a combination of safety and quality programs, all of our instruments are calibrated and our storage and transfer systems are tested on a regular basis. 
 
Safe Operations: Our employees are essential to the safe operation of our plant. Their training, their experience, their observations and their knowledge of how to respond to situations is the basis of safe operations. These people apply their knowledge and training in their everyday actions. All activities in Plant II - from unloading railcars to filling trucks and railcars with finished products - are restricted to trained, designated employees. 
 
The equipment and systems that contain raw materials are closed; that is, the materials are contained in equipment that is designed to prevent any materials from reaching the atmosphere or environment.  Th 
is extends from the time we unload a railcar or tank truck of raw materials, move them through storage tanks to the processing vessels, on to finished product storage tanks and loading finished products into containers for shipment. All relief venting is carefully controlled through scrubbers or chemical cleaners that are designed to capture and significantly reduce emissions.  
 
Auditing: The Vinings Quality System at West Oak is certified according to ISO 9002 guidelines. While directed at quality, the training and documentation requirements of ISO standards are quite similar to those for OSHA and EPA under Process Safety Management and Risk Management. 
 
In addition to the audits required by all three of these guidelines, we are regularly visited, inspected and/or audited by regulatory agencies.  
 
Emergency Response: Our operators are trained to identify unusual occurrences. In the event of an incident on the plant site, our Emergency Response Plan tells us to take the following actio 
ns: 
   A public address system will notify all employees that an event has occurred. Monitors include automatic detectors and visual inspection by our operators. 
   Operators will shut down transfer systems as they evacuate the operating portions of our plant 
   All employees will shelter in place in an office area on the site 
   Designated employees will call for fire and emergency services via 911 
   We will summon our emergency response contractors 
   We will advise emergency responders of the known hazards and follow their guidance 
 
Training and preparation: Certainly all of us want to do everything we can to protect the health and well being or our employees and our community. We have our Layers of Protection in the plant; we use training exercises to further protect our employees and to reduce the impact of any releases on our neighbors.  
 
Training is extended to include local Fire and Emergency Services groups. Through these training exercises, we are developing partnerships. These partners 
hips allow us to gain confidence in each other's knowledge and abilities to deal appropriately with incidents. These shared roles in incident response are intended to assure the public, and ourselves, that we can and will react properly and promptly. Vinings Industries is an active member of the Cobb County Resource Council, a partnership of government and industry designed to share information, technology, equipment and resources in the event of an incident.  
 
Lastly, over the past few months, we have added an important job function to the West Oak  staff - an HS&E Specialist. This individual will play an important role in enhancing the plant's safety systems and operations.
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