Vanderbilt Chemical Corporation - Executive Summary |
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a.) Accidental release prevention and emergency response policy. Vanderbilt Chemical Corporation - Bethel Division's (VCC-Bethel) accidental release prevention policy is that all releases are preventable through good design, construction and operating practices. All accidental releases are reviewed and corrective actions are determined and implemented. The emergency response policy is that the on-site emergency response team will provide incipient response to an emergency and the local fire department will be used to respond to larger emergencies. b.) Stationary source and regulated substance handled. The stationary source is the carbon disulfide storage and delivery system at VCC-Bethel. Carbon disulfide is the regulated substance handled. c.) Worst-case scenario. The worst-case scenario is the failure of the 8,000 gallon carbon disulfide storage tank. The carbon disulfide is spilled into a 25 x 10 foot covered sump, which mitigates the release. The toxic cloud formed by the evaporating carbon disulfide would reach offsite endpoints and several nearby houses. Alternative-case scenario. The alternative-case scenario is the failure of the 1 inch carbon disulfide delivery line resulting in the release of the contents of the line. The size of the release is mitigated by automatic shutdowns on the pump if the line fails. The toxic cloud formed by the evaporating carbon disulfide would reach off-site receptors but not residences. d.) General accidental release prevention program and chemical-specific prevention steps. VCC-Bethel's general accidental release prevention program begins with designing the process equipment and writing operating procedures to prevent accidental releases and to mitigate the consequences if a release occurs. Process hazard analyses are performed on processes that contain hazardous chemicals. Pre-start-up safety reviews are also conducted. If an accidental release occurs, the root cause(s) of the release and corrective actio ns to prevent a future release are determined. The corrective actions are tracked to ensure that they are completed in a timely manner. The following specific steps were taken to prevent and mitigate the consequences of a carbon disulfide release: 7 Store carbon disulfide in a double-walled tank, with interstitial space monitoring. 7 High level alarm on the tank. 7 Tank and unloading area are located in a dike area which drains to a below grade covered sump. Water is maintained in the sump to prevent the evaporation of the carbon disulfide. Carbon disulfide is heavier than water and will be covered by the water layer that prevents vaporization. 7 The number of flanges in carbon disulfide service has been minimized by using welded piping. 7 The welds in the piping have been x-rayed. 7 The carbon disulfide pump will shut down if low pressure or low flow is detected in the line. These parameters indicate that there may be a leak in the line. 7 The carbon disulfide pump and valves are located in a box that is blanketed with nitrogen. The box will contain any leaks from the pump and valves. 7 The carbon disulfide storage area has an automatic deluge sprinkler system. 7 An operator continuously monitors unloading operations. 7 The carbon disulfide emergency shut down system may be remotely operated at all points of use. e.) The five-year accident history. There have been no releases or accidents (as defined by Risk Management Program guidance) associated with the carbon disulfide storage and delivery system in the past five years. f.) Emergency response program. VCC-Bethel's emergency response program includes the following: 7 Written emergency response plan that uses the incident command system 7 Trained emergency response team (approximately one third of the workforce) 7 Fixed sprinkler systems throughout the site 7 Routine drills for the emergency response team 7 Local fire department is less than one mile from the site g.) Planned changes to improve s afety. VCC-Bethel Division plans to improve safety at the site by making the following changes: 7 More frequent drills for the emergency response team 7 Drill with the local fire department 7 Upgrade plant security 7 Upgrade emergency response equipment 7 Conduct a third party audit of the site's safety procedures in 2000 |