The Dow Chemical Company - Executive Summary |
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General Executive Summary For The Dow Chemical Company Riverside, Missouri Site 1. Accidental Release Prevention and Emergency Response Policies We at The Dow Chemical Company are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Extruded Polystyrene Production/Polystyrene Production. We have 1 regulated substance present at our facility. This substance is Ethyl chloride [Ethane, chloro-]. It is used as a blowing agent for extruded polystyrene production.. The maximum inventory of Ethyl chloride [Ethane, chloro-] at our facility is 386000.00 lb.. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario, including administrative controls and mitigation measures To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from Extruded Polystyrene. In this scenario 200000 lb. of Ethyl chloride [Ethane, chloro-] is released. The release quantity has been limited to 87% of the maximum capacity of the source by a system of administrative controls. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.36 miles is obtained correspo nding to an endpoint of 1psi overpressure. The alternative release scenario submitted for Program 3 flammable substances involves a release from Extruded Polystyrene. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 186000 lb. of Ethyl chloride [Ethane, chloro-]. Active mitigation controls such as Computer Alarms/Response, and Operator Intervention are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1psi overpressure is 0.23 miles. 4. The General Accidental Release Prevention Program Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with Dow Loss Prevention Principles and Dow Engineering Standards. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information The Dow Chemical Company maintains a detailed record of safety information (i.e., MSDS, Spec Sheets) that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every 3 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 05/20/1997 during the Dow Consolidated Audit. Operating Procedures For the purposes of safely conducting activities within our covered processes, The Dow Chemical Company maintains written opera ting procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training The Dow Chemical Company has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 1 year and more frequently as needed. Mechanical Integrity The Dow Chemical Company carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at The Dow Chemical Company to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/20/1997. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at The Dow Chemical Company. The most recent review was performed on 05/22/1995. These reviews are conducted to confirm that con struction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits The Dow Chemical Company conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 05/20/1997. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation The Dow Chemical Company promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation The Dow Chemical Company truly believes that process safet y management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. The Dow Chemical Company has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History The Dow Chemical Company has had an excellent record of p reventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan The Dow Chemical Company carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Jefferson County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several de velopments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The Behavior Based Safety Program and good housekeeping practices are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 7/199. |