Elf Atochem North America, Inc. - Wichita Plant - Executive Summary

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A Risk Management Program has been implemented at Elf Atochem's Wichita production facility to reduce the risk of accidental releases of hazardous materials. This Risk Management Plan summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Plan summary is organized to correspond with specific EPA RMP definitions and requirements, including: 
    Elf Atochem policies to protect health, environment, and safety; 
    Facility identification and regulated substances in covered processes; 
    Hazard Assessment; 
    Prevention Program; 
    Five-Year Accident History; 
    Emergency Response Plan; and 
    Planned changes to improve safety. 
Elf Atochem Policies for Health, Environment, and Safety 
Risk management and safety have been important concerns at Elf Atochem for many years; this RMP formalizes and documents these activities. Elf Atochem is comm 
itted to conducting its operations in a safe, responsible manner and to reducing risks to health and the environment. 
This commitment to health, environment, and safety (HES) starts with the CEO. Senior management routinely dedicates time to a review of HES matters, including safety. This emphasis on safety is carried through to the facility level, where the Plant Manager and the Safety Committee regularly review safety performance, take corrective actions, and strive for continuous improvement. The success of Elf Atochem's HES programs is also reflected by a strong commitment to safety by employees and contractors. 
Elf Atochem's HES programs include policies, procedures, standards, and guidance materials designed to fulfill Elf Atochem's commitment to health, environment, and safety. These materials include Risk Management Program guidance to help our facilities prevent and/or reduce the risk of accidents. 
Facility Identification and Regulated Substances in Covered Process 
The Elf 
Atochem Wichita facility is located at 6040 South Ridge Road, Wichita, Kansas. The facility manufactures chlorinated and fluorinated hydrocarbon refrigerants via continuous chemical reaction and purification processes. Certain substances used and produced within the facility are regulated under 40 CFR Part 68, the EPA Risk Management Program (RMP) Rule. These substances are present, in various processes, at or above the minimum threshold for RMP applicability and include: 
HF Railcar Storage & Unload 
  Hydrogen Fluoride                       3,400,000 lbs. 
Bulk HF Storage 
  Hydrogen Fluoride                          850,000 lbs. 
Unit III Reactor System 
  Hydrogen Fluoride                              3,600 lbs. 
Unit IV Reactor System 
  Hydrogen Fluoride                              6,800 lbs. 
HF Absorption/Recovery System 
  Hydrogen Fluoride                            77,000 lbs. 
HCl Purge Acid Storage 
  >37% Hydrochloric acid solution    120,000 lbs. 
Chloroform Storage  
roform                                   1,200,000 lbs. 
HF and chloroform are used as process feedstocks. HCl is a by-product. 
This facility is covered by Title V of the Clean Air Act, but has not received a permit as of the date of this submittal. 
Hazard Assessment - Worst Case Scenario 
The worst-case accident release scenario is a catastrophic failure of the largest HF storage vessel. HF is received as a liquid in pressurized rail cars and unloaded into storage tanks. Administrative controls limit the HF quantity in this vessel and this quantity was assumed to be released over 10 minutes in the worst-case scenario. Engineering controls to enforce the administrative control include a high-level alarm (which sounds at 80% level). 
It should be noted that regulatory agencies and Elf Atochem consider the worst-case scenario to be an extremely unlikely event. This Risk Management Plan includes information on mitigation and prevention measures implemented by Elf Atochem to reduce the r 
isk of this type of event. 
Worst-Case Release Mitigation Measures 
The multiple layers of preventive measures make it very unlikely that a significant HF release will occur. In addition, in the unlikely event that a release occurs, Elf Atochem has an array of mitigation measures to reduce any potential impacts. Passive mitigation systems include diking to limit the spread of HF and, consequently, the release impact. The diking area is filled with limestone to partially neutralize spilled HF. 
Active mitigation systems cannot be considered in modeling worst-case scenario impacts, but the significant investment that Elf Atochem has made in active mitigation measures should effectively reduce the risk associated with an RMP incident. These include: 
 An HF vapor suppression system (deluge system), which can be supplemented by stationary and portable fire monitors, to knock down HF vapor with water sprays. 
 HF could be pumped from a damaged tank into another storage tank to reduce th 
e amount potentially released. 
 Diking system is provided with a drain to a trench with a pumping system that can be manually activated to contain and collect any spilled HF.  The dike is filled with limestone which serves to neutralize the spilled HF. 
 HF tanks are under continuous observation to detect any problems, including operator visual inspections (4 to 6 times a day), video camera surveillance, and both local and control room indicators for pressure and tank level/alarm. 
 HF field sensors are located at the HF feed pumps and the HF rundown tank to provide early warning of any release. 
 All operators are trained to respond to emergencies through the facility HAZWOPER Training Program. 
Hazard Assessment - Alternative Release Scenario 
One alternative scenario for each regulated toxic substance was also modeled in the hazard assessment. A description of each of these scenarios follows. The Alternative Release Scenario for HF is failure of an unloading line from a rail ca 
r. The Alternative Release Scenario for chloroform is failure of a piping flange in the storage area. The Alternative Release Scenario for Hydrochloric Acid (>37% solution) is overfilling of an atmospheric pressure storage tank. These Alternative Release Scenarios are somewhat more likely than the Worst-Case Scenario, but are still very unlikely events. This Risk Management Plan includes information on mitigation and prevention measures implemented by Elf Atochem to reduce the risk of these types of events. 
Alternative Release Scenarios: Mitigation Measures 
While the Alternative Release Scenarios are, by definition, more likely than the Worst-Case Scenario, they are still very unlikely given the facility's prevention program. If a release should occur, Elf Atochem has an array of mitigation measures to reduce any potential impacts. Examples of mitigation measures that would lessen the impacts of the Alternative Release Scenarios are listed below. 
    HF unloading is conducted inte 
rmittenly, during daylight hours only, and under strict supervision. In the event of a leak, the nitrogen system and HF unloading pumps can be quickly shut down. 
    If a release should occur, the loading rack has an HF vapor suppression system, which can be supplemented by stationary and portable fire monitors. 
    The loading rack is equipped with both video cameras and an HF field sensor to provide early warning of any release. 
    The Chloroform Storage Area is diked to contain any accidental release of liquid chloroform. 
    Redundant tanks and pumps exist so that the material from one tank may be transferred to the other if necessary. 
HCl >37% solution 
    There are redundant storage tanks and pumps so that if one tank reaches a high level the other tank can be utilized.  If one pump fails, the tank can be emptied with the spare pump. 
    If the tank should overfill, the area is contained.  Any spill would flow to the wastewater system where the acid would be neutralized a 
nd disposed. 
Chemical-Specific Prevention Steps:  
Worst Case Scenario 
Measures that would prevent the HF storage tank failure center on the design, construction, and inspection of the tanks. These measures include: 
    HF storage tanks are pressure vessels which are designed and constructed in accordance with American Society of Mechanical Engineers (ASME) pressure vessel standards using industry-standard materials of construction. 
    As part of the Mechanical Integrity program, pressure vessels and atmospheric storage tanks are inspected and tested according to the American Petroleum Institute Standard 510 and Standard 653, respectively. 
    The risk of over-filling is addressed by the high-level alarms. 
    The risk of over-pressure is addressed by a system of rupture disks and pressure relief valves, and the unloading pump is designed so that it cannot create a pressure higher than the relief valve setting. 
    All systems are tested on a routine basis to ensure reliability. 
are vented to a common line which helps prevent unequal pressures and over-pressure. 
    Tanks are located in areas with no overhead construction or equipment that could fall and impact a tank. 
    Access to the facility is restricted through security barriers and trained security personnel, thereby minimizing the risk to the tanks of vehicular damage or sabotage. 
    No flammable materials are allowed near the HF tanks, construction throughout the facility is non-combustible, and fire hazards are strictly controlled. 
The alternative release scenario selected for HF is the full failure of the rail car flexible liquid line connection during unloading. HF rail cars are unloaded using nitrogen pressure applied to the rail car's vapor space while the material is pumped to the storage vessels. This is an unlikely scenario, and the most likely cause of such a failure would be for the rail car to be pulled away while the loading line is still connected. Prevention steps for this scenario i 
    Rail stops (or wheel chocks) to prevent movement of the car. 
    Steel cables that secure the car front and rear. 
    Signage that indicates the car is unloading. 
    Careful control of the switch crew by Elf Atochem, with procedures that prohibit hooking up to a car that is still connected. 
    Automatic valve in the HF pump discharge line that closes automatically when the pump shuts down to prevent back flow from the tanks. 
    The unload hose is pressure tested at each use and replaced every 6 months regardless of condition. 
The alternative release scenario for HCl is overfilling of a product storage tank. HCl is continuously produced in the production process and piped to a series of storage vessels. Manually-controlled transfer occurs from tank-to-tank to manage product inventories. Prevention steps include: 
    Standard operating procedures. 
    Visible tank level indicators and alarms. 
    Operator attention during HCl transfer. 
    Radio communication between the cont 
rol room and tank farm is used to carefully control the operation and to minimize the likelihood of tank overfilling.. 
The alternative release scenario for Chloroform is failure of a piping flange at the storage tank. Chloroform is a raw material that is received via pipeline to a series of storage vessels. Manually-controlled transfer occurs from tank-to-tank to manage product inventories. Prevention steps include: 
    Standard operating procedures. 
    Visible tank level indicators and alarms. 
    Operator attention during Chloroform transfer. 
    Piping and flanges are routinely inspected for mechanical integrity and monitored for developing leaks. 
Five-Year Accident History 
From the beginning of 1994 to the present, there have been no accidents/releases of regulated substances from covered processes that meet EPA criteria for the Five-Year Accident History, which are focused on serious accidents with either onsite deaths, injuries, or significant damage; or known offsit 
e deaths, injuries, property damage, or environmental damage. Elf Atochem realizes that the community may also be interested in smaller releases or regulated chemicals that do not meet EPA criteria for the Five-Year Accident History. We have been diligent in reporting releases of hazardous materials and internally investigate and correct the causes of such releases. 
Emergency Response Plan 
A written emergency response plan is maintained at the facility. The plan was developed in cooperation with civil authorities and was coordinated with the community emergency response plan. 
The emergency response plan includes procedures for notifying civil authorities and the public in the event of an incident. The plan also includes documentation of proper first-aid and medical treatment necessary to treat accidental human exposures; procedures for the use of emergency response equipment and for its inspection and testing; a description of the training program for all employees in relevant emerg 
ency response procedures; and procedures for review and update, as appropriate, of the emergency response plan to reflect changes at the facility, and to ensure that employees are informed of these changes. 
Planned Changes to Improve Safety 
Most of Elf Atochem's Wichita facility processes are covered by the OSHA PSM rule and therefore stringent safety programs have been in place for years.  Prevention measures such as Management of Change (MOC) and Pre-Startup Safety Review (PSSR) are utilized at this facility even for processes not covered under PSM or RMP.   
Elf Atochem continually searches for potential safety improvements.  One such improvement that has been identified, by adding all chloroform systems to the mechanical integrity inspection program, is to replace old chloroform receiving piping and more safely route such piping by utilizing a pipe rack.
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