Washougal Plant - Executive Summary |
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Executive Summary - Vinings Industries, Inc. Plant: Washougal, WA Vinings Industries is a chemical manufacturing company based in Atlanta, GA. We produce products for several diverse industries including paper manufacturing, pigment mining, textile sizing, paint manufacturing, water treatment and agricultural pest control. The Washougal, Washington facility manufactures products for paper, water treatment and agricultural markets. The portion of the plant covered by Risk Management, makes two dithiocarbamate products that are sold to other chemical companies for use in agricultural pest control and for use in wastewater treatment. While the Washougal facility is 10 years old, the Organics Unit producing these dithiocarbamates is less than three years old. From initial concept, the design of the Organics Unit included product, process and employee safety considerations. OSHA regulations (Process Safety Management) required that several Layers of Protection be included during design, before startup and to continue through operations and training of all employees. These Layers of Protection are now parts and obligations of our Risk Management Programs. The Organics Unit uses three raw materials that are covered under Risk Management: carbon disulfide, methylamine and dimethylamine. EPA lists carbon disulfide as a Toxic; the two anhydrous amines are listed as flammables. Carbon disulfide: 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 Clear, colorless, flammable gas with a fishy odor. 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 headac hes. Prolonged exposure to high concentrations may be fatal Dimethylamine Clear, colorless, flammable gas with a fishy or ammonia odor Slightly heavier than air Exposure can be irritating to the eyes and throat Liquid contact with the eyes can result in severe pain and corneal injury. Contact with the skin can cause dermatitis or blistering. Inhalation of fumes can cause nausea, vomiting and headaches. Prolonged exposure to high concentrations may be fatal As part of Vinings' stewardship and safety programs, we recognize that the amines are also toxic and that carbon disulfide is flammable. The design of storage and handling systems take both hazards of each material into consideration. All materials handling, from rail car unloading, through storage, reaction, storage and loading of finished product into shipping containers, is a closed loop during normal operating conditions. Venting, when required, is routed through scrubbers designed to minimize emissions to the atmosphe re. Recent tests on the system indicated the need for additional scrubbing capacity. The approval of our proposed additional scrubbing capacity is pending at the local air permit regulatory authority. In the production of dithiocarbamates, reactions between a specific amine and carbon disulfide will yield a specific dithiocarbamate. The Organics Unit uses two amines to produce two distinct dithiocarbamates. The reaction systems (as well as loading and unloading systems) are computer controlled and monitored by trained operators. Interlocks in the computer logic, for example, will not allow a rail car of amine to be unloaded unless all valves are in the proper position and that all safety observations and checks are properly processed. Offsite Consequence Analysis: Worst Case Scenario - Toxic Chemical - Analysis of our processes showed the Worst Case Scenario (Toxic) to be the sudden and complete loss of a full tank (350,000 pounds) of carbon disulfide. The only safety precautions t hat Risk Management allows to be considered in the Worst Case Scenario are passive mitigation. In our case, the storage tank is surrounded by concrete dike containment. The contents of the ruptured tank would empty into this secondary containment, limiting the surface area from which carbon disulfide could evaporate. Based on EPA's Offsite Guidance, we estimate evaporated carbon disulfide would travel approximately 2.1 miles. This distance is based on the assumption of rural terrain. Much of the area around the plant is, however, urban. On these sides of the plant, the distance to the "endpoint" is less than 2.1 miles. Within the larger affected area, a population of 5,100 would potentially be affected, including residences, schools, recreation areas, commercial and industrial facilities, a wildlife sanctuary, preserve or refuge and a National Forest. Worst Case Scenario - Flammable - Analysis of our processes showed the Worst Case Scenario (Flammable) to be the sudden and complete lo ss of a full tank (220,000 pounds) of dimethylamine. 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 0.45 miles. Within these areas, a population of 203 would potentially be affected, including recreation areas, commercial and industrial facilities, and a wildlife sanctuary, preserve or refuge. 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 - Analysis of our systems indicate that the more l ikely toxic scenario would be continuous venting of vapor from the relief valve on the carbon disulfide tank because of tank over pressurization due to a fire in the containment pit below the tank. Mitigation systems including sprinkler systems, a deluge system, and emergency shutdown systems are available, but because of time considerations are not used in calculating the distance endpoint. In such case, the loss rate would be 30,000 pounds in one hour. Using EPA's Offsite Guidance, we estimate carbon disulfide would travel 0.76 miles before the concentration dispersed to a level considered by EPA to be non-hazardous. Within these areas, a population of 647 would potentially be affected, including residences, recreation areas, commercial and industrial facilities, and a wildlife sanctuary, preserve or refuge. Alternative Case Scenario - Flammable - Analysis of our systems indicate that the more likely scenario (flammable) would be the release of 25,000 pounds of methylamine from a 1" hole in the tank. Our shower/deluge system would mitigate an estimated 70% of the released product, catching lost material in the secondary containment pit below the storage tank. 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 0.14 miles. Within these areas, a population of 9 would potentially be affected, including commercial and industrial facilities, and a wildlife sanctuary, preserve or refuge. Accident history: During the 2 1/2 year history of the Organics Unit, we have had one accidental release of methylamine on July 2, 1997, estimated to be 1,950 pounds. No offsite injuries occurred, but one nearby industrial facility was evacuated at our recommendation. In The past, 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 det ermine the source(s) of these odors and to take actions to prevent a recurrence. In 1998, modifications to an existing scrubber were made which significantly improved its performance. Since then, no confirmed odor complaints have been received for the Washougal plant. Additionally, planned increased scrubbing capacity for the Organics Unit should further aid in reducing emissions. The goal at Vinings is to produce quality products and to produce them safely. We have systems in place that are designed to prevent accidents, to safeguard our employees, our community and our environment. Following is a partial listing of the Layers of Protection that we employ in our everyday activities. Design: As previously stated, in the early days of the design of the Organics Unit, we used best engineering practices to assure the systems would operate as intended. We have concrete dikes (secondary containment) to catch any spilled materials. All of our valve systems are designed to fail-safe. This means that in the event of computer failure or loss of electrical or air power, valves will return - open or closed as necessary - to the "safe" position. 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 will correct it. Maintenance: We have a documented maintenance program in place. Using a combination of safety and quality programs, instrument calibration, prestartup safety reviews, Management of Change and a Work Order system are integrated into Maintenance. 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 the Organics unit - from unloading r ailcars to filling trucks and railcars with finished products - are restricted to trained, designated employees. Most activities in the Organics Unit are computer controlled. This means that nearly all actions taken by an operator are checked against an internal list in the computer's memory as well as with remote sensors to make sure it is the correct action. Established safe conditions must be met before actions can be completed. The equipment and systems that contain the materials are closed; that is, the materials are contained in equipment that is designed to prevent materials from reaching the atmosphere or environment. This extends from the time we unload a railcar of raw materials, move them through storage tanks to the processing vessels, on to finished product storage tanks and loading finished products into a tank truck or railcar for shipment. All relief venting is carefully controlled through scrubbers or chemical cleaners that are designed to capture and significantly reduce emissions. Additional scrubbing capacity is now being designed to more completely capture and neutralize residual materials and occasional odors. Auditing: The Vinings Quality System at Washougal 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 actions: An alarm system will notify all employees that an event has occurred. Monitors include automatic detectors, computer systems and visual inspection by our operators. Operators will shut down transfer systems as they evac uate the operating portions of our plant All employees will initially shelter in place in one of three areas on the site Designated employees will call for fire and emergency services via 911 We will summon our emergency response contractors Designated employees will call Industrial Park neighbors and alert them to our situation 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 partnerships 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. The Washougal plant is an active member of the Clark County Local Emergency Planning Committee. Lastly, over the past year we have added two important job functions to the Washougal staff - a Production/Process Engineer and an HS&E Specialist. Both of these individuals will play important roles in enhancing the plant's safety systems and operations. During the Summer of 1999, we intend to add a Quality Manager and a Project Engineer to the staff. Again, these functions will enhance our goals of producing quality products and to produce them safely. |