Occidental Chemical Corp., Delaware City Plant - Executive Summary
EXECUTIVE SUMMARY |
Occidental Chemical Corporation (OxyChem), a wholly owned subsidiary of Occidental Petroleum Corporation (OPC), owns and operates a chlor-alkali manufacturing facility in New Castle, DE. This facility is known as the Delaware City Plant and is located on River Road, State Route 9. The chlor-alkali facility consists of a plant which manufactures chlorine, caustic soda, caustic potash and hydrogen along with facilities to store, load and ship chlorine. The facility was originally constructed in 1965 and employs 135 full-time employees.
1. Accidental Release Prevention and Emergency Response Policies at the Stationary Source (' 68.155(a)):
OxyChem is committed to operating the Delaware City Plant in a manner that is safe for its workers, the public and the environment. It is our policy to adhere to all applicable Federal, State and local rules and regulations, industry standards and best practices. As part of this commitment, OxyChem has established a system to
help ensure safe operation of the processes at this facility, which includes the prevention of accidental releases of hazardous substances. One component of this system is a risk management program (RMP) that helps manage the risks at the Delaware City Plant and complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirement Risk Management Programs (the RMP rule), OSHA 1910.119, and the State of Delaware Extremely Hazardous Substance Risk Management Act requirements (EHS rule). This document is intended to provide the public with a description of the risk management program at the Delaware City Plant, while satisfying the RMP plan requirements of the RMP rule and the Delaware EHS rule.
The RMP at the Delaware City Plant consists of the following three elements:
7 A hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents t
hat have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances)
7 A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes)
7 An emergency response program to help respond to accidental releases of regulated substances from covered processes
Information further describing these elements is provided in this RMP Plan.
Although the risk management program at the Delaware City Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the plant's safety and environmental program. In fact, the Delaware City Plant has a comprehensive safety and environmental program in place, establishing many levels of safeguards against release of a hazardous substance as well as injuries and damage from such a release.
OxyChem's policy on the use of hazardous substances:
Before using a hazardous substance at the Delaware City Plant, less hazardous alternatives are always considered. When a hazardous substance is used at the plant, OxyChem reviews the potential for an accidental release of this substance which could adversely affect plant workers, the public and the environment, and takes steps to prevent any such effects. This is accomplished through the facility's Management of Change (MOC) and Process Hazard Review (PHR) procedures which are followed for all new installations or modifications of existing processes.
OxyChem strives to prevent accidental releases of the hazardous substances used at the facility: OxyChem implements reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used at the Delaware City Plant, the equipment is carefully designed, installed, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in
the design, construction and operation of the equipment. OxyChem also uses the Corporate Fire, Safety and Environmental (FS&E) Guidelines when designing new or modifying existing processes. Each project is thoroughly reviewed before approval. In addition, OxyChem requires the documentation of standard operating procedures and training of affected employees with regard to these procedures as part of the MOC procedure. OxyChem's mechanical integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances.
OxyChem's goal is to minimize impacts from an accidental release: In the event of an accidental release, the Delaware City Plant controls and contains the release in a manner that will be safe for workers and will prevent impact to the public and the environment. OxyChem utilizes emergency response plans as required by government regulation. OxyChem trains its workers to respond
to an accidental release, reducing the consequences of a release if it occurs. The facility also maintains an active Chlorine Emergency Response Team which is on call 24-hours a day to respond to an accidental chlorine release. OxyChem also has established a Special Situations Center in the Dallas corporate office to assist in all emergencies. In addition, the OxyChem Delaware City Plant works with the local fire department and local emergency planning committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur. The OxyChem Delaware City Plant has assisted the LEPC in writing and implementing the Delaware City Community Awareness and Emergency Response Plan (DC-CAER).
The Delaware City Plant's emergency response plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, Delaware and EPA regulations. This plan outlines the responsibilities and actions required to control an emergency that l
imits itself to within the Delaware City Plant. If the emergency extends beyond the plant boundaries and affects the surrounding communities, the Delaware City Community Awareness & Emergency Response (CAER) Plan is initiated by a call to 911 with a statement of the type of emergency.
OxyChem is an active participant in the community: OxyChem is an active participant in plant and community programs which promote education, safety and environmental awareness. The facility has implemented a Voluntary Protection Program (VPP) in which employee participation at all levels is required in designing, implementing and maintaining safety programs. Safety is a primary concern in our facility and is demonstrated by our selection by OSHA in June, 1996 as the first and only OSHA Star facility within Delaware under OSHA's Voluntary Protection Program (VPP).
OxyChem is an industry leader in the implementation of the Chemical Manufacturers Association's Responsible Care. Initiative. As part of O
xyChem's Responsible Care. efforts, the Delaware City plant has voluntarily been involved in a Community Advisory Panel (CAP) since 1991. The purpose of this group is to share information about plant operations with members of the community and to discuss their concerns. The group meets periodically and covers topics of interest to the members including plant safety and environmental performance, emergency response programs, health issues and process safety performance. Through this outreach effort, as well as other community involvement, the plant stays abreast of community concerns and works to address them.
In order to effectively implement these policies, OxyChem established a management system headed by the Health, Environmental and Safety (HES) Department to oversee safety and environmental-related activities.
2. The Stationary Source and Regulated Substances Handled (' 68.155(b) ):
The Delaware City Plant handles only one substance that is regulated by the RMP rule, as s
hown in the following list of RMP-covered Program Level 3 processes at the plant.
Regulated Substance Process Largest Vessel Inventory*, lb. RMP Threshold, lb.*
Chlorine Storage Tanks 400,000 2,500
* - Largest Vessel Inventroy and threshold quantity is the quantity of "pure" chemical, not of the solution
Chlorine is one of the major products made at this facility. The primary purpose of this facility is to manufacture, liquefy, store and ship chlorine, related alkaline co-products and hydrogen gas. The daily production of the liquid chlorine is collected in six (6) 150-ton chlorine storage tanks. The chlorine from these tanks can be transferred to two (2) 200-ton tanks for additional storage or shipped to wholesale customers via a 2" liquid pipeline, a 6" gaseous pipeline, 55-ton and 90-ton rail cars, and 16-ton truck trailers. An additional 200-ton storage tank is maintained emp
ty and under a vacuum condition at all times in the event that chlorine would need to be transferred from one of the eight other tanks due to an emergency condition. The facility complies with Department of Transportation (DOT) regulations in the loading and shipment of the chlorine product. The facility also uses Industry best practices and those recommended by the Chlorine Institute in its operations.
One ton containers of liquid chlorine are utilized within the facility's waste water treatment plant, closed cooling water system and chlorination of the facility's water effluent to the Delaware River.
3. The Worst-Case Release Scenario(s) and the Alternate Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario (' 68.155(c) ):
The Delaware City Plant performed off-site consequence analysis to estimate the potential for accidental release of a regulated substance that could affect the public or the environ
ment. The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario " and an "alternative release scenario." Because a "worst case scenario" requires that all safety systems fail simultaneously, it is highly unlikely that such a worst-case release scenario would ever occur. The alternative release scenarios are developed to help the LEPC improve the community emergency response plan.
The RMP*COMP (TM) system was used to calculate the distance to the toxic endpoint (range of effect). The meteorological data used for the modeling was the EPA default for the worst case and EPA suggested values for the alternative release scenario. EPA's recommended Landview program was utilized to estimate the number of people living within this distance from the location of the storage tank. USGS maps were utilized to identify the public and environmental receptors located within this distance.
The following information summarizes the off-site consequence ana
lysis performed by the Delaware City Plant:
3.1 Toxic Substances - Chlorine
The "worst-case release scenario" for chlorine is the failure of one of the largest chlorine storage tanks which would release 400,000 pounds of liquid chlorine in a 10-minute period as mandated by EPA. It is assumed that the liquid chlorine vaporizes within the 10-minute time period. The worst case release scenario was evaluated using RMP*COMP (TM) Ver. 1.06. Under the EPA default worst weather conditions, the chlorine gas cloud would travel a distance of 20 miles before the concentration of chlorine was reduced to below 3 parts per million (ppm) (which is the 'endpoint' Emergency Response Planning Guideline value established in the RMP rule). The U.S. Census indicates that 585,780 people live within this distance from the chlorine storage tank. Several public and environmental receptors are also located within this distance.
The "alternative case release scenario" is the failure of a 1-inch loading h
ose connected from the liquid chlorine tank car loading header to a rail car. This scenario would release 1,170 pounds of chlorine liquid in a 0.3-minute period. The RMP*COMP (TM) Ver. 1.06 , was used for alternative release scenarios to determine the off-site consequences. Assuming a wind speed of 3 meters/sec, a D stability class and urban topography, the chlorine cloud would travel 0.6 miles before reaching a chlorine concentration of below 3 ppm (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule). The are no residences within this distance from the car loading spot.
3.2 Program 3 Processes-Flammable Substances
There are no regulated flammable substances in quantities above the threshold quantities at the plant. Propane is stored on-site in 30 pound cylinders, however, the total quantity is less than the threshold quantity of 10,000 pounds.
4. The General Accidental Release Prevention Program and the Specific Prevention Steps ('
Since 1990, the Delaware City Plant has used a prevention program to help prevent accidental releases of hazardous substances in compliance with the State of Delaware's Extremely Hazardous Substance Regulations. Beginning in 1994, the plant revised this prevention program for the chlorine manufacturing and storage processes to comply with the 14 elements of the OSHA Process Safety Management (PSM) prevention program. In 1996, the EPA RMP rule established two levels of prevention requirements:
Program 3 is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment outside the plant's fenceline;
The following sections briefly describe the elements of the Delaware City Plant's Program 3 prevention program that address EPA's RMP rule prevention program requirements.
4.1 Program 3 Prevention Program
The Delaware City Plant's Program 3 prevention program consists of the following 12 elements:
4.1.1 Process Safety
The Delaware City Plant maintains technical documents which are used to help ensure safe operation of the plant processes. These documents address (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant and (3) design basis and configuration of the equipment at the plant. OxyChem ensures that this process safety information is available to all employees.
Material safety data sheets (MSDSs) document the physical properties of the hazardous materials handled at the plant, including regulated substances in covered processes. The information available for each hazardous substance typically includes:
7 Toxicity information and permissible exposure limits
7 Physical data (e.g., boiling point, melting point, flash point)
7 Reactivity and corrosivity data
7 Thermal and chemical stability data
7 Hazards of mixing substances in the process
MSDSs for hazardous substances handled in each process are av
ailable from the plant's Safety Department and the office administrator. In addition, key MSDSs are provided to the LEPC and the DC-CAER group upon request for use in helping formulate emergency response plans.
The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process. The available information includes:
7 Operating parameters
7 Process flow diagrams
7 Process chemistry
7 Maximum intended inventories
7 Safe upper and lower limits for parameters such as temperature, pressure, or flow
7 Design basis and configuration of equipment
7 Piping and instrumentation diagrams, including materials of construction
7 Electrical classification
7 Safety systems
7 Applicable design codes and standards
7 Design basis for relief and ventilation systems
Operating manuals contain the process objectives, process chemistry, overview of the process operations, critical process variables with consequences of deviations
, equipment and instruments descriptions, troubleshooting guidelines, start-up and shut down procedures and equipment operating procedures.
These documents are used to (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment.
4.1.2 Process Hazard Analysis
The Delaware City Plant performs and updates, within every 5 years as required by OSHA and the EHS rule, process hazard analyses (PHAs) of the covered process to help identify process hazards and generate recommendations that might improve the safe operation of the process. A team comprised of personnel with engineering and process operating experience and a leader with process hazard analysis experience is assembled to analyze the hazards of the process. The plant primarily uses the "HAZOP" technique to perform this analysis. However, other methodologies may be used as appropriate. The PHA team prepares a written report describing the results of the analysis, including a list of recommendatio
ns. Responsibility to resolve the recommendations is assigned to unit personnel and, when appropriate, changes to enhance the safety of the process are implemented.
4.1.3 Operating Procedures
Delaware City Plant process engineers, technicians and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include:
7 Steps for safely conducting activities
7 Applicable process safety information, such as safe operating limits and consequences of process deviations
7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs
Plant personnel develop and maintain operating procedures that cover all p
hases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown and temporary operations. The operating procedures are used both to help in operating the plant's processes and as a training guide.
The Delaware City Plant trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process and (3) a detailed review of the process operating procedures and safe work practices. Oral reviews and written tests are used to verify that an employee understands the training material before the employee can resume work in the process. The operators are consulted annually to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed and changes to the tra
ining program are implemented as appropriate.
4.1.5 Mechanical Integrity
The Delaware City Plant maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public or the environment. The mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes. The mechanical integrity program includes:
7 Specifications for inspection and testing of process equipment
7 Specifications for replacement parts and equipment
7 Procedures for inspecting, testing and maintaining process equipment
7 Procedures for safe work practices such as Lock, Tag and Try; Hot Work; Confined Space Entry; and Line Breaking
7 Training of maintenance personnel
7 Documentation of maintenance activities
ement of Change
The Delaware City Plant management of change program ensures that an evaluation and approval process is used for all proposed changes to chemicals, equipment and procedures for a covered process to help ensure that the change does not negatively affect safe operations. Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change review. All other changes must be confirmed through the full management of change review to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes.
4.1.7 Pre-startup Review
The Delaware City Plant performs a safety review through our MOC procedures of a new or modified process before the process is placed into service to help ensure that the process has b
een prepared to operate safely. This review confirms that:
7 Construction and equipment are in accordance with design specifications
7 Adequate safety, operating, maintenance and emergency procedures are in place
7 Employee training has been completed
7 For a covered process, a PHA has been performed if the process is new or management of change requirements have been completed if an existing process has been modified
The management of change pre-start up safety review check list will be completed during the MOC walk through for new processes, major modifications and/or start up of existing processes that have been shut down for more than 6 months.
4.1.8 Compliance Audit
The Delaware City Plant audits covered processes at least every three years to be certain that the prevention program is effectively addressing the safety issues of operations at the plant. The plant assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and this team ev
aluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved and appropriate enhancements to the prevention program are implemented.
Both Occidental Petroleum Corporation and Occidental Chemical Corporation perform audits of the facility programs, process and documentation at regular intervals.
4.1.9 Incident Investigation
The Delaware City Plant investigates incidents, including near misses, that could reasonably have resulted in a serious injury to personnel, the public or the environment so that similar incidents can be prevented in the future. The plant trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendat
ions are resolved and appropriate process enhancements are implemented.
OxyChem has a formal program including training for incident investigations and the report generation.
4.1.10 Employee Participation
The Delaware City Plant developed a written employee participation program for all covered processes to help ensure that the safety concerns of the plant's workers are addressed. The plant encourages active participation of personnel in the prevention program activities of all processes at the plant. Employees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHAs, MOCs and operating procedures.
4.1.11 Hot Work Permits
The Delaware City Plant established a hot work permit program to control spark or flame-producing activities that could result in fires or explosions in covered processes at the plant. The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to compl
y with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The Shift Supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation.
The Delaware City Plant established a program to help ensure that contractor activities at the plant are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that the plant only hires contractors who can safely perform the desired job tasks. The plant explains to the contract supervisors the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant's emergency response procedures. The plant requires that the contractor supervisors train each of their employees who will work at the plant before that worker begins work at the plant site. The plant periodically reviews c
ontractors' training documents and conducts bi-weekly audits of the contractor's work performance to help ensure that safe practices are followed.
5 Five-year Accident History (' 68.155(e) ):
A 750-pound chlorine release occurred on July 21, 1994. This release was caused by the reaction of chlorine and residual mineral oil on improperly cleaned steel parts placed in the Suction Chiller vessel in one of the plant's chlorine compressors. There were no off-site injuries or significant damage. Downwind residents were requested to shelter in place. The Delaware Memorial Bridge was closed to traffic for approximately 1-1/2 hours. Since then, OxyChem has developed and implemented strict cleaning and inspection procedures for all metal parts being placed in chlorine service to ensure that there is no residual mineral oil remaining on the parts. There were no other releases of chlorine in the past five years which had an off-site impact.
6. The emergency response program (' 68.155
The Delaware City Plant has established a written emergency response plan and maintains an emergency response team trained in these emergency response procedures. All plant personnel are trained in evacuation procedures. The written emergency response plan complies with the following federal and state contingency plan regulations:
7 OSHA 29 CFR 1910.38(a) - Employee Emergency Action Plans
7 OSHA 29 CFR 1910.119 (n) - Process Safety Management of Highly Hazardous Chemicals
7 OSHA 29 CFR 1910.120(p) and (q) - Hazardous Waste Operations and Emergency Response (HazWOPER)
7 OSHA 29 CFR 1910, Subpart L - Fire Protection
7 EPA 40 CFR 302.6 - Notification Requirements
7 EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Plan
7 EPA 40 CFR 355.40 - Emergency Planning and Release Notifications
7 EPA 40 CFR 112 - Spill Prevention, Control and Countermeasures Plan
7 EPA 40 CFR 68 - Risk Management Programs for Chemical Accidental Release Prevention
7 Delaware Regulation for
the Management of Extremely Hazardous Substances.
The Delaware City Plant has a Chemical Emergency Response Program Team (CERP) available 24 hours per day to respond to in plant chemical emergencies. The plant's CERP team serves as the Region 3 CHLOREP Regional Response Team for the Middle Atlantic states and responds to chlorine emergencies within this region. The team maintains a mobile chemical emergency command center equipped with the necessary equipment to respond to chlorine emergencies.
The Delaware City Plant uses a SAFER Real Time modeling program to assess release impacts, if any, and to aid in the determination of response activity. The Delaware City Plant has a community alert (CAL) system available through the DC-CAER plan to notify the public of a potential or actual hazardous situation. The DC-CAER committee is currently evaluating the use of the New Castle County's new telephonic public notification system which was recently implemented. In addition the Delaware Ci
ty Plant has developed a Special Situations Plan which is a program designed for responding to emergencies that may have impacts beyond the immediate plant and is a supplement to the Emergency Response Plan. The Special Situation Plan links the local response to the OxyChem Corporate Special Situation Control Center located in Dallas, Texas which can then provide assistance as needed.
The facility is a member of the Delaware City CAER committee, whose membership includes:
7 City of Delaware
7 Delaware City Fire Company
7 New Castle County Police
7 New Castle County Emergency Services and Emergency Preparedness Agency
7 Delaware Emergency Management Agency
7 Delaware State Police
7 State Division of Public Health
7 Department of Natural Resources and Environmental Control
7 Delaware State Fire School
7 New Castle County Emergency Medical Services Council
7 Industrial Representatives from the Delaware City Industrial Complex
The DC-CAER committee meets every two months and conducts an
nual training exercises of the emergency response plan. The Delaware City Plant's emergency response plan has been communicated to the New Castle County Emergency Services and Emergency Preparedness Agency and the DC-CAER committee.
7. Planned Changes to Improve Safety (' 68.155(g) ).
The Delaware City Plant constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, and a program soliciting safety and environmental suggestions from the plant employees.
8. Certification (40 CFR 68.185)
General Certification: To the best of my knowledge, information, and belief formed after reasonable inquiry,
the information submitted in this RMP Plan is true, accurate, and complete.
Signature: W. Dean Hulsey* Date Signed: June 18, 1999
Title: Plant Manager
* The Certification with original signature is presented in the attached cover letter.