Marchem Technologies - Executive Summary |
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EXECUTIVE SUMMARY The Risk Management Plan (RMP) has been prepared for Marchem Technologies, LLC (Marchem) facilities at 20851 South Santa Fe Avenue, Long Beach, California in accordance with the requirements of the California Code of Regulation (CCR) Title 19, Division 2, Chapter 4.5 (California Accidental Release and Prevention Program [CalARP]). Marchem manufactures surface-active agents (surfactants) and has an SIC Code of 2843. Four state regulated acutely hazardous materials are used, handled, or stored for manufacturing processes above the State Threshold Quantity (STQ): dimethyl sulfate, epichlorohydrin, ethylene oxide and propylene oxide. Processes handling these substances were determined to be eligible for Program 3 requirements. A Hazard and Operability (HAZOP) Team was established by Marchem to conduct HAZOP studies and Process Hazard Analyses (PHAs) during the first calendar quarter of 1999. During this time period, all previously conducted HAZOP studies and PHAs w ere reviewed and updated to incorporate recent process changes and modifications at Marchem's facilities. The HAZOP Team consisted of the plant manager, plant operation manager, process operators, facility maintenance personnel, laboratory staff and outside technical consulting professionals from PES Environmental, Inc. The guideword approach was used in conducting HAZOP studies and PHAs to identify hazards. Identified risks were assessed for likelihood and severity. Using the risk matrix from Appendix M, Region I LEPC, CalARP Implementation Guidance Document, each risk was evaluated as being acceptable, acceptable with controls, undesirable, or unacceptable. Based on each evaluation, remedy action issues were identified, discussed, and recommended for implementation. The HAZOP Team also conducted an External Events Analysis. The following external events were determined to have a reasonable probability of occurrence and were evaluated: aircraft impact, external flooding, extreme winds, hail, high summer temperature, lightning, missile impact, sabotage, seismic activity, and transportation accidents. Missile impacts that may result from extreme winds, high summer temperature, lightning and seismic activity were found to present the greatest risk with undesirable or unacceptable consequences. Details of the analyses and risk evaluation along with resulting recommended actions are provided. Off-Site Consequence Analyses were conducted for four release scenarios to evaluate human health and environmental impacts associated with an accidental release. Each release scenario considered the most conservative conditions that would result in the greatest off-site impacts. The first scenario, the worst case scenario as defined by Section 112 r (7) of 40 CFR Part 68 for a toxic gas, is the release of the maximum quantity of ethylene oxide in storage over a period of ten minutes. This was chosen as the tank car release, since the storage tank is passively mitigated by location as an underground storage tank. Based on air dispersion modeling using average meteorological conditions, four alternative accidental release scenarios were identified during the HAZOP studies, PHAs and/or external event analyses. These release scenarios involved: a) the rupture of the ethylene oxide vapor return line during a seismic event while unloading a tank car, actively mitigated by detection of the spill and shutdown of the system; b) the rupture or failure of the propylene oxide loading line during a seismic event, c) the rupture of the DMS conveyance line to the process area, actively mitigated by operator in charge of process whenever system is running, d) the spill of epichlorohydrin in the drum storage area as a result of a forklift accident. These release scenarios were determined by the HAZOP Team to be likely and credible, being associated with either the compounded failure of administrative process controls, mechanical integrity, safety systems, or a s erious external event. A detailed description of all incident categories that could have involved the four acutely hazardous materials processed at the Marchem chemical manufacturing facility during the past five years is provided in Section 3.0. During this period there have been no reportable incidents at Marchem in the following categories: personnel injury or illness, environmental release, and community exposure beyond Marchem's property boundary. Marchem has prepared, maintains, and conducts periodic training of its Emergency Action Plan. This plan describes the procedures by which an emergency response is handled by the management team and operators at Marchem. All employees at Marchem, including on-site contractors, are periodically trained on the Emergency Action Plan. A detailed discussion of the plan is provided at Section 5.0. The following process safety related recommendations are being are being reviewed for appropriate implementation at the Marchem facility: 7 I nstallation of seismic ground motion sensors at strategic locations in the plant process areas that would be interlocked into the facility Emergency-Stop system. 7 Conduct a structural engineering evaluation of the warehouse structure and the steel frame structure in the process area. 7 Construction of a containment dike for the epichlorohydrin drum storage area to confine the surface area extent of a spill should it ever occur. 7 Installation of interlocking control devices throughout the process area to: control hazardous material unloading operation from tankers and rail cars; monitor the storage of these materials; control the conveyance of these materials from the storage area to the process area; and, control the process of chemical manufacturing in the reactor area. |