Dixie Chemical Company - Executive Summary |
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I. General Description Dixie Chemical's manufacturing plant is situated on 45 acres in the Bayport Industrial Park 25 miles Southeast of Houston. As a leading manufacturer of performance chemicals, Dixie's products find a variety of end uses. These include: Resins Coatings and Printing Inks Paper Sizing Chemicals Solvents Food, Drugs, and Cosmetics Surfactants Lube Additives Textiles and Dyes Agricultural Chemicals Contract chemical processing is also a vital part of Dixie Chemical's operations. Dixie Chemical performs sophisticated custom processing under contracts with other chemical manufacturing companies. Dixie Chemical produces most of these products via multi-step synthesis operations. These batch operations include any of the following unit operations: Centrifugation Crystallization Distillation Dry ing Extraction Mixing Solvent Exchange Synthesis Reactions Dixie utilizes the following toxic materials in sufficient quantities to be included under the U.S.E.P.A. RMP regulations: Acrylonitrile, Aqueous Ammonia, Epichlorohydrin, and Propyleneimine. Similarly, Dixie uses the following flammable materials in sufficient quantities to also be included under the RMP program: 1,3-Butadiene, and Isoprene. Of the above chemicals only Propyleneimine is manufactured at Dixie's Bayport facility. It is sold separately and is also used as a raw material for the subsequent synthesis of another product. The remainder of the above regulated chemicals serve as raw materials. Dixie is committed to providing a safe workplace, a clean environment and continued quality improvements. The company has received industry-wide recognition for its safety record and quality performance. All plant operating personnel are required to have classroom in struction as well as equipment specific training prior to being able to independently work in any of the manufacturing areas. A complete hazard review and an operating manual, meeting Process Safety Management regulations, are in place before starting to make any of our products. A team consisting of production, engineering, and research personnel is assigned to monitor the startups of all new production campaigns. II. RISK INVOLVEMENT Because of the nature of these materials, each of the above chemicals are stored in their own dedicated storage tank. Each of these tanks are located within a spill containment area sufficient to contain the volume of the largest tank within the respective area along with a six inch rainfall. This insures that spills will not leave Dixie's plant site. Because most of the Dixie's manufacturing efforts are scheduled in campaigns, and not continuously, the inventories of the above hazardous chemicals are kept at a minimum between campaigns thus redu cing the risk associated with these aforementioned chemicals most of the year. A typical manufacturing operation involves storage of the raw materials in either tanks, tank trailers, or drums; reaction of the raw materials under specific conditions; purification via distillation; and drumming out the selected product. Inventory of both raw materials, intermediates, and final products are kept at minimum levels to reduce the overall risk. The RMP regulations require, however, that risk be assessed assuming that each of the tanks storing hazardous chemicals be considered full and that a spill or leak develops that completely empties the respective tank in as little as ten minutes. Although minor leaks and spills have occurred at Dixie, a spill of this magnitude has never happened. Spill containment was taken into account when assessing the following scenarios. III. WORST CASE SCENARIOS The consequences of a spill or total release of any of the four following chemicals were assess ed: Acrylonitrile, Aqueous Ammonia, Epichlorohydrin, and Propyleneimine. In each case the entire contents of the respective storage tank was emptied into its respective containment area. Under the USEPA's very conservative Off Site Consequence Analysis, the area of influence, where the concentration of fumes from such a spill could be hazardous to a person's health, was determined. Since Dixie's Bayport facility is located in an industrial park, the distance from Dixie plant to the nearest residential neighbor is over a mile. The calculated areas of influence for each of the worst case scenarios from the four above chemicals did not reach out to any residential neighborhoods. Similarly the effects of a Worst Case release of either of our two flammable materials followed by a fire would not reach any of the residential neighborhoods. IV. ALTERNATIVE SCENARIOS The consequence of a spill or release of any of the four following toxic chemicals, denoted as Alternative Scenarios, based on historical performance were made to more appropriately assess the risk to the community: Acrylonitrile, Aqueous Ammonia, Epichlorohydrin, and Propyleneimine. In each of the four cases small amounts were assumed either as overflowing from a storage tank or leaking from a punctured drum. Passive measures such as dikes were assumed. In addition, the efforts of personnel were assumed which would minimize the amount spilled or released. Again the areas of influence from these four cases did not reach any of the residential neighborhoods and in fact seldom got beyond the properly line of Dixie's Bayport plant. Similarly the effects of an Alternative Scenario associated with our flammable materials did not reach any of our residential neighborhoods. V. OSHA PSM MEASURES AT DIXIE OSHA's Process Safety Management (PSM) program has been in place at Dixie's Bayport plant for over five years. This program which has as its central goal the protection of Dixie's personnel withi n our plant site has resulted in a safety program which also extends out beyond our plant site to help protect our adjacent industrial and residential neighbors. This PSM program involves the formal reviews of potential process hazards to identify and prevent process accidents prior to and during operations. In Dixie's PSM program regular equipment inspections are performed. A Management Of Change (MOC) program prevents unauthorized equipment or process change of any PSM regulated operation. Prompt and detailed investigations of every safety incident are carried out in order to insure that other incidents do not happen. Audits are performed to ensure that the proper manufacturing and safety procedures are followed. The following changes have taken place under the PSM program which have reduced incidences at Bayport: Redundant level devices with high level alarms have been installed. A foam system is available to suppress vapors from spills. Water spray systems for cooling ta nks are present in flammable material storage. VI. ACCIDENT HISTORY No accidental spills or releases of RMP chemicals occurred at Dixie Chemical which either harmed any employees or the environment during the past five years. VII. EMERGENCY RESPONSE PROGRAM Dixie Chemical Company has a fully trained Emergency Response Team (ERT) at their Bayport plant. This team is made up of volunteers from operations, maintenance and analytical servicesl. Several members of the ERT on each of the four rotating shifts such that immediate help can occur whenever an accident, spill, or other emergency happens. All ERT personnel receive training as specified by OSHA in 29 CFR 1910.120, 1910.156, and the National Fire Protection Association standards. Annual refresher training is conducted for all team personnel. Drills are conducted at least annually to certify the current level of readiness of all ERT personnel. Drills are evaluated to verify proficiency and to identify areas of needed imp rovement. A plant alarm system serves to alert all plant personnel to any emergencies. A Community Awareness/Emergency Response (CAER) phone line permits citizens to be informed of drills, emergencies, and other areas of interest. The plant radio network is also used to coordinate the actions during any ERT event. Dixie Chemical is a member of the Channel Industry Mutual Aid organization (CIMA) which provides mutual emergency response from over 50 companies in the event aid is needed. Dixie's ERT particapates in area emergency drills with CIMA and the local LEPC. VIII. POSSIBLE CHANGES TO REDUCE RISK Dixie's product mix changes frequently due to the nature of the batch speciality chemical business. This means changes often occur in the chemicals we handle. Constant vigilance will be necessary to insure that the risks associated with these new chemical operations are kept to a minimum. In addition, steps must be evaluated for the reduction of risks related to the existing RM P listed chemicals. These changes also provide opportunities for risk reduction. Equipment must be modified to produce a new product. We use this change as a chance to upgrade the equipment by adding additional safety and environmental controls. These improvements benifit all processes using the modified equipment. One area being evaluated concerns the storage of Acrylonitrile. One risk reduction project being considered involves discontinuing the use of dedicated storage tanks and instead using tank trailer quantities only when they are needed. This Acrylonitrile trailer would be sited within a contained unloading area. Other suggested risk reduction ideas will be evaluated by the PSM/RMP committee at Dixie. |