Occidental Chemical Corporation, Durez Plant - Executive Summary

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RISK MANAGEMENT PLAN - EXECUTIVE SUMMARY 
 
Occidental Chemical Corporation (OxyChem), a wholly owned subsidiary of Occidental Petroleum Corporation, owns and operates a synthetic resin and sodium alkoxide manufacturing facility in Niagara Falls, New York.  The facility is located at 5000 Packard Road.  The facility was originally constructed in 1928.  Overall, the facility employs 95 full-time employees. 
 
1.    The Accidental Release Prevention and Emergency Response Policies at the Stationary Source (68.155(a)) 
OxyChem is committed to operating the Niagara Falls, New York plant in a manner that is safe for its workers, the public, and the environment. It is our policy to adhere to all applicable Federal, State and local rules and regulations, industry standards and best practices.  As part of this commitment, OxyChem has established a system to help ensure safe operation of the processes at this facility which includes the prevention of accidental releases of hazardous substances.  One co 
mponent of this system is a risk management program (RMP) that helps manage the risks at the Niagara Falls Plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirement Risk Management Programs (the RMP rule). This document is intended to satisfy the RMP Plan requirement of the RMP rule and to provide the public with a description of the risk management program at the Niagara Falls Plant. 
 
The risk management program at the Niagara Falls Plant consists of the following three elements: 
 
7 A hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances). 
 
7 A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated subst 
ance (covered processes). 
 
7 An emergency response program to help respond to accidental releases of regulated substances from covered processes. 
 
Information further describing these elements is provided in this RMP Plan. 
 
Although the RMP at the Niagara Falls Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety and environmental program at the Niagara Falls Plant.  The Niagara Falls Plant has a comprehensive safety and environmental program in place, establishing many levels of safeguards against release of a hazardous substance as well as injuries and damage from such a release. 
 
OxyChem limits the use of hazardous substances.  Before using a hazardous substance at the Niagara Falls Plant, less hazardous alternatives are considered.  When a hazardous substance is used at the Niagara Falls Plant, OxyChem considers the potential for this substance to adversely affect plant workers, the public, and the envir 
onment and takes steps to prevent any such effects.  This is accomplished through the facility's Management of Change (MOC) and Process Hazard Review (PHR) procedures which are followed for all new or modifications of existing processes. 
 
OxyChem strives to prevent releases of the hazardous substances used at the facility.  OxyChem implements reasonable controls to prevent foreseeable releases of hazardous substances.  When a hazardous substance is used at the Niagara Falls Plant, the equipment is carefully designed, installed, operated, and maintained to reduce the likelihood of an accidental release.  Industry and government standards are closely adhered to in the design, construction, and operation of the equipment.  OxyChem also uses the corporate Fire, Safety and Environmental (FS&E) Engineering Guidelines when designing new or modifying existing processes.  Each project is thoroughly reviewed before approval.  In addition, OxyChem requires the documentation of standard operating  
procedures and the training of employees with regard to these procedures as part of the MOC procedure for all new or modifications to existing process.  OxyChem's mechanical integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances. 
 
OxyChem's goal is to minimize impacts from an accidental release. In the event of an accidental release, the Niagara Falls Plant controls and contains the release in a manner that will be safe for workers and will prevent injury to the public and the environment. OxyChem utilizes emergency response plans as required by federal regulation.  OxyChem trains its workers to respond defensively to an accidental release, reducing the consequences of a release if it occurs.  OxyChem provides response training to its personnel, designates an emergency response coordinator to oversee response activities and coordinates response efforts with area industry an 
d the local emergency response agencies.  The facility also maintains an active Emergency Response Team which is on-call 24 hours per day to respond to an on-site accidental release.  OxyChem has a Special Situations Center at its Corporate Offices in Dallas, Texas to assist in all emergencies. In addition, OxyChem works with the local fire department and with the local emergency planning committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur. 
 
OxyChem is an active participant in the community.  OxyChem is an active participant in plant and community programs which promote education, safety and environmental awareness. The facility has implemented a Voluntary Protection Program (VPP) in which employee participation at all levels is required in designing, implementing  and maintaining safety programs. 
 
OxyChem is an industry leader in the implementation of the Chemical Manufacturer's Association sponsored Responsible Care. Initiative.  As part of O 
xyChem's Responsible Care. efforts, the Niagara Falls Plant is voluntarily involved in a Community Advisory Panel (CAP).  The purpose of this group is to share information about plant operations with members of the community and to discuss their concerns.  The group meets periodically and covers topics of interest to the members including plant safety and environmental performance, emergency response programs, health issues and process safety performance.  Through this outreach effort, as well as other community involvement, the plant stays abreast of community concerns and works to address them. 
 
Over the past five years the Niagara Falls Plant has received the following OxyChem safety and environmental awards: 
 
7 OxyChem Corporate Environmental Merit Award - 1996 through 1998 
For full permit compliance 
 
7 OxyChem Corporate Environmental Pollution Prevention Award - 1998 
 
Although the risk management program at the Niagara Falls Plant helps provide assurance that the facility is maint 
ained and operated in a safe manner, it is only one component of the safety and environmental program. In fact, the Niagara Falls Plant has a comprehensive safety and environmental program in place establishing many levels of safeguards against release of a hazardous substance and injuries and damage from a release of a hazardous substance. In order to effectively implement these policies, OxyChem established a management system headed by the Health, Environment and Safety (HES) Department to oversee safety and environmental-related activities.  This RMP Plan is primarily intended to describe those parts of the safety and environmental program at the Niagara Falls Plant that are required by the RMP rule.   
 
 
2.    The Stationary Source and Regulated Substances Handled (68.155(b)) 
The Niagara Falls Plant handles one regulated substance in sufficient quantity to be covered by the RMP rule, as shown in the following list of RMP-covered Program Level 3 processes at the plant. 
 
Regulated Subst 
ance:  Formaldehyde Solution (45%) 
 
Process:  Resin Manufacturing 
 
Process Quantity, pounds*:  339,000 
 
RMP Threshold, pounds*:  15,000 
 
   *Process and threshold quantity is the quantity of total solution 
 
Formaldehyde is used as a raw material for phenol-formaldehyde resin.  The specific hazards of formaldehyde are as follows: 
7 a combustible liquid 
7 irritating to the eyes, ears, nose, and throat 
7 questionable carcinogen 
 
3.    The Worst-case Release Scenario(s) and the Alternative Case Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario (68.155(c)) 
The Niagara Falls Plant performed off-site consequence analysis to estimate the potential for accidental release of a regulated substance to affect the public or the environment.  The off-site consequence analysis evaluates a "worst-case release scenario " and an "alternative case release scenario ".  The Plant does not expect a worst-case release scenario to ever o 
ccur.  The alternative case release scenario was selected to help the LEPC organize the community emergency response plan.  
 
Trinity software modeling was used for evaluating the distance to the toxic endpoint for the worst-case and alternative case scenarios.  The meteorological data used for the modeling was the EPA default for the worst-case scenario and EPA-suggested values for the alternative case scenario. The EPA-recommended Landview III Program, available from the U.S. Census, was utilized to estimate the number of people living within worst-case and alternative case distances from the location of the storage tank and the public and environmental receptors located within these distances. 
 
In both release scenarios, the heated formaldehyde solution rapidly cools upon release and contact with the concrete or asphalt ground surface.  The liquid formaldehyde solution primarily crystallizes to form paraformaldehyde solid, with some evaporation occurring to form a small vapor cloud. 
 
 
The following information summarizes the off-site consequence analysis performed by the Niagara Falls Plant: 
 
3.1.    Toxic Substance(s) - Formaldehyde Solutions 
The "worst-case release scenario" for a 45% solution of formaldehyde is the release of the entire contents of a 30,000 gallon (290,000 lb. of formaldehyde solution - 15,000 lb. threshold) storage tank over a 10 minute period.  A concrete diked area contains the released formaldehyde solution while an estimated 50 lb. of formaldehyde gas vaporizes.  The maximum distance to the toxic endpoint concentration based on modeling is 0.16 miles from the source.  The U.S. Census indicates that 50 people live within this distance from the location of the tank.  The only public receptor located within this distance is an industrial area.  The only environmental receptor located within this distance is a small, isolated wetland. 
 
The "alternative case release scenario" for a 45% solution of formaldehyde is a failed gasket or weld at the pres 
surized Formalin Loop and the leaking of 7,500 lb. of formaldehyde solution (64 lb. of formaldehyde vapor) to the asphalt/concrete surface below over a 30 minute period.  The maximum amount spilled is based on data from a previous Formalin Loop leak at a similar facility.  Modeling this scenario indicates a toxic endpoint distance of 0.04 miles from the source.  The U.S. Census indicates that 2 people live within this distance.  The only public receptor located within this distance is an industrial area.  The only environmental receptor located within this distance is a small, isolated wetland. 
 
3.2.    Program 3 Processes-Flammable Substances 
There are no regulated flammable substances in quantities above the threshold quantities at the plant.  Propane is stored on-site in 30 lb. cylinders, however, the total quantity is less than the threshold quantity of 10,000 pounds. 
 
 
4.    The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps (68.155(d)) 
Since 1994,  
the Niagara Falls Plant has used a prevention program to help prevent accidental releases of hazardous substances.  Beginning in 1994, the plant formalized this prevention program for the formaldehyde manufacturing and storage process to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. 
 
In 1996, the EPA RMP rule established another level of prevention requirements: 
 
Program 3 is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment outside the fence line. 
 
The following sections briefly describe the elements of the Niagara Falls Plant's Program 3 prevention program that addresses EPA's RMP rule prevention program requirements. 
 
4.1.    Program 3 Prevention Program 
The Niagara Falls Plant's Program 3 prevention program consists of the following 12 elements: 
 
4.1.1.    Process Safety Information 
The Niagara Falls Plant maintains a variety of technical documents that are used to help ensure  
safe operation of the plant processes. These documents address (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant, and (3) design basis and configuration of the equipment at the plant.  The Plant ensures that this process safety information is available to all employees, the LEPC, the Niagara Falls Fire Department, the Niagara Falls Memorial Hospital, and the Niagara County Sheriff's Office. 
 
Material safety data sheets (MSDSs) document the physical properties of the hazardous materials handled at the plant, including regulated substances in covered processes. The information available for each hazardous substance typically includes: 
 
7 Toxicity information and permissible exposure limits  
7 Physical data (e.g., boiling point, melting point, flash point)  
7 Reactivity and corrosively data  
7 Thermal and chemical stability data  
7 Hazards of mixing substances in the process 
 
MSDSs for hazardous substances han 
dled in each process are available at the Process Safety Management Library so that the operators have ready reference to this information.  In addition, MSDSs for products stored in amounts exceeding applicable thresholds are provided to the LEPC and the fire department for use in helping formulate emergency response plans. 
 
The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process.  The available information includes: 
 
7 Operating parameters 
7 Block flow or simplified process flow diagrams 
7 Process chemistry 
7 Maximum intended inventories 
7 Safe upper and lower limits for parameters such as temperature, pressure, or flow 
7 Consequences of deviations from established operating limits 
7 Design basis and configuration of equipment 
7 Piping and instrumentation diagrams, including materials of construction 
7 Electrical classification 
7 Safety systems 
7 Applicable design codes and standards 
7 Design ba 
sis for relief and ventilation systems 
 
When important information was not available, from the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analyses of the process.  Many of the operating parameters are included in the operating procedures to help with the safe operation of the process.  These documents are used to (1) train employees, (2) perform process hazards analyses, and (3) help maintain the equipment. 
 
4.1.2.    Process Hazard Analysis 
The Niagara Falls Plant performs and updates, within 5 years as required by OSHA, process hazard analyses (PHAs) of the covered processes to help identify process hazards and generate recommendations that might improve the safe operation of the process.  A team composed of personnel with engineering and process operating experience and a leader with process hazard analysis experience is assembled to analyze the hazards of the process.  The plant primarily uses the "what-if 
checklist" technique to perform this analysis.  The PHA team prepares a written report describing the results of the analysis, including a list of recommendations.  Responsibility to resolve the recommendations is assigned to unit personnel and, when appropriate, changes to enhance the safety of the process are implemented. 
 
4.1.3.    Operating Procedures 
Niagara Falls Plant process engineers, operators, and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed.  The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets.  Operating procedures include: 
 
7 Steps for safely conducting activities  
7 Applicable process safety information, such as safe operating limits and consequences of process deviations 
7 Procedures for safe work practices such as Lock, Tag and Try; Hot Work; Confined  
Space Entry; and Line Breaking 
7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements, and actions to take if exposure to a hazardous substance occurs 
 
Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations.  The operating procedures are used both to help in operating the plant's processes and as a training guide. 
 
4.1.4.    Training 
The Niagara Falls Plant trains its workers to safely and effectively perform their assigned tasks.  The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process, and (3) a detailed review of the process operating procedures and safe work practices.  Oral reviews and written tests are used to ve 
rify that an employee understands the training material before the employee can resume work in the process.  The operators are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training.  Recommendations from the operators are reviewed, and changes to the training program are implemented as appropriate. 
 
4.1.5.    Mechanical Integrity 
The Niagara Falls Plant maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment.  The mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration, and damage before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes.  The mechanical integrity program includes: 
 
7 Specifications for inspection and testing of process equipment  
7 Specifications fo 
r replacement parts and equipment  
7 Procedures for inspecting, testing, and maintaining process equipment  
7 Training of maintenance personnel  
7 Documentation of maintenance activities 
 
4.1.6.    Management of Change 
The Niagara Falls Plant management of change (MOC) program evaluates and approves all proposed changes to chemicals, equipment, and procedures for a covered process to help ensure that the change does not negatively affect safe operations.  Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program.  All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. 
 
4.1.7.    Pre-startup Review 
The Niagar 
a Falls Plant performs a safety review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely.  This review confirms that: 
 
7 Construction and equipment are in accordance with design specifications 
7 Adequate safety, operating, maintenance, and emergency procedures are in place 
7 Employee training has been completed  
7 For a covered process, a PHA has been performed if the process is new or management of change requirements have been completed if an existing process has been modified 
 
A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed. 
 
4.1.8.    Compliance Audit 
The Niagara Falls Plant audits covered processes to be certain that the prevention program is effectively addressing the safety issues of operations at the plant.  The plant assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and 
this team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process.  The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 
 
Both Occidental Petroleum Corporation (OPC) and Occidental Chemical Corporation (OCC) perform audits of the facility programs, process and documentation at regular intervals.  The facility is required to address all action items within 6 months of notification. 
 
4.1.9.    Incident Investigation 
The Niagara Falls Plant investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented in the future.  The plant trains employees to identify and report any incident requiring investigation.  An investigation team is assembled, and the investigation is initiated w 
ithin forty-eight (48) hours of the incident.  The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. 
 
OxyChem has a formal program including training for incident investigations and the report generation. 
 
4.1.10.    Employee Participation 
The Niagara Falls Plant developed a written employee participation program for all covered processes to help ensure that the safety concerns of the plant's workers are addressed.  The plant encourages active participation of personnel in the prevention program activities of all processes at the plant.  Employees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHAs, MOCs, and operating procedures. 
 
4.1.11.    Hot Work Permits 
The Niagara Falls Plant established a hot work permit program to control spark or flame- producing activities that could result in fires or explosions in covered processes at the plant.  The plant reviewed OSHA 
's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements.  Personnel who are to perform hot work are required to fill out the Hot Work Permit Form.  The Shift Supervisor reviews the completed form before work can begin.  Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation. 
 
4.1.12.    Contractors 
The Niagara Falls Plant established a program to help ensure that contractor activities at the plant are performed in a safe manner.  The program reviews the safety record of all contractors to help ensure that the plant only hires contractors who can safely perform the desired job tasks.  The plant explains to the contract supervisors the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant's emergency response procedures.  The plant requires that the contractor supervisors train each of their employe 
es who will work at the plant before that worker begins work at the plant site.  The plant periodically reviews contractors' training documents and work performance to help ensure that safe practices are followed. 
 
 
5.    The Five -Year Accident History (68.155(e)) 
The Niagara Falls Plant has completed a five year accident review beginning in June 1994 that indicates no off-site releases of toxic compounds. 
 
 
6.    The Emergency Response Programs (68.155(f)) 
The Niagara Falls Plant has established a written emergency response program to help safely respond to accidental releases of hazardous substances.  The emergency response plan includes procedures for the following: 
 
7 Informing the local fire department and the public about accidental releases that could reasonably result in off-site consequences 
7 Providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at the plant 
7 Controlling and containing accidental releases of hazardou 
s Substances, including the use of emergency response equipment 
7 Inspecting and maintaining emergency response equipment 
7 Reviewing and updating the emergency response plan 
 
In addition to Plant Emergency Procedures, the Niagara Falls Plant has developed a Special Situation Plan which is designed for addressing situations that may have an impact on the community.  The Special Situation Plan links the local response to the OxyChem Corporate Emergency Response Center located in Dallas, Texas.  Corporate resources and assistance can be provided as needed. 
 
The Niagara Falls Plant maintains an emergency response team trained in these emergency response procedures.  All plant personnel are trained in evacuation procedures.  The plant periodically conducts emergency response drills and provides semi-annual tours for the local fire department.  The written emergency response plan(s) complies with the following federal contingency plan regulations: 
 
7 OSHA 29 CFR 1910.38(a) - Employee Emerge 
ncy Action Plans 
7 OSHA 29 CFR 1910.119(n) - Process Safety Management of Highly Hazardous Chemicals 
7 OSHA 29 CFR 1910.120(p) and (q) -  Hazardous Waste Operations and Emergency Response (HazWOPER) 
7 OSHA 29 CFR 1910, Subpart L - Fire Protection 
7 EPA 40 CFR 302.6 - Notification Requirements 
7 EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Plan 
7 EPA 40 CFR 355.40 - Emergency Planning and Release Notifications 
7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention 
 
The emergency response plan(s) has been communicated to local emergency response officials through the local fire department and LEPC.  The plant maintains a regular dialogue with the local fire chief and LEPC, and the plant provides appropriate information to the fire chief and LEPC.  The Niagara Falls Plant has an Emergency Response Team (ERT) available 24 hours per day to respond to plant chemical emergencies.  The team has access to on-site emergency equipment which are ap 
propriate for the anticipated emergency situations and capabilities of OxyChem personnel. 
 
 
7.    Planned Changes to Improve Safety (68.155(g)) 
The Niagara Falls Plant constantly strives to improve the safety of the processes at the facility through both the incident investigation program and a program soliciting safety suggestions from the workers.  
 
 
8.    Certification (40 CFR 68.185) 
General Certification:  To the best of my knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. 
 
Signature:    William Bazell*  Date Signed:    June 2, 1999 
 
Title:    Plant Manager 
 
*  The Certification with original signature is presented in the attached cover letter.
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