Occidental Chemical Corporation Ashtabula Plant - Executive Summary

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Occidental Chemical Corporation (OxyChem), a wholly owned subsidiary of Occidental Petroleum Corporation (OPC), owns and operates a specialty chemical manufacturing facility in Ashtabula, OH. This facility is known as the Ashtabula Plant and is located at 725 State Road in Ashtabula.  At this facility, OxyChem manufactures a variety of specialty organic chemicals for other OxyChem plants and for outside customers.  The facility was originally constructed in 1954 and employs 79 full-time employees. 
1.  Accidental Release Prevention and Emergency Response Policies at the Stationary Source  (' 68.155(a)): 
OxyChem is committed to operating the Ashtabula 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 that includes the prevention of accidental releases of hazardous substances.  One component of this system is a risk management program (RMP) that helps manage the risks at the Ashtabula Plant and 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) and OSHA 1910.119. 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 Ashtabula Plant. 
The RMP at the Ashtabula 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 ope 
rate the processes containing more than a threshold quantity of a regulated substance (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 risk management program at the Ashtabula 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 Ashtabula Plant.  In fact, the Ashtabula 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's policy on the use of hazardous substances:  Before using a hazardous substance at the Ashtabula Plant, less hazardous alternatives are always considered.  When a hazardous substance is used at the Ashtabula Plant, OxyChem rev 
iews the potential for an accidental release of this substance, which could adversely, affect plant workers, the public and the environment, 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 installations or modifications of existing processes that handle hazardous materials. 
OxyChem strives to prevent accidental 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 Ashtabula 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) 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 training of affected employees with regard to these procedures as part of the MOC procedure. 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 Ashtabula Plant controls and contains the release in a manner that will be safe for workers and will prevent impact to the public and the environment.  OxyChem utilizes emergency response plans as required by government regulation.  OxyChem trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs. OxyChem also has established a Special Situations Center in the Dalla 
s corporate office to assistant 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 has assisted the LEPC in writing and implementing the Ashtabula County, Community Awareness and Emergency Response Plan (AC-CAER). 
Ashtabula Plant's emergency response plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, Ohio and EPA regulations.  This plan outlines the responsibilities and actions required to control an emergency that limits itself to within the Ashtabula Plant.  If the emergency extends beyond the plant boundaries and affects the surrounding communities, the Ashtabula County-CAER Plan is initiated by a call to 911 and a statement of the type of emergency. 
OxyChem is an active participant in the community:  OxyChem is an active participant in plant and com 
munity programs which promote education, safety and environmental awareness.  In addition, the Ashtabula Plant demonstrates community commitment by providing involvement and leadership in important local organizations such as the Local Emergency Planning Commission (LEPC) and the Ashtabula River Partnership (ARP).  OxyChem was a founding member of the Community Advisory Panel (CAP), which was formed in 1994.  Safety is a primary concern in our facility and throughout our corporation.  The Ashtabula Plant received OxyChem's Silver award by completing two years without an OSHA recordable incident on January 4, 1999.  Additionally, CMA recognized OxyChem's accomplishments in safety with the prestigious "Excellence in Safety Award".  The plant also achieved over one year without an excursion from environmental permit limits.  The Ashtabula facility has been awarded OxyChem's 1998 Environmental Performance Award for achievements in minimizing environmental notifiables and efforts in waste a 
nd emission reductions. 
OxyChem is an industry leader in the implementation of the Chemical Manufacturer's Association sponsored Responsible Care. Initiative. As part of OxyChem's Responsible Care. efforts, the Ashtabula Plant has voluntarily been involved in a Community Advisory Panel (CAP) since its inception in 1994. 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 monthly 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. 
In order to effectively implement these policies, OxyChem established a management system headed by the Health, Environmental and Safety (HES) Departments to oversee safety and environmental-related 
2.  The Stationary Source and Regulated Substances Handled (' 68.155(b)): 
The Ashtabula Plant handles three regulated substance that are covered by the RMP rule, as shown in the following list of RMP-covered Program Level 3 processes at the plant.  The list is as follows: 
(Regulated Substance; Process; Largest Vessel Inventory, lbs; RMP Threshold (lb)) 
(Chlorine; Cylinders; 2,000; 2,500) 
(Epichlorohydrin; Storage tank; 220,000; 20,000) 
(Hydrogen sulfide; Railcar; 130,000; 10,000) 
Chlorine is a raw material occasionally used at this facility, and is being included with this submission as a predictive filing. The liquid chlorine is stored in five (5) 1-ton chlorine cylinders.  These cylinders are positioned on a concrete and steel rack and are connected to the transfer piping to the process.  The facility uses best practices and Chlorine Institute recommended practices in its operations. 
Epichlorohydrin is used as a raw material.  It is stored as a liquid in a 24,000  
gallon storage tank and is pumped to the process through stainless steel piping.   
Hydrogen sulfide is used as a raw material.  It is stored as a liquefied gas in a railroad tankcar and flows to the process through carbon steel piping. 
3.   The Worst-Case Release Scenario(s) and the Alternate Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario (' 68.155(c)): 
The Ashtabula 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 RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario " and an "alternative release scenario."  In reality, however, OxyChem does not expect a worst-case release scenario to ever occur.  The alternative release scenarios are developed to help the LEPC improve the community emergency response plan.   
RMP*Comp Version 1.04 was used for  
evaluating the distance to the toxic endpoint for the worst-case scenario and the alternative release scenarios to determine the off-site consequences.  The meteorological data used for the modeling was the EPA default for the worst case and EPA suggested values for the alternative release scenario. The EPA recommended Landview program was utilized to estimate the number of people living within this distance from the storage location.  USGS maps were utilized to identify the public and environmental receptors located within this distance. 
The following information summarizes the off-site consequence analysis performed by the Ashtabula Plant: 
3.1 Toxic Substances -  
Hydrogen sulfide 
The "worst case release scenario" for hydrogen sulfide assumes the contents of a full railcar, 130,000#, are released to the atmosphere in ten minutes.  RMP*Comp Version 1.04 was used for the hydrogen sulfide worst case scenario to determine the off-site consequences.  Assuming a wind speed of  1.5 m/s, a 
F stability class and urban topography, the hydrogen sulfide cloud would travel 16 miles before reaching a hydrogen sulfide concentration below .042 ppm (which is the Emergency Response Planning Guideline value established in the RMP rule).  The U.S. Census indicates that 360,000 people live within this distance from the railroad car.  Public receptors located within this distance include schools, residences, hospitals, recreation areas, major commercial, office and industrial areas. No environmental receptors are located within this distance. 
The "alternative case release scenario" for hydrogen sulfide is the leak from a gasket or line failure of material from a pressurized pipeline.  The amount released is 400 pounds over a ten minute period.  This is the amount of hydrogen sulfide contained in the plant liquid hydrogen sulfide feed line.  This line is protected at both ends by emergency shut-off valves, activated by toxic gas monitors.  Assuming a wind speed of 3 meters/sec, a D  
stability class and urban topography, the hydrogen sulfide cloud would travel 0.3 miles before reaching a hydrogen sulfide concentration below .042 ppm (which is the Emergency Response Planning Guideline value established in the RMP rule).  The U.S. Census indicates that 420 people live within this distance from the pressurized pipeline.  Public receptors located within this distance include residences and a major industrial area.  No environmental receptors are located within this distance. 
The "worst case release scenario" for epichlorohydrin was not reported because the worst case scenario for hydrogen sulfide  results in a larger impact distance.  
The "alternative case release scenario" is the failure of the 1-1/2 inch pipe connecting the liquid epichlorohydrin tank to the process building releasing 3,000 lbs of epichlorohydrin vapor in a 60-minute period.  RMP*Comp Version 1.04 were used for alternative release scenarios to determine the off-site consequences.  A 
ssuming a wind speed of 3 meters/sec, a D stability class and urban topography, the epichlorohydrin cloud would travel 0.1 miles before reaching an epichlorohydrin concentration of below 0.076 ppm (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule).  The U.S. Census indicates that 44 people live within this distance from the storage tank.  Public receptors located within this distance include a major industrial area.  No environmental receptors are located within this distance. 
The "worst case release scenario" for epichlorohydrin was not reported because the worst case scenario for hydrogen sulfide  results in a larger impact distance.   
The "alternative case release scenario" is the failure of a valve on a partial ton cylinder releasing its remaining contents of 1,000 lbs of chlorine vapor in a 30-minute period.  RMP*Comp Version 1.04 was used for alternative release scenarios to determine the off-site consequences.  Assuming a w 
ind speed of 3 meters/sec, a D stability class and urban topography, the chlorine cloud would travel 0.1 miles before reaching an chlorine concentration of below 0.0087 ppm (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule). The U.S. Census indicates that 44 people live within this distance from the storage cylinders.  Public receptors located within this distance include a major industrial area.  No environmental receptors are located within this distance. 
3.3 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 the Specific Prevention Steps (' 68.155(d)): 
Program 3 is essentially the same as OSHA PSM, except that the program also focuses on protecting the pub 
lic and the environment outside the plant's fenceline; 
The following sections briefly describe the elements of the Ashtabula Plant's Program 3 prevention program that address EPA's RMP rule prevention program requirements. 
4.1 Program 3 Prevention Program 
The Ashtabula Plant's Program 3 prevention program consists of the following 12 elements: 
4.1.1  Process Safety Information  
The Ashtabula Plant maintains technical documents which 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.  OxyChem ensures that this process safety information is available to all employees.  
Material safety data sheets (MSDSs) document the physical properties of the hazardous materials handled at the plant, including regulated substances in covered processes. The informatio 
n 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 corrosivity data  
7 Thermal and chemical stability data  
7 Hazards of mixing substances in the process 
MSDSs for hazardous substances handled in each process are available from the plant's Safety Department and the ISO Coordinator. In addition, copies are maintained within the guard shack, the plant library and the main office building so that this information is accessible for all personnel.  In addition, key MSDSs are provided to the LEPC and upon request for use in helping formulate emergency response plans. 
Before the start-up of a new process, a document named a Special Quality Plan is developed.  This plan provides a central location for the key information about the process, and includes: 
7 Operating parameters (including safe upper and lower limits) 
7 Health, Environmental and 
Safety Information 
7 Process flow diagrams 
7 Process chemistry 
7 Material compatibility 
7 MSDS's for all raw materials, products, and co-products 
7 Proper protective equipment 
This document is used to train employees and complete process hazards analysis.   
In addition to the Special Quality Plan, engineering document files are maintained which include: 
7 Operating parameters 
7 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 Proper protective equipment 
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 basis for relief and ventilation systems 
Special quality plans are typically maintained for 1 year.  If the process is to continue beyond that time, the MSDS's and operating parameters are added to the common fi 
le and the remaining data is covered by the engineering file. 
4.1.2 Process Hazard Analysis 
The Ashtabula Plant performs and updates, within every 5 years as required by OSHA and the EHS rule, process hazard analyses (PHAs) of the covered process 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 "HAZOP" 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 before start-up. 
4.1.3 Operating Procedures 
Ashtabula Plant process engineers, operators and super 
visors 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 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 and normal shutdown.  They also include detailed instructions to follow in the event of a process upset.  The operating procedures are used both to help in operating the plant's processes  
and as a training guide.  In addition, the Ashtabula plant utilizes instruction logbooks to communicate on a daily basis.  These logbooks provide an opportunity to emphasize key points and request specific tasks. 
4.1.4 Training 
The Ashtabula 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 verify that an employee understands the training material before the employee can resume work in the process.   
4.1.5 Mechanical Integrity 
The Ashtabula 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 in 
spection and testing program to help identify equipment deterioration 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 for replacement parts and equipment  
7 Procedures for inspecting, testing and maintaining process equipment  
7 Procedures for safe work practices such as Lock, Tag and Try; Hot Work; Confined Space Entry; and Line Breaking 
7 Training of maintenance personnel  
7 Documentation of maintenance activities 
4.1.6 Management of Change  
The Ashtabula Plant management of change 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 replacemen 
t 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 Ashtabula Plant performs a safety review through our management of change procedures 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 includes a review of procedures and a walkthrough of the system to confirm 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 
Pre-start up safety reviews are completed for new processes, major modifications and/or start up of existing process equipment that has been shut down for more than 6 months. 
4.1.8 Compliance Audit 
Occidental Chemical audits covered processes to be certain that the prevention program is effectively addressing the safety issues of operations at the plant.  Occidental Chemical assembles an audit team that includes personnel knowledgeable in the PSM rule and in the processes.  The results of the audit are documented, recommendations are resolved and appropriate enhancements to the prevention program are implemented.   The audit of the facility programs, safety and environmental processes, and documentation is conducted at three year intervals.  Action plans resulting from the compliance audit are completed in a timely fashio 
4.1.9 Incident Investigation 
The Ashtabula Plant investigates incidents, including near misses, that could reasonably have resulted in a serious injury to personnel, the public or the environment so that similar incidents 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 within 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 Ashtabula Plant developed a written employee participation program 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.  Employ 
ees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHAs, MOCs and operating procedures.   
The plant supports its Safety Committee, a team of Ashtabula employees which includes operators, maintenance technicians and management.  Their purpose is to focus awareness on safety, both on and off the job, by working closely on safety issues, trouble-shooting problem areas and making recommendations to management. 
4.1.11 Hot Work Permits 
The Ashtabula 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.  A hot work permit is required for personnel who are to perform hot work in any area of the plant containing chemical hazards .  The Shift Supervisor or designated permit 
writer executes all the requirements of the hot work procedure before work can begin.  Training in the use of the Hot Work Permit Form is included in the plant's new hire orientation. 
4.1.12 Contractors 
The Ashtabula 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 employees who will work at the plant before that worker begins work at the plant site.  The plant periodically reviews contractors' training documents and conducts regular audits of the contractor's work performance to help ensure that s 
afe practices are followed. 
5.   Five-year Accident History (' 68.155(e)): 
The Ashtabula has experienced no releases of hydrogen sulfide, epichlorohydrin or chlorine in the past five years. 
6.  The Emergency Response Program (' 68.155(f)). 
The Ashtabula Plant has established a written emergency response plan and maintains an emergency response team trained in these emergency response procedures.  All plant personnel are trained in evacuation procedures. The written emergency response plan complies with the following federal and state contingency plan regulations: 
7 OSHA 29 CFR 1910.38(a) - Employee Emergency 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 Ashtabula Plant has an internal emergency response team.  Trained responders are on-site 24 hours per day to respond in plant chemical emergencies.  In addition, the Ashtabula Plant has developed a Special Situations Plan which is a program designed for responding to emergencies that may have impacts beyond the immediate plant and is a supplement to the Emergency Response Plan.  The Special Situation Plan links the local response to the OxyChem Corporate Emergency Response Center located in Dallas, Texas which can then provide assistance as needed. 
The facility is a member of the local emergency planning committee (LEPC) whose membership includes: 
7 Local Fire Departments 
7 Representatives from Area Industry 
7 Director of County Emergency Management Agency 
7 Local Sheriff's Department 
The LEPC meets every month and conducts annual training exe 
rcises of the emergency response plan.  
7.  Planned Changes to Improve Safety (' 68.155(g)). 
The Ashtabula Plant constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, and a program soliciting safety and environmental suggestions from the plant employees.  Our active safety committee works to focus awareness on safety, both on and off the job by working closely on safety issues, trouble-shooting problem areas and making recommendations to management.  These recommendations are evaluated by the committee and acted upon as appropriate to improve safety at our facility 
8.  Certification (' 68.185). 
To the best of my knowledge, information, and belief formed after reasonable inquiry, the information submitted in this RMP Plan is true, accurate, and complete. 
David A. Flautt, Plant Manager* 
* Signature included on attached hard copy.
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