Milliken Chemical - Dewey Plant - Executive Summary |
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Executive Summary Milliken Chemical - Dewey Plant Milliken Chemical, a Division of Milliken and Company, owns and operates the Dewey Plant. The Dewey Plant is a specialty chemical batch operation located near Inman, which is approximately 7 miles north of Spartanburg, South Carolina. The first priority of the Dewey Plant is the health and safety of its associates and the surrounding community. OSHA recognized the Dewey Plant as a "Star Site" in 1993. Year to date, through 6/99, the recordable incident rate for the site is 0.0. Plant associates have worked more than 500 days without a recordable incident and have worked more than 8 years without a lost time incident. Of equal importance is protection of the environment. To this end, significant resources are committed to ensuring that the plant is in complete compliance with all regulations and that the plant is operated in a manner that protects the quality of the environment. There have been no reportable releases from the facility in more than five years. The U.S. EPA Risk Management Program (RMP) regulates certain chemicals that are stored above threshold quantities. The Dewey Plant is subject to this regulation due to the fact that Ethylene Oxide, Propylene Oxide, and Phosphorous Oxychloride are stored on-site in excess of listed threshold quantities. The threshold storage quantity for Ethylene Oxide is 10,000 pounds. Ethylene Oxide is received by rail car and is stored in a storage tank. Ethylene Oxide is a "building block" chemical used to manufacture a wide variety of industrial chemicals, including lubricants, surfactants, and industrial intermediates that are used in coatings, colorants, and a variety of other applications. Dewey Plant also stores Propylene Oxide in quantities above the specified threshold quantity of 10,000 pounds. Propylene Oxide is also received by rail car and is stored in a storage tank. Propylene Oxide is another "building block" chemical used in the manufacture of products similar to those of Ethylene Oxide. The third chemical used by the Dewey Plant and stored in quantities above the threshold quantity of 5,000 pounds is Phosphorous Oxychloride. Phosphorous Oxychloride is received and stored in drums. Phosphorous Oxychloride is a building block chemical that is used in the manufacture of flame retardants, pharmaceutical ingredients, and agricultural products. At the Dewey Plant, Phosphorous Oxychloride is used to manufacture colorants that are used in urethane foams. The Dewey Plant is a Program 3. Program 3 requires both a worst-case and alternative-case modeling analysis to be performed. In addition to describing worst- and alternative-case scenarios for Ethylene Oxide, alternative-case scenarios must be performed for Propylene Oxide and Phosphorous Oxychloride. The U.S. EPA explicitly specifies the conditions for the worst-case scenario release. According to the General Guidance for Risk Management Programs (EPA 550-B-98-003, Page 4-4), the chances of a worst case release occurring are very low. A number of assumptions are made in generating worst-case release scenarios, including complete failure of all safety systems and worst-case weather conditions for air dispersion; consequently, the results are very conservative. EPA has established concentrations for each toxic substance, below which it has determined that nearly all individuals could be exposed for up to one hour without serious health effects. These concentrations are intended to protect the general public. The endpoint distance estimated under the worst-case scenario is intended to provide an estimate of the maximum possible area that might be affected in the unlikely event of catastrophic conditions. It is not intended to delineate a zone in which the public would likely be in danger. The EPA intends these endpoint distances to form the basis for discussion among the regulated community, emergency responders and the general public, rather than the basis for any specific actions. The worst-case release scenario for the Dewey Plant involves a leak developing in a rail car of Ethylene Oxide. In this scenario, the entire contents of the rail car would be released in ten minutes. Based on the conservative parameters, which are required in the modeling as mandated by the U.S. EPA, the endpoint distance is 3.9 miles. The residential population within that radius is estimated at 14,000. Schools, residences, recreational and commercial areas are located within this radius. As noted earlier in the quote from the U.S. EPA, the worst case scenario represents the "maximum possible area" that might be affected in the unlikely event of catastrophic conditions. The alternative-case scenario for Ethylene Oxide involves a leak in a transfer hose from which 61 pounds are released. The Dewey Plant has established controls that will detect releases and, under certain conditions, activate sprinkler systems to minimize release impact . For the purposes of this analysis, a ten minute release duration is assumed. Based on average weather conditions at the plant site, the endpoint distance is 164 feet. This release is isolated to the plant site and there are no off-site consequences. The alternative case scenario for Propylene Oxide is similar to the Ethylene Oxide scenario in which there is a leak in a transfer hose. In this case (due to an increased length of pipe), 264 pounds are released. As mentioned in the Ethylene Oxide scenario, there are controls in place to detect releases and, under certain conditions, activate sprinkler systems to minimize release impact. For the purposes of this analysis, a ten minute release duration is assumed. Based on average weather conditions at the plant site, the endpoint distance is 145 feet. This release is isolated to the plant site and there are no off-site consequences. The alternative-case scenario for Phosphorous Oxychloride involves a drum falling from a pallet during transportation on-site and developing a leak. The entire contents of the drum would be released and form a pool on the ground. Based on average weather conditions at the plant site, the endpoint distance is 887 feet. This release would go off- site but would not affect any residences. The Dewey Plant is committed to the education and training of all associates in the area of safety and emergency response. For this reason, plant associates are ready to respond in the event of an emergency. Plant associates are trained to respond to both fire and hazardous material emergencies. In addition, the plant has worked closely with the North Spartanburg Fire Department to ensure that they are prepared to respond in the event of an emergency. Milliken Chemical has taken a pro-active stance in the protection of human health and the environment and the prevention of accidental releases. As a result, the potential for any such incident is low. G:\SHARED\ENVIRON\112R\RMPexesu.doc Page 3 of 4 |