Solutia Inc. - Decatur Plant - Executive Summary |
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RMP EXECTIVE SUMMARY Name of Company: Solutia Inc. - Decatur Plant Site Address: P.O. Box 2204, Highway 20 West, Decatur, Alabama 35609 Site Manager: Paul Meganck RMP Contact: Charles Chen Phone Number: 256-552-2809 Fax Number: 256-552-2214 Facility and Regulated Substances: Monsanto Company's chemical manufacturing facilities were spun off in September 1997 to form a new chemical company, Solutia Inc.. Solutia Inc. - Decatur Plant is one of the 18 chemical manufacturing facilities that make up the company, which has approximately 8,000 employees. Staffing at Decatur Plant is currently about 1,000 Solutia employees and 500 permanent contractor employees. Built in 1952, the Decatur Plant is situated on a 668 acre tract, 4 miles west of the City of Decatur, on the Tennessee River (river mile 302). Of the 668 acres, over 300 acres are presently in use. The plant primarily manufactures Acrilan acrylic fib er and various nylon intermediate chemicals for the production of nylon fiber. There are six chemicals in our processes that are regulated by EPA's Risk Management Program (RMP) rule. They are: Acrylonitrile (AN) ------------------- A raw material to make acrylic fiber and nylon intermediate chemicals. Propionitrile (PN) ------------------ A by-product from manufacture of nylon intermediate chemicals. Sulfur Dioxide (SO2) ------------- A raw material to make acrylic fiber. Vinyl Acetate (VA) ----------------- A raw material to make acrylic fiber. Vinylidene Chloride (VCL2) ---- A raw material to make acrylic fiber. Dimethylamine (DMA) ----------- A raw material to make acrylic fiber. Most raw materials (i.e., AN and VA) arrive at the plant by barge on the Tennessee River. Solutia Inc. has officially adopted the following six commitments, expressing our intention to operate responsibly: * We will ensure that our operations and distribution systems are safe for employees, visitors, site contractors, communities and the environment. * We will make products that are safe when used responsibly. * We will keep our operations open to our communities and foster open communications with all of our stakeholders. * We will continuously improve our raw material and energy utilization efficiencies, to reduce our impact on the environment and improve the sustainability of our businesses. * We will encourage active participation in and positive contributions to safety, health and environmental stewardship by our employees. * We will search worldwide for new technologies that bring environmental, safety and health value to all of our stakeholders. By acting on these commitments, we expect to match the best practices of our peer companies and to adhere to the Responsible Care guidelines developed by the Chemical Manufacturers Association. 1.0 Accidental Release Prevention and Emergency Response Poli cies At Solutia Inc - Decatur Plant, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP rule * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program 2.0 Stationary Source and Regulated Substances In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Note: The totals reflected below represent chemical in key process, storage, or transportation containers. A. Toxics Chemical Name Quantity (Tons) Container Use Acrylonitrile (AN) Process 2,000 Process Vessels Raw Material Storage 19 ,700 5 - Tanks Raw Material Transportation 3,600 1 - Barge Raw Material Propionitrile (PN) Process 35 Process Vessels By Product Storage 353 2 - Tanks By Product Transportation 85 1 - Railcar By Product Sulfur Dioxide (SO2) Process 5 Pocess Vessels Raw Material Storage 45 1- Tank Raw Material Transportation 20 1- Truck Raw Material Vinyl Acetate (VA) Process 122 Process Vessels Raw Material Storage 1218 1 - Tank Raw Material Transportation n/a* 1 - Barge Raw Material * Barge is always connected to the tug boat during VA unloading. B. Flammables Chemical Name Quantity (Tons) Container Use Vinylidene Chloride (VCL2) Process 21 Process Vessels Raw Material Storage 214 1 - Tank Raw Material Transportation 95 1 - Railcar Raw Material Dimethylamine (DMA) Process 9 Process Vessels Raw Material Storage 86 2 - Tanks Raw Material Transportation 180 3 - Railcars Raw material Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 3.0 Key Offsite Consequence Analysis Scenarios Decatur Plant uses JBF's RMPlanner software (version 2.0) to perform the offsi te consequences analyses required under the RMP rule, which implements section 112 r of the 1990 Clean Air Act Amendments. EPA's RMP rule requires that we provide information about the worst-case release scenarios and alternative release scenarios for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: 1. For worst case scenarios (WCS): Acrylonitrile (AN) -------------- 17,776,000 lbs ----- >25 Miles Propionitrile (PN) ---------------- 706,000 lbs ----- >25 Miles Sulfur Dioxide (SO2) -------------- 90,000 lbs ----- 9.7 Miles Vinyl Acetate (VA) -------------- 2,436,000 lbs ----- 3.3 Miles Vinylidene Chloride (VCL2) ----- 428,000 lbs ----- 0.37 Mile Dimethylamine (DMA) ------------ 120,000 lbs ----- 0.37 Mile Description of WCS: AN ------- Catastrophic loss of the largest vessel (No. 3 Bulk AN Storage Tank) with the maximum possible amount in the tank at the time of Its failure PN -------- Catastrophic loss of the largest vessel (PNT or RCRA Tank) with the maximum possible amount in the tank at the time of Its failure SO2 ------ Catastrophic loss of the largest vessel (SO2 Storage Tank) with the maximum possible amount in the tank at the time of Its failure VA ------- Catastrophic loss of the largest vessel (VA Storage Tank) with the maximum possible amount in the tank at the time of Its failure VCL2 --- Catastrophic loss of the largest vessel (VCL2 Storage Tank) with the maximum possible amount in the tank at the time of Its failure DMA ---- Catastrophic loss of the largest vessel (DMA Railcar) with the maximum possible amount in the tank at the time of Its failure 2. For alternative release scenarios (ARS): Acrylonitrile (AN) ---------------- 166,667 lbs ----- 3.8 Miles Propionitrile (PN) ------------------ 11,100 lbs ----- 3.8 Miles Sulfur Dioxide (SO2) ----------- 42,180 lbs ----- 1.6 Miles Vinyl Acetate (VA) ------------- 46,667 lbs ---- 0.98 Mile Vinylidene Chloride (VCL2) ---- 7,500 lbs ----- 0.064 Mile Dimethylamine (DMA) ----------- 7,500 lbs ----- 0.097 Mile Description of ARS: AN ------ 12 Inch AN Transfer Line from Barge Breaks for 10 Minutes PN ------ Line Ruptures While Loading Refined PN Railcar for 5 Minutes SO2 ---- 1 Inch Hole in SO2 Storage Tank; 10 Inch Liquid Above Hole; Leaks for 60 Minutes VA ------ 6 Inch VA Transfer Line from Barge Breaks for 10 Minutes VCL2 --- 3 Inch VCL2 Transfer Line from Railcar Breaks for 10 Minutes DMA --- 3 Inch DMA Transfer Line from Railcar Breaks for 10 Minutes 4.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity Program * Management of change Process * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Acrylonitrile (AN) * Low level alarm on the tank would be triggered. The area is also visually inspected at least twice daily. ACAM sensors (sump sniffers) on the transfer pumps may be triggered depending on wind direction. * Tank dike would minimize the release of material. Check valves on the discharge side of the transfer pumps would prevent material from flowing back into the tank. * An operator would notify the site coordinator immediately. Cleanup would be handled by the HAZMAT team. Propionitrile (PN) * ACAM system would alarm due to high PN concentration in the air. The sump level alarm would trigger. This alarm can only be turned off at a location next to the tank, so someone would have to notice the release while acknowledging the alarm. Low level alarm on the PNT Tank would go off. The area is inspected at least twice daily. * Tank dike would contain the material and prevent ground contamination. Check valves on t he discharge side of the transfer pumps would prevent material from flowing back into the tank if the release occurred while loading a railcar. * An operator would stop the flow of material into the tank and immediately contact the site coordinator. Cleanup would be handled by the HAZMAT team. Sulfur Dioxide (SO2) * Four SO2 Monitors Around Tank Alarmed in NCP Control Room * Diked Storage Area; HAZMAT Team; Routine Vessel Inspection * Acquire Proper PPE; Turn in Emergency Alarm; Notify Site Coordinator; Evacuate Area Downwind of Tank; Notify Appropriate Agencies; Water Spray (HAZMAT Team) Vinyl Acetate (VA) * Human Observation * Dike; HAZMAT Team; Routine Vessel Inspection * Acquire Proper PPE; Turn in Emergency Alarm; Notify Site Coordinator; Evacuate Area if Necessary; Close Valves to Polymer Areas; Notify Appropriate Agencies; Apply Foam to Entire Area Until Material Can Be Disposed of Vinylidene Chloride (VCL2) * Human Observation * HAZMAT Team; Routine Vess el Inspection * Acquire Proper PPE; Turn in Emergency Alarm; Notify Site Coordinator; Evacuate Area if Necessary; Pull Deluge System; Notify Appropriate Agencies; Water Spray (HAZMAT Team) Dimethylamine (DMA) * Human Observation * HAZMAT Team * Acquire Proper PPE; Turn in Emergency Alarm; Notify Site Coordinator; Evacuate Area if Necessary; Close Valve on Liquid Unloading Line and at Storage Tank; Notify Appropriate Agencies; Water Spray (HAZMAT Team) These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5.0 Five-year Accident History There were not any agency reportable spills/releases of the six RMP-covered chemicals in the last five years.. 6.0 Emergency Response Program We at Solutia use several types of safety audits to ensure that our plant runs safely. Following are some of the different types of audits, inspections and reviews that are conducted: PSM and Non-PSM audits, ISO audits, Corporate and Insurance surveys and audits,, Environmental and IndustrialHygiene audits, Management of Change audits. We conduct pre-engineering safety audits and inspections on new process before any engineering work is done. During the phase of construction walkthrough safety inspections are completed. Pre-startup inspections are done before the process is started. Solutia at Decatur, Alabama is very dedicated in preparation just in case we might have an emergency. We have 75 firefighters across the 4 shifts that we work. These firefighters train 48 hours annually at the site on things like flammable liquid fires, interior fire fighting, hazardous communications, incident command and others. Our firefighters also train at Texas A&M Fire School on similar item s but larger projects. We have two fire trucks that are equipped with foam and dry chemical extinguishing agent to supplement the 6 fire pumps that draw fire water from the river. Currently we are working on a $3 million fire water upgrade project to increase our pumping capacity. Currently we have 28 EMTs training 56 hours annually on trauma assessment, burn care, confined space rescue and others. We have a fully stocked ambulance readily available should we need to transport any of our employees to a local hospital. Our EMTs train on confined space rescue on site at the training center in Mobile Alabama. We have (9) nine Hazardous Materials Specialist that respond to on site and to off site chemical emergencies . These dedicated people are trained to handle both railcar and highway emergencies. They train more than forty hours annually on chemical data, shipping containers, vessels, tanks and incident command. We have a fully stocked emergency van that carries supplies tha t the Specialist use to control any chemical emergencies. Our Site spends countless thousands of dollars protecting the employees and environment by maintaining 150 automatic sprinkler systems, 27 smoke detection systems, 6 fire pumps and miles of underground fire mains, gaseous fire suppression systems, hundreds of fire extinguishers and other protection equipment. Solutia formally Monsanto is a charter member of the Local Emergency Planning Committee (LEPC) and has a representative on the Executive Steering Committee of this organization. We are a charter member of the Industrial Emergency Association (IEA) and have a representative on the Emergency Response Committee of the same. Participation in planning and execution of community drills through our membership in these two organizations has always been rewarding. Solutia has a good working relationship with other Industrial Plants and emergency responders from the City of Decatur. We invite representatives from local indust ries and fire fighters from the City of Decatur to tour the plant annually. During these visits we exchange ideas about various items and take the opportunity to train together on live fire fighting exercises at our training facility. There is an on-site emergency response team trained to handle all chemical incidents. Any chemical incidents that may have off-site impacts are reported to the Morgan County Emergency Management Agency (EMA) which can initiate a county-wide emergency alerting system. We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. 7.0 Planned Changes to Improve Safety The following is a list of improvements that we a re planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: * Maintain a capital and maintenance program to enhance reliability of operating units, therefore reducing upset conditions. * Maintain OSHA Star Status * Maintain ISO 9000 Status 8.0 Certification Solutia Inc. - Decatur Plant has no Program 1 or 2 process. To the best of the undersigneds knowledge, information, and belief formed after reasonable inquire, the information submitted is true, accurate, and complete. Paul Meganck Signature Print Name Site Manager Title Date 9.0 RMP Data The following pages present additional inf ormation about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: Registration Offsite consequence analysis Five-year accident history Program 3 prevention program Emergency response program |