Olin Corporation Augusta, Georgia Plant - Executive Summary |
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1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Olin Corporation in Augusta, Georgia, we are committed to operating and maintaining all of our processes in a safe and responsible manner. Olin has always had a safety and environmental program, which relies on the fundamental belief that all accidents are preventable. Our goal is "Zero" incidents. To help insure that an emergency situation with off-site consequences will never arise, Olin has put six layers of safety and environmental protection in place: . Employees . Mechanical Integrity . Process Hazard Reviews . Process Controls . Monitoring Systems . Emergency Response We use a combination of accidental release prevention 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 we have designed and implemented. 2.0 STATIONARY SO URCE AND REGULATED SUBSTANCES Our facility produces chlorine, caustic soda, hydrochloric acid, and sodium hydrosulfite (along with other industrial chemicals), using a variety of chemicals and processing operations. Olin/Augusta employs approximately 105 people, including engineers, operating and maintenance technicians, and administrative disciplines. The plant is located at 2402 Doug Barnard Parkway, two miles south of Augusta's Bush Field Airport. In our processes, we use or produce the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics (Maximum Inventory) Chlorine 3,400,000 pounds Hydrochloric Acid 2,300,000 pounds Sulfur Dioxide 1,900,000 pounds Also included in the RMP list of regulated substances and handled at the Augusta facility, but exempt from the regulation, is hydrogen. In the case of hydrogen, the volume on site do es not meet the coverage requirements under RMP for flammables, which is 10,000 pounds or greater. 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 We are providing information about the worst-case release scenario and alternative release scenario(s) 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: Worst-case Release Scenario Regulated Toxic Chemicals Our worst-case release scenario (by EPA definition) for our facility would be the catastrophic failure of one of the four 150 ton chlorine storage vessels. These vessels have administrative controls to limit the maximum inventory. Weight alarms prevent more than 150 tons from being present in the 188 ton tank. The contents would be released over a 10 minute period, with no mitigation measures to limit the exposure distance. The estimated exposure distance would be greater than 25 miles, and would potentially impact public receptors (such as residences, schools, hospitals, prisons, major industrial areas, and public recreational areas), and environmental receptors (such as national and state parks, and designated wildlife sanctuaries). This scenario is highly unlikely because of adherence to high industry standards set by The Chlorine Institute, Inc. Tanks and associated piping are designed according to these standards, are inspected regularly, and repairs made promptly. One chlorine storage tank is always empty to provide space for the transfer of chlorine in case of a leaking tank. Chlorine and air entering these tanks are kept dry to ensure corrosion potential is very low. Alternative Release Scenario(s) Regulated Toxic Chemica ls The alternate release scenario for chlorine would be the over chlorination of our chlorine scrubbing system, resulting in a 100 pound chlorine release. The release duration would be 15 minutes, with no mitigation measures to limit the exposure distance. Administrative controls currently in place to limit the exposure distance are chlorine monitors located in and near the vent to alert operators of a chlorine release. This will ensure a prompt response to stop the chlorine source immediately. The estimated exposure distance would be 0.50 miles, and would potentially impact public receptors (such as major industrial areas). No residential areas are within the exposure area. The alternate release scenario for hydrochloric acid would be a pipe leak resulting in an 850 pound hydrochloric acid release. The release duration would be 20 minutes, with no mitigation measures to limit the exposure distance. Administrative controls in place are air monitors located within the plant and the perimeter to alert operators to a hydrochloric acid release. This will ensure a prompt response to isolate the leak from the source of hydrochloric acid. The estimated exposure distance would be 0.60 miles, and would potentially impact public receptors (such as major industrial areas). No residential areas are within the exposure area. The alternate release scenario for sulfur dioxide would be an unloading hose failure resulting in a 150 pound sulfur dioxide release. The release duration would be 15 minutes, with no mitigation measures to limit the exposure distance. Administrative controls in place to limit the exposure distance are air monitors and remote cameras to alert operators of a sulfur dioxide release. This wil ensure a prompt response to isolate the leak from the source of sulfur dioxide. The estimated exposure distance would be 0.60 miles, and would potentially impact public receptors (such as major industrial areas). No residential areas are within the exposure area. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 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 such as PSM, including: Process safety information Process hazard analyses Operating procedures Training Mechanical integrity Management of change Pre-startup reviews Compliance audits Incident investigations Employee participation Hot work permits Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Chlorine containment tank to capture chlorine releases from chlorine system relief valves. Chlorine monitors in the chlorine scrubber stack. Chlorine re cycle system for compressors. Sulfur dioxide monitors at the scrubber and in the vent stacks at the reactors. Hydrochloric acid loading systems equipped with shut off systems. All loading operations are monitored (Chlorine and HCL) 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 the way we do business, and we have specific accountabilities and controls to ensure we are meeting our own high standards for accident prevention. 5.0 FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. During the past five years we have had one accidential release of chlorine, which was 21 pounds. There was no offsite impact with this release. For this incident, we conducted a formal incident investigation to identify and correct the root cause of this release. 6.0 EMERGENCY RE SPONSE PROGRAM We maintain an emergency response 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 Augusta-Richmond County Emergency Operations Plan. 7.0 PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: Automatic shutoff system for chlorine loading stations. Closure of chlorine pipeline to neighboring industry. Integration of process control computers into the facility. |