Stepan Company - Executive Summary
STEPAN COMPANY - MILLSDALE PLANT |
Risk Management Plan
I. EXECUTIVE SUMMARY
Stepan Company is committed to operating in a manner that is safe for Stepan Company employees, the public, and the environment. As part of this commitment, Stepan Company has established operations and management systems to help ensure safe operation of the processes at this facility. One part of this system is a Risk Management Program (RMP) that helps manage chemical risk at Stepan Company's Millsdale Plant and complies with the Environmental Protection Agency's (EPA) regulation 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Program Rule (RMP Rule). One of the requirements associated with the RMP Rule is to submit a Risk Management Plan (RMPlan) describing the risk management program at Stepan Company's Millsdale Plant. This document is intended to satisfy the RMPlan requirements associated with the RMP Rule and to provide the public with a description of the risk managemen
t program at Stepan Company's Millsdale Plant.
1.1 Accidental Release Prevention and Emergency Response Policies
Stepan Company is committed to the safety of Stepan Company employees, public, and preservation of the environment, through the prevention of accidental releases of hazardous substances. Stepan Company implements controls to prevent releases of hazardous substances. In the event of a chemical release, trained personnel will respond to control and contain such releases. Stepan Company evaluates each situation, evacuates employees as necessary, and contacts the local fire department to control and contain the release to prevent and/or reduce the consequences of the release. The Millsdale Plant will also contact Will County Emergency Management Agency (EMA) to assist with emergency management if necessary.
Will County Emergency Management Agency (EMA) has established a Chemical Emergency Preparedness Plan to coordinate emergency response activities and communicate w
ith the public should an accident occur that may pose risk to the community. The communication and public notification system is called the Community Alert Network (CAN). The community is notified of the situation and what action to take via telephone.
Stepan Company's Millsdale facility conducts training and practice exercises on a regular basis to assure effectiveness of the emergency response program.
1.2 The Stepan Company and Regulated Substances
Stepan Company is a major manufacturer of specialty and intermediate chemicals used in a broad range of industries. Stepan Company is a leading merchant producer of surfactants that are the key ingredients in consumer and industrial cleaning compounds. Manufacturers of detergents, shampoos, lotions, toothpastes, and cosmetics depend on surfactants to achieve the foaming and cleaning qualities of their products. Stepan Company's Millsdale Plant handles four (4) substances regulated by the RMP rule in sufficient quantities to be cov
ered by the regulation.
Sulfur trioxide (SO3 ) is delivered by rail car, stored on site, and used in the sulfonation processes. There are five (5) sulfonation processes located at the Millsdale Plant site. The sulfonation processes receive sulfur trioxide from two (2) bulk storage tanks. The sulfonation processes manufacture various sulfonic acids which may be sold to customers for the production of detergents and cleaning products, or further processed within Stepan Company.
Sulfur trioxide (SO3 ) is also delivered to the Millsdale Plant via truck for use in the Process Technology Department (PTD). The PTD uses sulfur trioxide to manufacture various sulfonic acids on a smaller scale than the production processes. Sulfur trioxide is classified as a toxic liquid in the RMP Rule.
Ethylene oxide (EO) is delivered by rail car, stored on site, and used in the alkoxylation process. The process is used to manufacture products that may be sold to customers, used as a raw mater
ial for the sulfonation process, or used as a raw material for polymer manufacturing. Ethylene oxide is classified as a toxic gas in the RMP Rule.
Propylene oxide (PO) is delivered by rail car, stored on site, and used in the alkoxylation process. The process is used to manufacture products that may be sold to customers, used as a raw material for the sulfonation process, or used as a raw material for polymer manufacturing. Propylene oxide is classified as a toxic liquid in the RMP Rule.
Aqua Ammonia (27 wt% aqueous solution) is delivered by tank truck, stored on site, and used in the neutralization process to neutralize the sulfonic acid manufactured from the sulfonation process. Aqua ammonia is classified as a toxic liquid in the RMP Rule.
As a result of the use of regulated substances at Stepan Company's Millsdale Plant, the following five (5) processes are covered by the RMP rule. The inventory of the substances varies during the year. Table I includes the maximum exp
ected inventory for each regulated substance during the year.
1.3 Offsite Consequence Analysis
Stepan Company's Millsdale Plant performed an offsite consequence analysis (OCA) to estimate the potential for an accidental release of the regulated substances included in Table I to effect the public or environment. The OCA consists of both worst case scenarios (WCS) and alternative release scenarios (ARS). The WCS represents a release based on catastrophic failure of equipment or piping. An ARS represents a release that might occur during the lifetime of a facility such as a pipe or hose leak. Both WCS's and ARS's help the Local Emergency Planning Committee (LEPC) improve the community emergency response plan. The scenarios also assist the Millsdale Plant for emergency response pre-planning. The WCS and ARS are completed as defined in the RMP rule.
The main objective of performing the OCA is to determine the distance at which certain effects might occur off-site because of an acc
idental release. Each regulated substance has an independent concentration to estimate the distance to the endpoint. Endpoints for toxic and flammable substances are defined in the RMP regulation.
The toxic endpoint concentrations vary among the covered substances based on potential health effects upon exposure. The endpoints for flammable substances are defined in terms of overpressure and radiant heat. The endpoints have been defined to minimize the potential for long term health effects upon exposure.
The distances to endpoint are estimated using EPA's Offsite Consequence Analysis (OCA) document and dispersion models.
The RMP Rule requires facilities to identify one worst case scenario to represent all the toxic substances and one worst case scenario to represent all the flammable substances. The RMP Rule also requires submission of an alternative release scenario for each toxic substance and one alternative release scenario to represent all the flammable substances. S
tepan Company's Millsdale Plant does not store or process any flammable substances defined by the RMP Rule.
Worst Case Release Scenario (WCS) - Toxic Substances
The worst case scenario for toxic substances at Stepan Company's Millsdale Plant is a catastrophic failure of a railcar containing 180,000 pounds of liquid sulfur trioxide (SO3). The worst case scenario assumes the entire quantity of sulfur trioxide is released in a period of ten (10) minutes. The resulting chemical release would reach off-site endpoints and public receptors. As defined by the regulation, the worst case scenario does not consider the presence of emergency interlock systems that will promptly isolate the release, or mitigation by emergency response personnel.
The distance to endpoint associated with the WCS was calculated using EPA's Offsite Consequence Analysis (OCA) document. The document includes look-up tables that may be used to find the distance from a release point based on the release rat
e and the substances toxic endpoint.
Alternative Release Scenario (ARS) - Toxic Substances
Following is a description of alternative release scenarios and mitigation available to respond to the release scenarios.
The ARS for sulfur trioxide (SO3) is the rupture of a 2-inch diameter transfer hose connected to a railcar for sulfur trioxide unloading. The hose fails due to railcar pull-away. The scenario assumes that the release will be isolated using the railcar safety interlock system. Prompt activation of the system is expected because unloading operations are constantly monitored. The railcar unloading system is also equipped with motion detectors that will isolate sulfur trioxide flow in the event of railcar movement. The resulting chemical release would reach off-site endpoints and nearby public receptors.
The ARS for ethylene oxide (EO) is the rupture of a 2-inch diameter transfer hose connected to a railcar for ethylene oxide unloading. The hose fails due to railca
r pull-away. The ethylene oxide rail cars are equipped with excess flow valves. An excess flow valve is internal to the rail car and stops ethylene oxide flow almost immediately in the event of hose failure. In addition to the excess flow valve, area monitors have been installed to detect airborne concentrations of ethylene oxide, and video cameras monitor the railcar unloading area. The railcar unloading system is equipped with a safety interlock system. Dry disconnects are also used for hose connections to minimize the potential for chemical release. All railcar brakes are set, and wheels are chocked prior to initiating transfer. The resulting chemical release would reach off-site endpoints and nearby public receptors.
The ARS for propylene oxide (PO) is the rupture of a 2-inch diameter transfer hose connected to a railcar for propylene oxide unloading. The hose fails due to railcar pull-away. The propylene oxide rail cars are equipped with excess flow valves. An excess flow
valve is internal to the rail car and stops propylene oxide flow almost immediately in the event of hose failure. In addition to the excess flow valve, area monitors have been installed to detect airborne concentrations of propylene oxide, and video cameras monitor the railcar unloading area. The railcar unloading system is equipped with a safety interlock system. Dry disconnects are also used for hose connections to minimize the potential for chemical release. All railcar brakes are set, and wheels are chocked prior to initiating transfer. This scenario is not expected to impact an off-site receptor.
The ARS for aqua ammonia (27 wt% aqueous solution) is the rupture of a 2-inch diameter transfer hose connected to a tank truck. The hose fails due to truck pull-away. The scenario assumes employees will detect the release and isolate the line. Tank truck unloading of aqua ammonia (27 wt% aqueous solution) is constantly monitored. The truck brakes are set and wheels are chocked pr
ior to initiating transfer. This scenario is not expected to impact an off-site receptor.
The distance to endpoint for the alternative release scenarios were calculated using the TRACE atmospheric dispersion model developed by SAFER Systems. TRACE is a comprehensive hazard assessment software tool for analyzing the impact of toxic, flammable, and explosive chemical releases into the atmosphere. TRACE has the capability to create a thorough and scientifically sound analysis of atmospheric releases.
1.4 Accidental Release Prevention Program and Chemical-Specific Prevention Steps
The following is a summary of the general accident prevention program in place at Stepan Company's Millsdale Plant. The Environmental Protection Agency (EPA) RMP regulation and the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulation regulate processes at Stepan Company's Millsdale Plant. The following summary addresses each of the OSHA PSM elements and descri
bes the management system in place to implement the accident prevention program.
Stepan Company's Millsdale Plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation include team membership in process hazard analyses, team membership during pre-startup safety reviews, emergency response team participation and creating/updating operating procedures. Employees have access to all information created as part of the PSM program. Specific ways employees are involved in accident prevention are documented in the Millsdale Plant's Process Safety Management Policy and Procedure. The Process Safety Engineer maintains the PSM policies and procedures at the Millsdale Plant.
Process Safety Information
Stepan Company's Millsdale Plant maintains a variety of technical documents that are used to help maintain safe operation of processes. These documents address chemical properties
and associated hazards, limits for operating conditions, chemical inventory, and equipment design information. The facility management of change procedure (MOC) is used to maintain up to date information. The documents are accessible to all employees electronically from their computers.
Chemical specific information, including exposure hazards and treatment are provided in the material safety data sheets (MSDS). This information is supplemented by information that addresses known corrosion concerns and hazards associated with reactivity. Each regulated process has defined operating limits for key process variables. The processes are operated within these limits using process controls (hardware and software), trained personnel and alarms/safety shutdown systems.
The Stepan Company's Millsdale Plant also maintains technical documents and specifications related to the design and construction of process equipment. This information includes material of construction, design pressure
and temperature ratings, area electrical classification, and design of safety systems. This information in conjunction with operating procedures and trained personnel, provide a basis for establishing inspections and maintenance activities, as well as evaluation of proposed processes and facility changes to ensure safety features in the processes are not compromised.
Process Hazard Analysis
Stepan Company's Millsdale Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. This is referred to as a Process Hazard Analysis (PHA).
The Millsdale Plant primarily uses the Hazard and Operability (HAZOP) Hazard Evaluation Procedure to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well
as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.
The PHA team's findings are summarized in a report and communicated to plant management and all employees associated with the process. Implementation of the findings is based on relative risk ranking parameters assigned by the PHA team. The risk ranking helps assure the findings with the highest risk receive prompt attention. All PHA findings are tracked until completion.
To help ensure that process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Millsdale Plant revalidates the process hazards analysis on a five (5) year frequency for the entire life of the process in accordance with the PSM regulation. The findings from the revalidations are ma
naged in the same fashion as for the original hazard analysis.
The Stepan Company's Millsdale Plant maintains written procedures that address various modes of operations such as:
* Process Startup
* Normal Shutdown
* Emergency Shutdown
* Operating Conditions
* Safety and Health Information
The procedures may be used as a reference for experienced operators and provide a basis for training new operators. Procedures are maintained current using the Management of Change procedure (MOC).
Prior to hiring, Stepan Company's Millsdale Plant requires potential chemical process operators to successfully complete an eight week junior college course related to chemical plant operations. New operators also receive facility safety and health training prior to introduction into their process area for on the job training. The operators begin to work independently once they have been certified through tests and/or skill demonstration that they are knowledgeable re
garding their duties. All training is documented.
Potential employees that have experience operating chemical processes do not have to complete the junior college course. Experienced chemical plant operators receive training related to the process where they will be working and on the job training. The operators begin to work independently once they have demonstrated through tests and/or skill demonstration that they are knowledgeable regarding their duties. All training is documented.
Stepan Company's Millsdale Plant uses contractors to supplement the work force during periods of increased maintenance or construction. Millsdale Plant has procedures in place to ensure contractors:
* Perform work in a safe manner
* Have appropriate knowledge and skills
* Are aware of hazards in the workplace
* Understand responsibilities during an emergency
* Understand site safety rules
* Inform Stepan Company employees of potential hazards
This is accomplished by requiring
contractors to complete general and job specific training annually. The operating chemical companies in Will and Grundy Counties, along with Three Rivers Manufacturing Association (TRMA), established common training for contractors that work at facilities in the area. In addition to TRMA training, contractors receive site specific training on an annual basis as well as specific training related to the process where the contractor will be working.
The Millsdale Plant also evaluates each contractor's safety program and performance prior to awarding bids to work at the plant site. All contractors are also subjected to random drug and alcohol testing. The Millsdale Plant monitors contractor performance at the plant site to ensure they are fulfilling their safety obligations.
Management of Change (MOC)
The Stepan Company's Millsdale Plant has a comprehensive system to manage changes to the process. This system requires that changes to items such as process equipment, chemicals, and
procedures are properly reviewed and authorized by a multi-functional and multi-level review team prior to implementation. The intention of the change process is to assure the proposed change is understood and will not introduce hazards into the process. Affected drawings, procedures, and/or technology documents are updated to reflect these changes. In addition, personnel training regarding the change may be provided when necessary.
Pre-Startup Safety Review (PSSR)
Stepan Company's Millsdale Plant conducts a PSSR for any new facility or facility modification. The purpose of the PSSR is to ensure safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. The procedure assures construction is completed within design specification and confirms the integrity of the equipment once installed. The procedure also includes process commissioning tests using non-hazardous fluids to confirm systems function as d
The PSSR process uses checksheets and checklists to manage construction and documentation that the process is ready to operate. Field verification of the process change serves a quality assurance function by ensuring design specification as wells a plant policies have been adhered to. All PSSR documents are retained for future reference.
The Stepan Company's Millsdale Plant has a program to maintain the following in a safe working condition:
* Pressure Vessels
* Piping Systems
* Relief Devices
* Process Controls
* Rotating Equipment
* Safety Equipment
The aspects of the program include:
* Developing procedures
* Providing training
* Performing inspections and tests
* Identification of deficiencies and corrective action
Maintenance personnel receive training related to safety and health hazards, emergency response, safe work practices, and maintenance procedures to help ensure they can perform their job in a safe manner. Inspection
s and tests are performed to help ensure equipment function as intended.
Safe Work Practices
The Stepan Company's Millsdale Plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of safe work practices include:
* Site Safety Rules
* Hot Work Permit Procedure to minimize potential for ignition sources
* Lock, Tag, Try Procedure to isolate energy that may cause injury
* Confined Space Procedure to ensure safety during entry into confined areas
* Line Break Procedure to remove hazardous materials before opening pipes
* Permitting procedures for the above and general work
These procedures and training provide a system to help ensure operations, maintenance, and contractor activities are performed safely.
The Stepan Company's Millsdale Plant has a comprehensive incident investigation procedure that promptly reviews all incidents that resulted in, or could have resulted in, a fire/explosion, toxic gas release,
major property damage, environmental loss, or personal injury. The objective for each investigation is to determine the facts associated with the incident, identify root cause, develop corrective action, and learn from the incident to prevent recurrence.
The investigations are completed using teams comprised of personnel involved in the incident, process safety, safety, management, and an impartial representative. The investigation team develops a report to communicate findings and tracks the findings to resolution. If incidents occur, they are reviewed during hazard analysis revalidation and operator training.
To help ensure the process safety management program is functioning properly, The Stepan Company's Millsdale Plant completes annual audits of the PSM program. The audits are conducted by Stepan Company corporate personnel knowledgeable of the PSM regulation. The audit team may identify findings that are tracked to completion.
Stepan Company is a m
ember of the Chemical Manufacturer's Association (CMA). CMA members participate in a program titled Responsible Care. Responsible Care has six (6) codes related to environmental, health, and safety management. One (1) of the six (6) codes is titled process safety code. The code includes 22 management practices that are very similar to OSHA's PSM regulation.
The Millsdale Plant participated in a voluntary audit sponsored by the Responsible Care Program in 1998. The purpose of the program is to ensure participating companies have management systems regarding environmental, health, and safety. The Millsdale Plant received favorable comments regarding their PSM system during the audit.
Chemical Specific Prevention Steps
The prevention program summarized in this document applies to Program 2 and Program 3 EPA RMP regulated processes at Millsdale Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by design error
, equipment failure, or human error.
In addition, to the PSM systems, Stepan Company's Millsdale Plant has safety features on many processes to help contain/control a release, quickly detect a release, and reduce the consequences associated with a release. The following types of safety features are used in various processes:
* Hydrocarbon detectors with alarms
* Smoke detectors
* Video Monitors
* Scrubbers and absorbers to remove hazardous materials from process streams
* Automated valves to provide isolation
* Safety Interlock Systems
* Curbing and dikes for containment
* Redundant equipment and instrumentation
* Pressure relief devices
* Automatic fire suppression and extinguishing systems
* Trained emergency response personnel
* On-site emergency response equipment
* Blast resistant building construction
1.5 Five-Year Accident History
No releases of any of the regulated substances at the Millsdale Plant have oc
curred within the last five (5) years that have resulted in fatalities, injuries, or significant property damage on site, or known fatalities, injuries, evacuations, shelter-in-place, property damage, or environmental damage off-site.
1.6 Emergency Response Program
Stepan Company's Millsdale Plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to an accidental release of regulated toxic and flammable substances. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel during and after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, Millsdale Plant has procedures that address maintenance, inspections, and testing of em
ergency response equipment. The emergency plan is revised to reflect process changes at Millsdale Plant.
Members of Stepan Company's Millsdale Plant's Emergency Response Team (ERT) receive training throughout the year. The ERT has sixty (60) members. Emergency response equipment includes:
* Three (3) 2,500 gallon per minute fire pumps
* Approximately 6,500,000 gallons for fire water supply
* 1,500 gallon per minute industrial foam engine
* 2,000 gallons of foam extinguishing agent
* Approximately 300 portable fire extinguishers
* Boat for response involving waterways
* 600 ft. of oil boom
* 2,500 and 3,000 gallon vacuum trucks
* Trauma kits for first aid
* Tactical rescue equipment
* Hazardous material response trailer
* Automatic fire protection systems
The overall emergency response program for Millsdale Plant is coordinated with Will County Local Emergency Planning Commission (LEPC). This coordination includes periodic meetings of the committee. The committee
members include local emergency response officials, local government officials, and industry representatives. Millsdale Plant has 24 hour communications capability with LEPC officials and the site Emergency Response Team. This provides capability to notify the public of an incident, if necessary, as well as facilitate quick response to the incident. The public is notified using the Community Alert Network (CAN). In the event of an emergency, the CAN system will notify the public by telephone. The system is managed by the LEPC and tested regularly.
In addition to LEPC meetings, Millsdale Plant conducts annual emergency drills that involve the LEPC, local fire department, other chemical plant emergency response teams, and Millsdale Plant's emergency response team.
1.7 Commitment to Accident Prevention
Stepan Company's Millsdale Plant constantly strives to improve the safety of Millsdale Plant's processes through safety reviews, safety committees, process audits, and a program to
solicit safety suggestions from employees. Stepan Company's Millsdale Plant resolves findings from PHA's, incident investigations, and PSM audits.
I hereby certify that to the best of my knowledge the information associated with all RMP regulated processes at the Millsdale Plant, after reasonable inquiry, is true, accurate, and complete.
Dwain Dodson, Plant Manager
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