PPG Industries Inc., Lake Charles Plant - Executive Summary |
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EXECUTIVE SUMMARY CHLORINE & CHLORINATED HYDROCARBON PROCESSES LDEQ Facility ID: 1255 PPG Industries Lake Charles, LA Accidental Release Prevention and Emergency Response Policies. The PPG Lake Charles facility complies with OSHAs Process Safety Management Rule (29 CFR 1910.119), applicable Louisiana and federal EPA regulations, and applicable Coast Guard and Department of Transportation requirements. PPG also follows the Responsible Care. Codes of Management Practice, including the Responsible Care. Community Awareness Code of Management Practice, and PPGs own Community Awareness and Emergency Response (CAER) Policy to assure emergency preparedness and foster community right-to-know. PPGs CAER Policy requires each manufacturing plant to have a pro-active community awareness and emergency response program to handle emergencies that might happen in that facility. All of these activities form an integral part of PPGs overall Environment, Health and Safety Policy, whose goal is to manufacture, sell, and distribute products worldwide in a manner that is safe and protective of our employees, neighbors, customers and other stakeholders, and the environment. Regulated substances handled. PPGs Lake Charles facility is part of the Chemicals Strategic Business Unit of PPG Industries, Inc. The facility produces chlorine, caustic soda, silica products and various chlorinated hydrocarbons. These chemicals are utilized in many areas such as water treatment, food processing, medicines, plastics and freon substitutes. The chlorine production process manufacturers chlorine in quantities that meet EPA Risk Management Program threshold quantities. A second process, Chlorinated Hydrocarbons, manufactures or stores chlorine, ethyl chloride, vinylidene chloride, vinyl chloride and ammonia in quantities that meet EPA Risk Management Program threshold quantities. Worst-case and alternative case release scenarios. The EPA RMP rule requires that a worst case scenario be analyzed which would involve the release both of toxic and flammable materials. The EPA RMP guidelines and an Offsite Consequence Analysis look-up table were utilized in this analysis. Chlorinated Hydrocarbon Process Worst Case Scenarios: 1. The worst-case release scenario for a flammable involves a vapor cloud explosion of a vinyl chloride storage tanks inventory. Administrative procedures are in place that limit the inventory to 90 % of the tanks total capacity. The EPA defined endpoint for this analysis is estimated to be beyond the plant boundaries. 2. The worst-case for chlorine involves the vaporization of a chlorine lines contents. The EPA defined endpoint for this analysis is estimated to be beyond the plant boundaries. 3. The worst-case for ammonia involves the vaporization of a storage tanks contents. Administrative procedures are in place that limit the inventory to 90% of the tanks total capacity. The EPA defined endpoint for this analysis is estimated to be beyond the plant boundaries. The Chlorine Process Worst-Case Scenario: 1. The worst case for the Chlorine Process involves the vaporization of a chlorine tanks inventory over ten minutes. This inventory is limited to 90 % of the tanks capacity through administrative procedures. The EPA defined end point for this analysis is estimated to be outside of the plant boundaries. 2. No flammables are present in the Chlorine Process that meet the EPA Risk Management Program requirements. Alternative case release scenarios were developed for each of the listed chemicals in the facility. These scenarios followed the guidelines provided by EPA and used the dispersion modeling program PHAST Version 5.01. Chlorinated Hydrocarbons Process Alternative Release Scenarios: 1. An alternative case release scenario was developed for ammonia which utilized information on physical location, detecti on methods, equipment layout and expected response times. This analysis indicated that an end point concentration would not extend beyond the boundaries of the plant. A second alternative release scenario was developed for chlorine which indicated that the EPA defined endpoint would be outside the plant boundaries. 2. An alternative release scenario representing all flammables in the Chlorinated Hydrocarbons Process was developed using vinyl chloride and all the appropriate information. This analysis indicated that an endpoint pressure would extend beyond the boundaries of the plant. Chlorine Process Alternative Release Scenario: An alternative release scenario was developed for chlorine which utilized the appropriate information concerning physical location, detection methods, equipment layout and expected response times. This analysis indicated that an end point concentration would extend beyond the boundaries of the plant. General accidenta l release prevention program and chemical specific prevention steps. Personnel and environmental, health and safety measures are included in all phases of the PPG Lake Charles operation. Detailed engineering and design standards are used. These standards may include national codes and standards, quality assurance inspections, over pressure protection systems, flammable and toxic gas detectors, emergency shutdown systems, a fire water system, computer controls for the processes and a procedure to systematically analyze potential hazards in each new process. Employees at the facility receive job-appropriate training. Training includes periodic retraining, as appropriate. Safety, environmental, operating and training procedures are subject to periodic reviews and updates. Additional systems are in place to review proposed changes and assure that any new training requirements are met. Another system assures a detailed review for hazards in each operating unit on a prescribed fre quency. All of the training and updating procedures are monitored. PPGs Lake Charles facility has an array of maintenance and inspection programs that minimize the possibility of equipment or piping failures. Periodic equipment inspections are performed to assure the equipment integrity. The inspections utilize recognized codes and procedures that are followed by specially trained individuals. Preventive and predictive maintenance programs are utilized and can include vibration monitoring, infrared imaging, inspections by independent experts, inspections by insurance specialists and root-cause analysis investigations. Piping systems are inspected and tested with X rays and hydrostatic tests prior to operation. The piping is monitored by a variety of methods to assure its condition. Maintenance personnel are included in many of the training and testing programs that the operators utilize. Additional training and procedures have been developed for activities that are specific t o maintenance. Five -year accident history. An accidental release of ethyl chloride occurred in August of 1998 in the Chlorinated Hydrocarbons Process. No injuries occurred but, the public roadways adjacent to the plant were closed as a precautionary measure. An accidental release of chlorine occurred in December of 1996 in the Chlorine Process. No injuries occurred but, a chlorine odor was detected in neighboring industrial plants. Emergency response program. The PPG Lake Charles plant has developed an emergency response plan that includes: 7 permanent fire protection systems, 7 mobile fire fighting and hazardous material handling equipment, 7 training for employees and emergency responders, 7 a computer modeling system linked to an on-site weather station that can predict the movement of air borne materials, 7 communication links with the Calcasieu Parish Office of Emergency Planning, 7 a coalition with other industries in the area that makes their response e quipment and people available if needed, 7 a coalition with chemical manufacturers throughout the country which accesses any individual in any company that has knowledge or training that might be useful in an emergency, and 7 participation in the Local Emergency Planning Committees plans for the entire community Notification requirements are defined and assigned to specific individuals in the plant. Some of the people work a rotating shift allowing notifications 24 hr. a day. Other people have pagers and cellular phones to allow them to be contacted at any time. PPG has a corporate emergency system that can be accessed at any time. This corporate system has additional resources for use in an emergency. Planned changes to improve safety. PPG is committed to the process of continuous improvement. This commitment extends beyond production into the environmental and safety aspects of our operations. |