Rhodia Inc. - Executive Summary

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Rhodia Inc. 
Rhodia is strongly committed to the safety of its employees, the public, and the environment.  This safety commitment is demonstrated by a comprehensive accidental release prevention program, covering all areas of Plant operations, from the design and installation of equipment to the operating procedures, maintenance practices, and employee training.  Rhodia's policy is to implement appropriate controls to prevent the accidental release of regulated substances. 
Safety and environmental excellence is one of the values that define Rhodia's culture.  All Rhodia employees are challenged to commit themselves to safety and environmental excellence and to integrate total safety into all work practices.  Every job, activity, and routine operation at the Plant is conceived, planned, and implemented in a manner that will ensure the health and safety of all involved and comply with all local, st 
ate, and federal regulations.  Rhodia's "Stop Work Policy" empowers and obligates all employees and contractors to immediately stop work if there is a health, safety, or environmental concern.  At no time is any Rhodia employee, contractor, or visitor compelled to undertake any action that he or she feels may endanger anyone's health or safety. 
If an unexpected release of a hazardous chemical were to occur, trained emergency response personnel are prepared to control and mitigate the effects of the release.  In addition to the emergency response team, all Plant employees are trained as hazardous material technicians requiring 40 hours of initial training and 8 hours of refresher training annually.  Rhodia's corporate nationwide Distribution Assistance Response Team (DART) is also trained and equipped to handle chemical emergencies and includes a network of experts such as toxicologists and other technical professionals who are available to assist the Plant, as well as provide informat 
ion to the community and outside emergency response agencies.  The Plant has coordinated emergency response planning with the Hammond Fire Department, the Hammond Department of Environmental Management, and the East Chicago Fire Department, who provide additional emergency response expertise. 
Since the industrial revolution, sulfuric acid has been the most widely consumed industrial chemical.  In the late 1800's, Stauffer Chemical began producing sulfuric acid from sulfur.  When World War II caused a sulfur shortage, Stauffer pioneered technology for recycling used or "spent" sulfuric acid.  In the recycling process, waste acids and other sulfur derivatives are regenerated into high purity commercial grade sulfuric acid, and returned for re-use.  Refiners use sulfuric acid in the production of "clean burning" gasoline with less vapors, and no lead.  A single refinery can produce as much as 500 tons per day of spent sulfuri 
c acid.  In the late 1980's, Rhone-Poulenc acquired Stauffer Chemical and became the world leader in the regeneration of spent sulfuric acid with seven U.S. plants and three in Europe.  With operations in more than 140 countries, Rhone-Poulenc is the world's seventh largest chemical and pharmaceutical company. 
John Stauffer built the Hammond Plant in 1929 to produce sulfuric acid for neighboring Shell Oil Company and other nearby industries.  In 1957, a sulfuric acid regeneration unit was built at the Hammond site.  Today, the Hammond Plant still makes sulfuric acid from spent acid and sulfur. 
Sulfuric acid regeneration requires thermal decomposition ("burning") of the acid to sulfur dioxide, and remaking the acid through chemical reaction.  The sulfuric acid regeneration furnace is the ideal place to process pumpable industrial wastes for their energy value.  The waste products are destroyed and heat is produced for efficient operation of the regeneration furnace.  The facility has  
been burning Resource Conservation and Recovery Act (RCRA) waste since 1980.  Rhodia is no longer in the sulfur dioxide and sulfur trioxide business, therefore, we do not store or transport either of these inorganic chemicals. 
The Hammond Plant's primary activities encompass regeneration of sulfuric acid, as well as the thermal destruction of hazardous and nonhazardous wastes.  The only substance regulated by the Risk Management Program (RMP) for Accidental Chemical Release that may, at times, be present at the Plant in a quantity that exceeds the threshold quantity (TQ) is chloroform.  The chloroform is part of a mixture of waste organic solvents that are processed for their energy value and for thermal destruction in the industrial furnace.  These waste solvents are stored on site in low pressure tanks or tank trucks for a short period of time for testing before they are burned in the industrial furnace.  Chloroform may exceed the TQ of 20,000 pounds while in storage.  The maximum i 
nventory of chloroform that is expected to be present in this facility is 28,600 pounds. 
Because Rhodia thermally destroys mixtures of hazardous and nonhazardous industrial wastes to produce heat, many other organic compounds may be encountered.  These mixtures may contain other RMP-regulated chemicals; however, none of these chemicals is present under conditions such that its TQ is exceeded.  These other regulated chemicals may be present in the mixtures at a concentration less than one percent, possess low vapor pressures, or may not represent a serious fire hazard (e.g., NFPA1 rating below 4).  In these situations, EPA has determined that the risk posed by the substance is sufficiently low and that inclusion in the Plant's RMP is not required.  However, Rhodia's accidental release prevention and emergency response policies are applied to all of the substances handled at the Plant, whether or not they are required to be included in the RMP. 
The Treatment Services waste storage process includes two 55,000-gallon tanks and four 8,000-gallon tanks, two truck direct burn bays, as well as the pumps and piping to deliver the waste solvents to the industrial furnace.  Historically, releases of waste solvents from storage systems most often occur from leaking pump seals or valves, leaks at piping connections, or inadvertent releases during loading or unloading activities.  While these incidents can impact employees, they seldom lead to a release of a reportable quantity or result in an off-site impact. 
Consistent with the RMP rule requirements, two specifically defined release scenarios (a worst-case release and an alternative release) were analyzed to determine the maximum distance to an endpoint where the chloroform concentration is 0.49 milligrams per liter (mg/l) in air, which equates to 100 parts per million, or 0.01 percent.  This endpoint represents the maximum airborne concentration below which nearly al 
l individuals could be exposed for up to 1 hour without experiencing or developing irreversible effects or symptoms that could impair their ability to take protective action. 
The release scenarios analyzed are based on the guidance contained in the USEPA's Risk Management Program Guidance for Offsite Consequence Analysis (the "OCA Guidance"), dated April 1999.  This guidance document includes "lookup" tables that relate the quantity and rate of chloroform released to the distance to the endpoint. 
3.1    Worst-Case Release 
The worst-case release is defined by the catastrophic rupture and complete loss of the maximum contents of one of the 55,000-gallon storage tanks when it is full of the waste containing the maximum concentration of chloroform (approximately 28,600 pounds of chloroform).  The liquid waste from the tank is considered to spread instantaneously to cover the area inside the dike around the storage tanks.  The chloroform is then considered to evaporate from the surface of t 
he liquid pool formed inside the dike and disperse into the atmosphere.  Using the specified worst-case meteorology contained in the OCA Guidance, the distance to the endpoint for a worst-case release was estimated to be 0.2 mile or 1056 feet. 
Although the worst-case consequence analysis is required by the RMP regulations, such a release should be considered a highly unlikely event.  Design, construction, and operation of the storage tanks are such that catastrophic failure is extremely remote. 
The worst-case release scenario is unlikely for the following reasons: 
* The tank is vented to a control device to maintain the tanks at basically atmospheric pressure, so internal pressure would not be able to increase to a level great enough to rupture the tank. 
* Rupture of the vessel from the outside as a result of inadvertent vehicular contact is unlikely since the unit is surrounded by a 3-foot high dike. 
* The worst-case weather conditions which were used for the atmospheric disper 
sion modeling of this scenario are uncommon; 
* Industry standards were followed for the manufacture and quality control of the storage tanks; 
* Atmospheric vents limit operating pressures; 
* The facility has a preventive maintenance program in place to maintain the ongoing integrity of the storage tanks; 
* The facility has a training program designed to ensure that the process is operated by qualified personnel; 
* The facility has emergency response procedures which enable trained personnel to respond quickly to isolate any potential releases. 
3.2    Alternative-Case Release 
The alternative, or "more likely", scenario is considered to be defined by a release of the waste solvent mixture containing chloroform due to a line break in the 1-inch pipe carrying the mixture to the industrial furnace.  The pump delivers 1,200 lbs./min. of the mixture and the release would be stopped within 15 minutes, resulting in 18,000 pounds of the mixture or 1,170 pounds of chloroform being releas 
ed.  The pipeline travels within the diked area around the storage tanks, so the passive mitigation2 provided by the dike was considered in this scenario.  Active mitigation3 was also considered, because it is believed that emergency responders could identify and stop the leak in less than 15 minutes.  As in the worst-case scenario, the released liquid would form a pool inside the dike, from which the chloroform would evaporate and disperse into the atmosphere. 
Using the specified meteorology contained in the OCA Guidance, the distance to the endpoint for the "more likely" release scenario was estimated to be less than 0.1 mile or less than 528 feet. 
The alternative-release scenario is unlikely for the following reasons: 
* Industrial standards were followed for the manufacture and quality control of the pipeline; 
* The pipeline travels within the diked area which minimizes potential damage from vehicles; 
* The facility has a preventive maintenance program in place to maintain th 
e ongoing integrity of the system; 
* The facility has a training program designed to ensure that the process is operated by qualified personnel; and 
* The facility has emergency response procedures which enable trained personnel to respond quickly to isolate any potential releases by closing valves and/or shutting down pumps or other equipment, as appropriate. 
The facility has carefully considered the potential for accidental releases of hazardous chemicals including chloroform, such as the occurrence of the worst-case and alternative-release scenarios described in Section 3.0.  The facility was designed and constructed in accordance with RCRA (40 CFR 264) and NFPA Standard 58, Liquefied Petroleum Gas Code, 1967 edition.  To help minimize the probability and severity of an accidental chemical release, a prevention program that satisfies the Occupational Safety and Health Administration, Process Safety Management of Highly Hazardous Chemicals standard (29 CF 
R 1910.119) has been implemented.  The key components of the prevention program are summarized below: 
* Critical process safety information regarding chemical hazards, the design basis of the process, and the equipment has been developed and documented.  This information is available to all process operators and used to fully understand and safely operate the process. 
* An employee participation program, which includes employees from all levels of the organization and from all areas within the plant (i.e., production and maintenance) has been developed.  The employees that are most knowledgeable about the processes are best able to easily, effectively, and regularly recommend changes or improvements that enhance safety. 
* The performance of a formal process hazard analysis (PHA) using the "What-if..." technique.  A team with expertise in engineering, operations, maintenance, and safety evaluates the existing process in depth and develops recommendations to improve the safety and o 
perability of the processes.  The PHA addresses:  (1) process hazards, (2)  previous incidents, (3) engineering and administrative controls applicable to the hazards, (4)  the consequence of control failure, (5) facility siting, (6) human factors, and (7) a qualitative evaluation of possible safety and health effects of control system failures.  The PHA generally results in multiple procedural and/or hardware recommendations to improve the safety and operation of the system.  These recommendations are then implemented in a timely manner.  The PHA is updated and revalidated every five years. 
* Written operating procedures (OPs) are maintained to provide the basis for proper and safe operation of the process.  The OPs include procedures for normal operation, startup, shutdown, emergency operation, and emergency shutdown.  They also describe safe operating limits for temperature and pressure, the consequences of operating outside these safe operating limits, and a description of safety  
systems and how they operate. 
* Process operators receive refresher training at least annually, or more frequently as needed.  The training content is based upon the process safety information and operating procedures.  The training program ensures that the operators understand the nature and causes of problems arising from process operations and serves to increase awareness with respect to the hazards particular to chloroform. 
* Documented maintenance checks are performed on process equipment to ensure proper operations and mechanical integrity.  Process equipment examined by these checks include pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in  
a safe and timely manner. 
* Formal authorization systems (i.e., management of change procedure, pre-startup safety review) are in place to ensure that process changes or expansions are as safe as the original design and that an independent recheck, prior to start-up, confirms that the changes are consistent with the engineering design and safety requirements.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of the changes and offered training to deal with the modification. 
* Events that might (or did) cause an accidental or unexpected release of hazardous chemicals are subjected to a formal investigation.  The objective of the investigation is to correct deficiencies in such a way as to prevent recurrence.  All incident investigation reports are retained for a minimum of five years. 
* Rhodia hires contractors to perform specialized maintenance and construction activities.   
Prior to selecting a contractor, Rhodia thoroughly evaluates the safety performance of the contractor.  All contractors that are hired to work on site are safety trained and tested.  Rhodia has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response in case of an accidental release of a regulated substance. 
* Prior to the performance of any hot work (i.e., spark or flame producing operations such as welding, cutting, brazing, and grinding), management must approve the work by executing a written hot work authorization permit to verify that appropriate precautions to prevent fire have been implemented. 
* Numerous safety systems including high-temperature, pressure, and high-level cut-offs are used in the system.  Rhodia is also installing a computer control system that will provide Treatment Services processes with additional controls and monit 
oring capabilities. 
* Adherence to fire codes and preparation for fires, storms, or events which could impact the processes. 
* Planning with the local fire department to ensure a rapid response to potential incidents involving the processes or external events. 
* Prevention program compliance audits are performed at least annually to verify that the elements are being properly implemented.  Any deficiency found in an audit is corrected in a safe and prompt manner. 
As a result of our stringent release prevention policies, only one accidental chloroform release has occurred during the last five years at the Treatment Services process.  This release took place on February 20, 1997 and involved 1447 pounds of hydrogen chloride/hydrochloric acid and 117 pounds of chloroform as well as other solvents not regulated under the RMP.  The incident was a result of human error and a chemical reaction.  Due to this accident, 25 people off site received medical tr 
eatment and several sheltering in place advisories were issued.  On site, there were no injuries. 
In 1995, Rhodia experienced a release of sulfur trioxide that resulted in off-site consequences.  Rhodia is no longer in the sulfur trioxide business and no longer stores or transports this chemical. 
Rhodia maintains a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response including first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced.  In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require modified emergency response procedures. 
Our emergency response plan has been coordinated with the L 
ake County Local Emergency Planning Committee (LEPC), as well as the Hammond Fire Department and the East Chicago Fire Department. 
1    National Fire Protection Association. 
2    Passive mitigation means equipment, devices, and technologies that function without human, mechanical, or other energy input.  Examples include enclosures (e.g., buildings) for compressed gases and secondary containment dikes for liquids. 
3    Active mitigation means equipment, devices, or technologies that require human, mechanical, or other energy input or function.  Active mitigation may include automatic shut-off valves, rapid transfer systems, and scrubbers. 
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