DuPont Memphis Plant - Executive Summary

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At DuPont's Memphis Site, we manufacture hydrogen cyanide, a basic building block for the manufacture of acrylics and solid cyanides.  In addition we produce Oxone, a dry non-chlorine based oxidizer used in the water treatment and homeproducts industries. 
We are located north of Memphis in the Lucy-Woodstock area of Shelby County at the intersection of Hwy51 and Fite Road.  The DuPont Plant began operation in 1952 and has operated safely within the community for over 46 years. 
The DuPont Memphis plant is committed to operating and maintaining all of our processes in a safe and responsible manner.  This document provides a brief overview of our comprehensive risk management activities. 
Our policy is that all accidental releases to the environment can be prevented.   Therefore our goal is to not have a release that impacts the public, environment, or plant personnel.  We work closely with local off-site emergency respo 
nders to ensure that in the unlikely event a spill or release goes beyond our fence line, we are all prepared to respond. 
In our processes, we use the following chemicals that EPA has identified as having potential to cause significant offsite consequences in the event of a substantial accidental release: 
         Hydrocyanic Acid (HCN) 
         Oleum (Fuming Sulfuric Acid) 
         Sulfur Dioxide (SO2) 
Accident Scenarios: 
The worst case accident scenario for the DuPont Plant involves oleum (fuming sulfuric acid). The accident that could affect people furthest away from our Plant involves the release of oleum from our storage tank. However unlikely, the scenario involves a total loss of tank contents, or 18,000 gallons in only 10 minutes.  
Such a release would create a vapor cloud that travels in the direction of the wind.  As the c 
loud travels away from the site it will become less concentrated and less harmful.  
The alternate accident scenario for oleum involves a hole developing in a pipeline carrying oleum.  Operators shutdown the system and use water fog and fire fighting foam to minimize fuming. Although the release would spread in much the same way as in the worst case scenario, the quantity of the chemical released is far less. 
The alternate accident scenario for Sulfur Dioxide involves a fume release from a safety relief plug mounted on one of our cylinders.  The cylinders are purchased from a local supplier.  Each cylinder is fitted with multiple safety relief plugs designed to protect the cylinder from building pressure and rupturing due to heat or contamination. In the scenario, approximately 584 pounds of SO2 vapor is vented to the air over a 20-minute period.   Personnel fully trained in using specialized equipment would stop the leak. 
The alternate accident scenario for Hydrogen Cyanide involves 
the release of vapor from our wastewater collection system after an accidental discharge of 1000 gallons of HCN.  In the scenario, approximately 812 pounds of HCN vapor is vented over 40 minutes. 
The alternate accident scenario for Ammonia involves a release from a safety relief valve.  This type of incident occurred in 1996 and was thoroughly investigated and changes made to prevent recurrence.  There was no off site or community impact.  The scenario involves a brief system overpressure, which opens a safety relief device for 10 minutes.  Approximately 815 pounds of Ammonia vapor is released. Personnel are trained to immediately respond and assure process controls function properly and system shutdown. 
The worst case accident scenario for a flammable material at the DuPont Plant involves Hydrogen.  The accident that could affect people furthest away from our Plant involves the release of gas from our piping system. However unlikely, the scenario involves a total loss of gas, or 18 
,100 pounds in only 10 minutes. 
The alternate accident scenario for Hydrogen involves a similar but much smaller release of gas from a failed connection, allowing approximately 5,650 pounds to be released.  Personnel will immediately shutdown the system. Although the release could ignite much like the worst case scenario, it would impact a much smaller area. 
Prevention Measures: 
At DuPont we take safety very seriously.  We practice "Defense-In-Depth" which means several things must all fail at the same time for a release to occur.  Since each one of our layers of defense is very reliable, the probability of a release that spreads beyond our plant boundary is very small.   
Listed below are some examples of the things we do to prevent releases and reduce the impact of releases that do occur:  
    (a) Plant equipment is designed carefully, to minimize the probability of a major leak or spill. 
    (b) All unusual operations, and small leaks or spills are investigated to prevent rec 
    (c) Safety controls such as instrumentation, warning alarms and automatic shutdowns are installed. 
    (d) Routine audits of the process are conducted by both Company and outside agencies. 
    (e) Regular equipment inspections and maintenance insure proper operations. 
    (f) Training and testing of operators and mechanics insures they follow safe operating procedures. 
Under the RMP, EPA requires companies to report accidents that result in death, injuries, significant property damage, evacuations, shelter-in-place, or environmental damage.   
Oleum - In the past five years we have had no releases that were reportable by EPA's RMP guidelines.  During this period we had only a few small leaks that were detected and contained within the plant.  They had no impact on the community. 
Sulfur Dioxide - In the past five years we not had an incident involving Sulfur Dioxide that would have been reportable by EPA's RMP guidelines.  We have ha 
d some minor leakage from connection tubing and one leak from a fusible plug, but all were detected immediately, contained within the plant and had no impact on the community. 
Hydrogen Cyanide - In the past five years we had one incident involving Hydrogen Cyanide that would have been reportable by EPA's RMP guidelines.  One of our employees was exposed to vapor from a leak and treated.  
Ammonia - In the past five years we had one incident involving Ammonia that would have been reported under this rule.  In this case, piping leaked and a brief fire resulted, damaging adjacent equipment and building siding.    We have had minor releases of Ammonia over the last five years, all detected immediately, contained within the plant and all had no impact on the community.  
Hydrogen - In the past five years we have had no releases that were reportable by EPA's RMP guidelines.  During this period we have had only a few leaks that were immediately detected and contained within the plant.  They  
had no impact on the community.  
The DuPont Memphis Site has developed a comprehensive Emergency Response Plan (ER Plan) that helps us to protect the health of the public and our employees and prevent harm to the environment.    
The overall site ER Plan begins with a brief description of the purpose and primary objectives for the plan.   This includes:  
    (a) Prevent injuries and save the lives of the public and our employees 
    (b) Minimize property damage 
    (c) Minimize interruptions to the continuity of operations 
    (d) Maintain security of company property 
    (e) Insure that we and the public are prepared to respond to incidents with potential for off-site impact  
     (f) Maintain good public relations 
    (g) Facilitate cooperation with local authorities 
An Emergency is defined as any incident occurring on or off the plant that affects the safety of off-plant neighbors, plant personnel or operations, to the extent that coordinatio 
n of plant personnel is required through channels other than those normally used.  Examples of these type of incidents include fires, hazardous chemical releases, and natural disasters. A higher level of emergency, called a Major Emergency, is declared whenever the safety of personnel in off site;  in more than one operating area on site is affected; or additional resources are needed to respond to the incident. 
Each RMP Covered Process, Operating area, and Normally Occupied building on the site maintains an Emergency Action Plan. 
Informing the Public and Local Emergency Response:  
There are four ways the public is notified whenever an Emergency occurs that may potentially impact them.  First, our procedures require the site Emergency Response Team to notify the Memphis Shelby County Emergency Management Agency by telephone during the emergency.   Second, our site has implemented a Community Communication System whereby individuals can call to hear a voice message on the status of a 
n incident.   Third, our facility has installed an air-horn warning system that alerts the local community to an Emergency condition occurring on site.   Fourth, one component of our Emergency Response effort is an Off-Plant Activities Team which will conduct air monitoring off plant during emergencies and work with the Incident Commander to determine the level the community around our facility should be alerted. 
Documentation of Proper First Aid and Medical Treatment Procedures:  
Plant supervisors and selected members of the Emergency Response team are designated and trained annually to provide first aid coverage when Medical personnel are not on site.   The person providing first aid is also responsible to take whatever action is necessary for prompt transportation of injured or ill personnel to the nearest hospital.  Site Safety, Health, and Environmental Standards for Off-Plant Medical and Incident Classification, Investigation and Reporting are the written documents which descri 
be these procedures. 
Procedures for Handling Accidental Release of a Regulated Substance: 
Hazardous materials emergencies may result from a spill or uncontrolled release of one or more plant materials.  Response to these incidents may require the services of the plant fire brigade or in some cases the site Regional HAZMAT Response Team.   All responses must comply with 29 CFR 1910.120 (q) - Hazardous Waste Operation and Emergency Response. 
The Incident Commander will, upon completion of the initial assessment, request the assistance of either the shift fire brigade or the Regional HAZMAT Response Team. In some situations, both organizations may be required to assist in handling the hazardous materials incident.  Additional resources may be obtained by requesting assistance from the Shelby County Fire Department. 
The Memphis Site Fire Brigade Standard Operating Procedure (SOP) describes the detailed response steps the site will take in the event of a hazardous material emergency. 

he following equipment is maintained on site to assist in responding to the location of the hazardous materials releases: 
    (a) Foam pumper truck 
    (b) Rescue/HAZMAT van 
    (c) Plant ambulance 
    (d) Regional HAZMAT Response Truck  (upon arrival of qualified Regional Team members) 
Coordination with Community Emergency Response Organizations: 
Our site has reviewed and coordinated our Emergency Response plan with local agencies and the Local Emergency Planning Committee.   Members of local Fire Departments and Emergency Response services have been to our site and participated in joint training with our Emergency Response employees. 
The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: 
    (a) Enhance training for site medical emergency responders 
    (b) Participate in Shelby County Emergency Mgt. Agency Community Notification S 
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