Westvaco Corporation, Chemical Division - Executive Summary |
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RISK MANAGEMENT PLAN PURSUANT TO 40 CFR 68(G) Westvaco Chemical Division De Ridder, LA Introduction Westvaco Chemical Division owns and operates a chemical plant that manufactures tall oil products and printing ink resins in De Ridder, Louisiana, which is subject to U.S. Environmental Protection Agency (EPA) regulations governing Accidental Release Prevention (ARP) Requirements: Risk Management Programs under Section 112(r) of the Clean Air Act (40 CFR Part 68). This Risk Management Plan (RMP) has been developed in accordance with the requirements specified under 40 CFR Part 68, Subpart G. The RMP certifies that Westvaco Chemical Division has instituted a Risk Management Program at the De Ridder, LA facility that is in compliance with U.S. EPA ARP requirements. The RMP includes an Executive Summary and Data Elements following the format published by U.S. EPA. This document identifies the applicable corporate policies and risk management systems, including comprehensive accide nt prevention and emergency response programs. In addition, this RMP identifies a worst-case release scenario, the potential off-site consequences of such a release, and the facility's five-year accidental release history. This RMP certifies that prevention and emergency response programs are in place so as to minimize risks to workers and the potentially affected public. RISK MANAGEMENT PLAN PURSUANT TO 40 CFR 68(G) Westvaco Corporation Chemical Division De Ridder, LA RMP Executive Summary 1.0 WESTVACO CHEMICAL DIVISION ACCIDENTAL RELEASE AND EMERGENCY RESPONSE POLICIES 1.1 Control of Hazardous Materials Westvaco strives to conduct its business in strict conformity with all applicable laws and in a safe and responsible manner. Westvaco has always placed the very highest priority on the safety and health of its employees and members of the communities in which it operates. This policy applies to the De Ridder, Louisiana facility and to all the locations of Westv aco and its subsidiaries and to all materials which may be hazardous to health, whether solid, liquid or gaseous. It is the responsibility of the Chemical Division Manager and the Corporate Research Director to ensure that each facility location within their respective authority is in full compliance with the provisions of this policy. Management at each company facility location, by utilizing effective process safety management, should be knowledgeable on a current basis as to materials which are present and aware of the possible risk associated with their handling, storage, use, discharge, spill, disposal, or release. Material Safety Data Sheets (MSDS) are to be maintained as required and reviewed as appropriate to possible exposures. Westvaco facilities are to be designed, constructed, inspected, maintained and operated in a manner so as to minimize the risk of exposure to employees and the public at large to hazardous materials and in conformity with all governmental regulation s and corporate guidelines. Each facility should maintain inspection records and up-to-date procedures to ensure that control of hazardous materials is maintained at all times. The procedures are to include provisions for the periodic testing, review, and update of the emergency response programs. Changes in protective technology should be monitored, and when found to be more effective, the need for change should be promptly considered. In addition, at a minimum of every three years, each affected facility will undergo a comprehensive process safety management compliance review. The functions of environmental protection, property conservation and safety and health are to be coordinated at each facility so that the most effective and practical protection of employees, public and environment from hazardous materials is achieved and regulatory reporting requirements are met. All employees should be trained and periodically retrained in a manner appropriate to their possible exposur e to materials which are considered hazardous. This should include methods for detection of the presence or release of hazardous materials, the physical and health hazards of the materials, and methods for protecting themselves and co-workers. The information provided by MSDS should be reviewed with employees as appropriate to their possible exposure. Each facility should coordinate its safety and emergency response program with local community emergency response officials to insure safe, effective, and swift response to emergencies in the workplace. This includes forthrightly disclosing to the community, through its emergency response officials, facts regarding the hazards and risks in operating the facilities, the prevention techniques in place, and assistance in devising the most appropriate and effective protection plans for the community and the plant. Each Division Manager, and the Corporate Property Conservation Manager, is to be specifically assured in writing of complianc e with the Control of Hazardous Materials Policy in his division on an annual basis. The Corporate Property Conservation Manager will provide annual written confirmation of compliance to the Chairman and the President. Each facility is to promptly investigate, correct, and report in writing to the Division Manager and the Corporate Property Conservation Manager all incidents involving hazardous materials having caused, or having the potential for causing, injury or loss. Clear understanding and careful observance of this policy throughout the organization is of great importance to Westvaco, its employees, and the public. While line management has the primary responsibility for providing safe conditions and for creating a climate in which the whole organization shares in the concern for both employee and community safety and health, each member of the organization plays a key role in assuring success. 1.2 Risk Management System Westvaco Chemical Division has developed management systems to implement and maintain compliance with the Accidental Release Prevention (ARP) and related chemical safety and emergency response programs at each facility location. The management system at the DeRidder, LA facility identifies lines of responsibility for the entire program and each of its key elements, as illustrated below. Risk Management Organization Chart DeRidder, LA Facility Accidental Release Prevention Program Plant Manager W. Martin Heyne Off-Site Hazard Assessment Accident Prevention Emergency Response Environmental Manager Safety Coordinator Property Conservation Daniel L. Price Roy A. McKinney Specialist Mitch C. LeBato 2.0 PROCESS AND SUBSTANCE SUBJECT TO 40 CFR PART 68 At the Westvaco plant in DeRidder, LA crude tall oil is fractionated into pitch, light ends, and several grades of rosins and fatty acids. Rosins and fatty acids are used in the production of hard resins and solution resinates that are used in the graphic arts industry. These products are also used to produce coatings (paper size), chemicals for the rubber industry, and wax compounds. Westvaco/DeRidder also operates an acrylic hard resin and acrylic emulsion process unit. In the acrylic emulsion batch process, monomers are blended in pre-mix tanks and slowly added to water, catalysts, surfactants, and other additives (such as ammonium hydroxide) in reactors to polymerize the monomer blend. The acrylic polymer emulsion removed from the reactor is filtered and pumped to drums, tote bins, or storage tanks. Amm onium hydroxide is also used as a nutrient for biological organisms in the WWTS. Risk management regulations promulgated by U.S. EPA under 40 CFR Part 68 apply to facilities (stationary sources) with greater than threshold quantities of specific toxic and flammable substances to develop Risk Management Programs and document compliance in Risk Management Plans. The Westvaco De Ridder Chemical Plant will be subject to the regulation because aqueous ammonia in greater than threshold quantities (20,000 lb of NH3 in concentrations exceeding 20%) are presently used. EPA recognizes that some processes that are regulated under this program would not pose an off-site hazard in the event of an accidental release. Such processes, classified as Program 1, have simplified requirements because off-site emergency response is not required. To qualify for Program 1, a facility with a regulated toxic chemical needs to meet two requirements: 1) no release over the most recent 5-year period has re sulted in off-site injury or environmental damage; and 2) dispersion modeling demonstrates that a worst-case release (as defined by the regulation) will not result in concentrations at public receptors that exceed the toxic endpoint. The Risk Management Plan requirements for Program 1 processes are as follows: 7 Registration 7 Accident history 7 Hazard assessment for worst-case releases 7 Coordinate emergency response procedures with local emergency planning and response organizations 7 Certification The following sections of the Risk Management Plan executive summary demonstrate that the ammonia process at Westvaco De Ridder qualifies for Program 1. 3.0 HAZARD ASSESSMENT 3.1 Five-Year Accident History In conjunction with the current ARP programs in place at the Westvaco Chemical facilities, there is a standard management practice that requires immediate internal reporting of unusual events, including those in which any abnormal emission of regulated chemicals is observed or suspected. The incident information is reviewed by supervisory staff and a determination is made as to whether a reportable quantity of any chemical listed as requiring reports to regulatory authorities is involved. If so, the appropriate authorities are promptly notified. During the past 5 years there has been no accident involving aqueous ammonia that qualifies for reporting under 40 CFR Part 68. This means that no accident has resulted in reportable on-site injury, off-site injury, off-site evacuation or sheltering in place, or off-site damage to property or the environment. Thus, Westvaco's De Ridder facility meets Program 1 accident history requirements. 3.2 Worst-Case Release Assessment As defined by 40 CFR Part 68, a worst-case release for a liquid is an instantaneous spill of the largest contents of any single vessel onto a flat, non-absorbing surface, accounting for passive mitigation (such as a dike or enclosure). To standardize and simplify to a practical level the many factors that can potentially occur in an accidental release situation, worst-case assumptions do not take into account the available active preventive measures or mitigation methods that would diminish or even eliminate the implied risks that are suggested by "worst-case" analyses. For the Westvaco Chemical Division De Ridder, LA facility, the worst-case release scenario is a spill under stable meteorological conditions (see section 3.2.1, below) of 15,599 gallons (80,500 lb) of a 30% ammonium hydroxide solution into a diked area. The available surface area in the dike is 1018 sq. ft and the dike is 1.5 ft deep. This will effectively limit the spill area and reduce the rate of release of ammonia to the atmosphere in the event of a release. The storage tank and dike are surrounded by buildings, tanks, and structures of varying height which, as the pool of spilled ammonium hydroxide evaporates into the atmosphere, will help increase the rate of dispersion. 3.2.1 Worst-Cas e Evaporation and Dispersion EPA regulation requires that worst-case analyses be conducted using stability class F and 1.5 m/sec wind speeds. These conditions, consistent with minimal mixing, occur during the night under clear skies and light winds. The EPA has published RMP Off-site Consequence Analysis Guidance (OCAG, May 1996) which provides a basic approach to estimate endpoint distances. However, the lack of precision in the OCAG dispersion tables requires the application of more refined techniques. The evaporate emissions calculations in the OCAG are based on a temperature of 770 F. The rule requires that if dispersion techniques other than the OCAG are applied, the maximum daily temperature be used. A review of climatological data for the National Weather Service reporting station at Lake Charles, LA indicated a recorded high temperature of 1010 F. This higher value was conservatively assumed as the temperature of the air, surface, and spilled solution even though such a high temperature is inconsistent with the worst-case dispersion conditions. Under more realistic meteorological conditions, the evaporation rate of ammonia would be much less and the area affected by the spill would be much smaller. Because a higher temperature than 770 F was used, the evaporation calculation contained in the OCAG was not applicable. Rather, a specialized ammonia evaporation model, NH3POOL1 was used. NH3POOL is a spreadsheet-based model that accounts for the variability of the evaporation rate according to temperature, wind speed and the ammonia solution concentration. NH3POOL provides results that are equal to the OCAG for a 770F temperature. The emissions model was then run using the higher 1010F temperature. The maximum emission rate that would occur during the first 10 minutes after the spill is used in this assessment. After this time, the emission rate would decrease along with the decreasing concentration of ammonia in the pool. Ammonia is a buoyant g as due to its molecular weight of 17 g/mol molecular weight and vapor density of approximately 60% of the surrounding air. Thus, emissions from a ground-level aqueous ammonia spill will have the tendency to rise above the ground and disperse more rapidly than would a passive tracer. 3.2.2 Toxic Endpoint The toxic endpoint for ammonia of 200 parts per million (ppm) as set by the Emergency Response Planning Guideline, Level 2 (ERPG-2), is protective for permanent or escape impairing injury for exposures up to one hour. Thus, the use of the maximum 10-minute emission rate is conservative. 3.2.3 Modeling Method The area surrounding the Westvaco De Ridder plant is predominantly rural. The release site is also dominated by large structures which generate a great deal of turbulence that will enhance the rate of dispersion in the vicinity of the ammonia tanks. EPA has developed model algorithms to simulate the effects of building wakes on dispersion of continuous releases. These alg orithms are included in the SCREEN3 dispersion model. SCREEN3 requires the specification of building dimensions to simulate aerodynamic wake effects. A review of building and structure dimensions near the ammonia storage tank indicates that dispersion of the ammonia plume will be affected for all wind directions. The height of the tank farm including the superstructure is approximately 20 ft and the minimum horizontal dimension is 46 ft. SCREEN3 was then applied with the NH3POOL emission rate, with building dimensions corresponding to the tank farm and worst-case meteorological conditions. The buoyancy associated with ammonia is accounted for in a spreadsheet-based program called LIFTOFF2, which estimates the reduction in ground-level concentration of ammonia from ground-level spills as a function of downwind distance. The LIFTOFF factor is then applied to the SCREEN3 results to estimate the ground-level concentration associated with the buoyant plume. The modeled SCREEN3/LIFTOFF ground-level concentrations were then compared to the toxic endpoint of 0.14 g/m3 (200 ppm) established by EPA to estimate the endpoint distance for the worst-case release. 3.2.4 Worst-Case Modeling Results The resultant rate of ammonium hydroxide evaporation from the diked pool, as modeled by NH3POOL with a worst-case wind speed of 1.5 m/sec and temperature of 1010F, is 0.83 lb/min (376 g/sec). Dispersion was simulated using the SCREEN3 model in the rural mode, assuming the pool is a ground-level point source subject to aerodynamic downwash. The worst-case endpoint distance associated with a ground-level concentration of 0.14 g/m3 is 250 m (820 ft) whereas the closest Westvaco facility boundary is located 305 m (1000 ft) from the ammonia tank. Thus, the worst-case modeled endpoint distance is well within the Westvaco site boundary and fenceline where access to the public is not allowed. As such, no public or environmental receptors would be adversely affected by a worst-case ammonia release. Thus, the Westvaco process that uses aqueous ammonia is eligible for Program 1 under EPA's Accident Prevention and Risk Management Regulations (40 CFR Part 68). 4.0 ACCIDENT PREVENTION Program 1 requirements under 40 CFR Part 68 do not mandate a formal accident prevention program. However, in accordance with the General Duty provisions of Section 112(r) of the Clean Air Act, Westvaco has in-place scientific operational and safety programs that are consistent with RMP Prevention Program requirements. As described in Section 1.1, the De Ridder, LA facility is designed, constructed, inspected, maintained and operated in a manner so as to minimize risk of exposure to employees and the public. In addition, at a minimum of every three years, the facility undergoes a comprehensive process safety management compliance review. 5.0 EMERGENCY RESPONSE PROGRAM Consistent with Program 1 requirements, Westvaco De Ridder coordinates emergency response with the local em ergency planning and response agencies, including the De Ridder police and fire departments. It is the policy of the Westvaco Chemical Division to place the highest priority on employee safety and health and on protection of the community from all plant-induced environmental conditions. An Integrated Contingency plan has been developed to provide protection by providing prompt action to control an emergency and minimize the amount of toxic material released and lessen or eliminate the hazards to employees and the community. Experience has shown that proper planning and an organized approach will reduce the effects of emergency events. Prompt internal and external communications, emergency equipment, and trained personnel are the key ingredients of this plan. Westvaco's policy provides for external communications with local and parish-wide response agencies. 6.0 PLANNED CHANGES TO IMPROVE SAFETY The Westvaco Chemical Division, under the recent RMP program, as well as its exist ing PSM and earlier Superfund Amendments and Reauthorization Act (SARA) Title III Community Right-to-Know Act compliance programs, has organized its manageme-nt system to effectively address all hazards and potential risks. Both the advanced planning aspects of process design, operating procedures, emergency prepared-ness, and the operational elements of system maintenance, safe operating practices and ongoing personnel training are necessary to support a continual improvement in facility safety. These programs are all documented so that needed information about the safe handling of all chemicals present at the facility is continuously available to employees, and can be readily interpreted by emergency response team staff and the Site Emergency Coordinator when questions arise from public safety officials on potential risks to the community. All of these features of the RMP and the integrated risk management program at this site lead to operations that are safe today, but will be ev en safer tomorrow. |