Pioneer Chlor Alkali Company, Inc. - Executive Summary |
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2644 LDEQ Facility ID Number Introduction Pioneer Chlor Alkali Co., Inc.'s St. Gabriel facility is located on approximately 45 acres, 12 miles south of Baton Rouge, LA. The main products produced at St. Gabriel are chlorine and sodium hydroxide. Chlorine is an element which occurs naturally as sodium chloride (table salt). An important use of chlorine is purification of drinking water. Other uses for chlorine include hospital sanitation, swimming pool treatment, and laundry bleach. Chlorine is a basic building block for production of many consumer products such as vinyl siding for houses, PVC pipes for plumbing, and over 85% of medicines and other pharmaceuticals made today. Sodium hydroxide is used to make products as diverse as soap, latex paint, rayon and nylon clothing, and many other items such as toothbrushes, fishing line, cellophane wrap, and aspirin. Pioneer's environmental and safety and health policies recognize the importance of safeguarding the environment and the community from receipt of raw materials through manufacture of our products and distribution to our customers. Programs are in place to ensure compliance with regulations and continuing improvement of performance over the years. Facility personnel are trained extensively in safe operation of the facility and in maintaining compliance with all applicable regulations. Chlorine is the only chemical at the facility which falls under the RMP regulations although Pioneer has practiced risk management and prevention for many years. Pioneer was the first OSHA VPP (Voluntary Protection Program) Star site in Louisiana, and has maintained that rating since 1985. This entails a complete audit by OSHA of our entire Safety and Health programs every 3-4 years. Pioneer employees have gone 21 years without a lost-time injury. Pioneer received the EPA's Environmental Excellence Award in the area of air compliance in 1998 as well as becoming one of twelve finalists for the Chemical Education Foun dation's Product Stewardship Award. As can be seen from these statistics, Pioneer's commitment to safety and risk prevention has long been an important part of our operation. Prevention Program The facility has developed a comprehensive accidental release prevention program based on the elements of OSHA's Process Safety Management Program. Each of the 12 elements is fully implemented and integrated into the standard operating practices of the plant. Summarized below are brief descriptions of each of the elements: Process Safety Information--Critical information on chlorine properties, chlorine production techniques, and chlorine handling is made readily available to facility personnel through Material Safety Data Sheets, current drawings, and comprehensive operations manuals. Additionally, the Chlorine Institute provides information and guidelines in the form of regularly updated technical pamphlets. This information is used as the basis for many of our operating procedures and chemical process systems. Process Hazard Analysis--The facility performs extensive Process Hazard Analyses on an established schedule. A trained team rigorously scrutinizes the operating processes and makes recommendations for safety enhancements. The recommendations are then prioritized and implemented accordingly. Operating Procedures--Clear and concise instructions have been developed by teams of experienced personnel for all facility operations. The operating instructions are kept current by regularly scheduled annual review, and by integrating the Management of Change procedures. Training--We have a thorough training program in place that is designed to train operations personnel on the technical aspects of the processes as well as leading them step by step through the operating instructions for each job. The program also provides ongoing training and refresher courses to continually enhance the capabilities of all plant employees. All training is documented to ensure comp letion. Mechanical Integrity--The Mechanical Integrity program in place at the plant is specifically designed to keep our equipment in viable condition. Trained maintenance technicians ensure that all pipes, tanks, valves, and other equipment involved in chlorine service are maintained and rigorously inspected on an established schedule. Recommendations from equipment inspections are then prioritized and implemented accordingly. Management of Change--Written procedures are in place to ensure that all process changes at the plant undergo several levels of review at the planning stage. No changes are made without review by a team that includes operations and maintenance personnel. Once a process change has been made, systems are in place to make sure that communication of the change will be made to any who may be affected. Pre Start Up Reviews--Before being placed into service, any new or modified system is thoroughly reviewed by a team composed of a cross section of plant employ ees. This review is designed to ensure appropriate design, adequate safety systems, and sufficient training. All recommendations from the review are then completed before start up. Compliance Audits--As a Star Plant in the OSHA Voluntary Protection Program, we are subjected to a meticulous audit on a three-to-four year cycle by a highly trained team, including industry representation, from the agency. Recommendations from the audits are promptly converted into action plans. Incident Investigation--Significant environmental, safety, or health incidents at the facility are fully investigated by appropriate teams to determine root cause and to put in place action plans designed to prevent recurrence. The findings are documented and communicated to facility personnel. Employee Participation--Employee participation is the cornerstone of the Voluntary Protection Program. Plant operators, maintenance technicians, and engineers, as well as supervisors and managers participate fully in Hazard and Operability Studies and incident investigations. All findings and recommendations are made available. A broad range of facility personnel also make up the safety committee and participate in a wide range of safety related activities. Hot Work--The facility's Hot Work procedure requires that detailed permitting activities take place before, during, and after any job that has the potential to provide a source of ignition. Contractor Safety--The contractor safety program, in place at the plant, places stringent qualification requirements on contracting firms. To become qualified to work at the facility, contractors must provide proof of training that matches our tough requirements. Additional facility specific training is then required before any contract work can take place. Contractor safety performance and compliance with facility safety requirement are monitored closely during all contract projects. Emergency Response Program The St. Gabriel Pioneer facility has in place a comprehensive written Emergency Action Plan. The plan provides for 24 hour/day, 365 day/year response capabilities. The plant responders are trained and qualified on the proper response techniques and are equipped with the necessary equipment to perform critical response procedures. As part of the ongoing training program for responders, we regularly perform readiness drills. These include both table-top planning sessions as well as full field responses to simulated incidents in the plant. Additionally, we conduct joint drills with the Iberville Parish Office of Emergency Preparedness and work closely with that office to coordinate emergency response actions. Pioneer is also an active member of the Geismar Area Mutual Aid group which provides resources for emergency response to other area facilities. The plant is equipped with a facility-wide alarm system. As soon as the alarm system is triggered, response teams assemble immediately, including those assigned the task o f making critical notifications. Current emergency phone numbers are maintained in the control room of the facility and also in the Emergency Action Plan, which is immediately available in several critical areas of the plant so that timely notifications can be made. Another key safety feature at the plant is the facility-wide chlorine monitoring network which can detect chlorine at very low concentrations. Operations personnel monitor the real-time readings from the chlorine sensors and will respond immediately to any detection. Additionally, the facility utilizes a computer modeling system that can help to plan potential scenarios and develop appropriate responses. Hypothetical Models The Environmental Protection Agency has defined the worst case scenario as the hypothetical rupture and full release of all contents of the facility's largest storage tank, assuming all safeguards have failed, during extremely stable weather conditions. While the probability of this scenario comin g to pass at any facility is extremely low, it does provide a template for emergency response planning. The computer-generated model for our largest chlorine tank results in a planning zone of 25 miles. Each facility must also prepare an alternate scenario that could have an off-site impact, based on plant operations. The Alternate Scenario may take into account emergency response control measures and actual storage and weather conditions. After a thorough review of our facility, we have selected the hypothetical rupture of a loading line while actively loading a chlorine rail car. For planning purposes only, it is assumed that the check valve on the rail car does not engage. The computer-generated model for this release results in a possible impact of up to 4.9 miles. It should be noted that a loading hose did once fail, but the check valve on the rail car worked properly. Less than 6% of the amount modeled for the alternate scenario was actually released. As a result of that incident, many additional safeguards have been added to prevent this type of incident from happening in the future. Five-Year History There are two incidents in the facility's five-year accidental release history. In both instances, the community near the plant sheltered in place. In one instance, two people were treated and released from a near-by hospital. As per our procedure, thorough investigations were performed to determine the causes of each of the incidents. The investigations were followed by responsible implementation of corrective action plans to ensure that there would be no recurrences. Safety Improvements We believe that continuous improvement is the key to success in the future. This is especially true in the safety, health and environmental areas. Our philosophy is to continuously look for opportunities to improve our abilities in protecting our people and our community. We actively solicit and implement safety and process improvement suggestions through ou r safety committee, our employee suggestion program, and our Total Quality Improvement program, which uses cross-functional teams to solve problems and implement solutions. A few recent examples of our ongoing safety improvement efforts include: * Installation of pipeline to customers, reducing rail car loading and transportation over 90% * Comprehensive Y2K readiness evaluation * Installation of new tail gas neutralizer * Upgrade of wastewater treatment system to recover mercury and return it to the process rather than going off-site for disposal in waste * Equipment design changes within the cell house to reduce emissions We aim to further enhance our partnerships with regulatory agencies and local responders, as well as with other industrial facilities, in the common goal of protecting our employees, our communities, and our futures. Pioneer has been an active member of the community advisory panel and the local emergency planning committee and will continue to be so in the futur e. |