Elf Atochem North America, Inc. - Mobile Facility - Executive Summary |
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Introduction A Risk Management Program has been implemented at Elf Atochem's Axis, Alabama plant for the reduction of accidental releases of hazardous materials. This Risk Management Plan summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Plan summary is organized to correspond with specific EPA RMP definitions and requirements, including: Introduction; Elf Atochem policies to protect health, environment, and safety; Facility identification and regulated substances covered processes; Hazard Assessment; Prevention Program; Five-Year Accident History; Emergency Response Plan; and Planned changes to improve safety. Elf Atochem Policies for Health, Environment, and Safety Risk management and safety have been important concerns at Elf Atochem for many years; this RMP formalizes and documents these activities. Elf Atochem is committed to conducting its operation s in a safe, responsible manner and to reducing risks to health and the environment. This commitment to health, environment, and safety (HES) starts with the CEO. Senior management routinely dedicates time to a review of HES matters, including safety. This emphasis on safety is carried through to the facility level, where the Plant Manager and the Safety Committee regularly review safety performance, take corrective actions, and strive for continuous improvement to safety by employees and contractors. Elf Atochem's HES programs include policies, procedures, standards, and guidance materials designed to fulfill Elf Atochem's commitment to health, environment, and safety. These materials include Risk Management Program guidance to help our facilities prevent and/or reduce the risk of accidents. Facility Identification and Regulated Substances in Covered Processes The Elf Atochem Axis, Alabama plant is located on Highway 43, approximately 7 miles north of Exit 19 on Interstate 65. The facility manufactures chemicals which are primarily used as additives in plastics and paints. Certain substances used within the facility are regulated under 40 CFR Part 68, the EPA Risk Management Program (RMP) Rule. These substances are present at or above the minimum threshold for RMP applicability. The chemicals that we use which are covered by the RMP requirements include: Chlorine 180,000 lbs; Hydrogen sulfide 130,000 lbs; and 1,3-butadiene 770,820 lbs. These chemicals are the building blocks (raw materials) for some of the plant's major products. Elf Atochem knows that these and other chemicals which we handle and use are hazardous and/or flammable. We handle these chemicals with a great deal of care and respect. This facility is covered by Title V of the Clean Air Act, but has not received a permit as of the date of this submittal. Hazard Assessment - Worst Case Scenario Elf Atochem strives to protect its employees, con tractors, the community and the environment. Elf Atochem was already addressing most of the EPA's requirements for RMP through our Process Safety Management (PSM) Program. For the worst case scenario, assume the largest tank of the chemical breaks open and spills all of its contents in 10 minutes. For toxics, chlorine and hydrogen sulfide, our largest tanks are rail cars, while for the flammable, butadiene, it is a storage tank. Also, assume all plant safety systems completely fail. Then determining the maximum distance to pose a risk of significant injury to the public or environmental receptors gives the following: Listed Chemical Maximum Distance Chlorine >25 miles 1,3-Butadiene 3/4 mile Neither the EPA nor Elf Atochem believes the worst case scenarios are realistic cases. This Risk Management Plan includes information on mitigation and prevention measures implemented by Elf Atochem to reduce the risk of a worst case scenario event. Hazar d Assessment - Alternate Release Scenario RMP requires each site to analyze Alternate Release Scenarios that could potentially impact the public. For chlorine and hydrogen sulfide, we used a leaking pipe (1/4 inch hole in a line or flange) as our alternate scenario. For butadiene, we used a 24 inch manway failure on process equipment as the alternate release scenario. The following distances were obtained: Listed Chemical Maximum Distance Chlorine 0.81 mile Hydrogen Sulfide 0.6 mile 1,3-Butadiene 0.4 mile This Risk Management Plan includes information on mitigation and prevention measures implemented by Elf Atochem to reduce the risk of an alternate release scenario event. Releases are prevented by designing for safety. Ways which the facility designs for safety include conducting hazard studies to identify potential release scenarios & assess safeguards, completing hazard studies for design changes, designing the plant to be built to in dustry and national engineering codes, maximizing employee participation in design work, designing components with multiple automatic safety shutdowns, building emergency shutoff valves into the process and transfer systems, using overhead sprinklers in flammable chemical storage and handling areas, maintaining computer software designed for process and emergency shutdowns, having specially designed explosion suppression systems, having chemical systems designed to stop process reactions quickly, maintaining a flare designed for control of emergency hydrogen sulfide venting, having fire fighting equipment strategically located in the plant, and ensuring that emergency escape routes from the units are maintained. The facility maintains for safety by operating a preventive maintenance program for tanks, equipment and piping, operating a leak detection and repair program to identify and repair equipment and piping leaks early, conducting routine mechanical inspections to determine that m etal thickness is adequate over the life of the equipment, routinely testing emergency shutdown devices and safety systems, checking sensors as part of a preventive maintenance program, and using mandatory checklists to ensure equipment is opened for repair without creating releases. The facility monitors for safety by operating more than 80 chemical gas sensors which detect leaks at very low levels. Sensors either sound alarms to warn workers or automatically shutdown the process to a safe state. Unit personnel are required to carry hydrogen sulfide monitors that sound an alarm when a leak is detected. The facility operates for safety by employing highly trained, knowledgeable, process safety certified operators. The operators are trained through the use of detailed operating procedures. Operations are computer controlled and monitored, and the process has latching/emergency shutoff valves which can be controlled from several locations. Additionally, video cameras are used to watch key areas, and high pressure/temperature/level alarms are used wherever needed. Operators carry radios while in the field. The facility audits for safety by performing process safety audits by in-plant and corporate personnel, conducting operational in-plant audits, conducting operations and safety inspections regularly, and by routinely investigating incidents/accidents. Emergency Response Plan A written emergency response plan is maintained at the facility. The emergency response measures to be taken for RMP release scenarios has been incorporated into the facility emergency response plan. The facility actively participates with Mobile County Local Emergency Planning Committee (LEPC) to coordinate emergency response training and drills at the plant site. Selected elements of the plan will be incorporated in to the Mobile County Emergency Action Plan, which is maintained by the LEPC. The facility is also involved in working with the other members of the LeMoyne Industri al Park (LIP), and as such, maintains an incident command protocol for emergency preparedness. We are prepared to respond to accidental releases. The facility prepares by having employees participate in drills and training for emergency response/ mutual aid, attending annual training at professional fire school, having fire/spill response equipment ready, having an emergency response team on site 24-hours / day, providing contractors with training on plant safety systems and process information, providing employees with medical/first responder and rescue training. Supervisors and key employees also receive incident command & spill response training. Five Year Accident History There have been no RMP releases for the last five years (i.e. no on-site or off-site injuries, property or environmental damage, and no off-site evacuations). |