Rhodia Inc. Morrisville Plant - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Rhodia Inc. Morrisville Plant are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also coordinated with Falls Township Fire Company No. 1 which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Manufacturing of Phosphorus based Chemical Intermediates. We have 3 regulated substances present at our facility. These substances include Phosphorus trichloride, Chlorine and Phosphorus oxychloride [Phosphoryl chloride]. The regulated substances at our facility are involved in several uses. The maximum inventory of Phosphorus trichloride at our facility is 1600000.00 lb. while Chlorine and Phosphorus oxychloride [Phosphoryl chloride] are present at our facility in quantities of 1440000.00 lb. and 480000.00 lb. respectively. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To evaluate the worst case scenarios, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations. For alternative release scenario analyses, w e have employed EPA's RMP*Comp(TM). The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from the Phosphorus Trichloride Process. The scenario involves the release of 180000 lb. of Chlorine in a liquid form over 10 minutes due to rupture of a chlorine tank car. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 14 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. One alternative release scenario has been submitted for each toxic substance present in Program 3 processes. The alternative release scenario for Phosphorus trichloride involves a release from PCL3 Tank Truck loading hose in the Phosphorus Trichloride process. The scenario involves the release of 11700 lb. of Phosphorus trichl oride over 10 minutes. Toxic liquid is assumed to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 36.3 minutes. The release is also assumed to be controlled by active mitigation measures that include emergency shutdown systems. All released Phosphorus trichloride is assumed to react completely to form stoichiometric quantities of HCL and non-regulated phosphoric acid. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.030 mg/L of Hydrogen chloride is 0.9 miles. The alternative release scenario for Chlorine involves a release of 3750 lb. of chlorine from a CL2 Tank Car unloading hose in the Phosphorus Trichloride process. Toxic liquid is assumed to be released to form a pool of height 1 cm, from which evaporation takes place. The release duration is estimated to be 15 minutes. The release is also assumed to be controlled by active mitigation measures that include excess flow val ve(s) and emergency shutdown systems Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.3 miles. The alternative release scenario for Phosphorus oxychloride [Phosphoryl chloride] involves a release from a POCL3 Tank Truck unloading hose in the Phosphorus Oxychloride Packaging process. The scenario involves the release of 12500 lb. of Phosphorus oxychloride [Phosphoryl chloride]. The release duration is estimated to be 10 minutes. Toxic liquid is assumed to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 120 minutes. The release is also assumed to be controlled by active mitigation measures that include emergency shutdown systems. All released Phosphorus oxychloride is assumed to react completely to form stoichiometric quantities of HCL and non-regulated phosphorus acid. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.030 mg /L of Hydrogen chloride is 0.3 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with various industry codes including; API, ASME, NFPA, and Rhodia Inc Process Hazards Management Program (PHMP). Two processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Rhodia Inc. Morrisville Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes in accordance wi th Unit Safety Files per the Rhodia Inc. PHMP. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is HAZOP and What-If per the Rhodia Inc. PHMP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Rhodia Inc. Morrisville Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily access ible to operators involved in the processes. Training Rhodia Inc. Morrisville Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least three years and more frequently as needed. Mechanical Integrity Rhodia Inc. Morrisville Plant carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; 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. Management of Change Written procedures are in place at Rhodia Inc. Morrisville Plant to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Rhodia Inc. Morrisville Plant. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Rhodia Inc. Morrisville Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audit s are undertaken in a safe and prompt manner. Two internal audit tools currently used are the Rhodia Inc. PHMP Facilitated Self Assessment and the Management Systems Requirements and Recommendations. Incident Investigation Rhodia Inc. Morrisville Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Rhodia Inc. Morrisville Plant truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. There is a site procedure for Employee Participation and a Plant Safety Committee is being established. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Rhodia Inc. Morrisville Plant 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 should an accidental release of a regulated substance occur. 5. Five-year Accident History Rhodia Inc. Morrisville Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no reportable accidental release during this period. 6. Emergency Resp onse Plan Rhodia Inc. Morrisville Plant carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate 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 a modified emergency response. Falls Township Fire Co. No.1 in conjunction with Bucks County EMA is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention prog ram. Closed loop rail car and tank truck loading and a new process and emergency scrubber for Chlorine, Phosphorus trichloride, and phosphorus oxychloride are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by year end, 1999. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Signature: Title: Date signed: |