DuPont Chambers Works - Executive Summary
Accidental Release and Emergency Response Policies |
At DuPont Chambers Works, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We follow the DuPont Corporate philosophy that the "goal is zero". This means we constantly strive for zero process safety incidents, zero environmental incidents and zero injuries. We have programs, procedures and management practices in place to support this goal of zero. We constantly assess our progress against this goal of zero and take corrective actions to get back on track whenever necessary.
Our primary focus is on prevention of any accidental releases. However, we have strong emergency response capabilities to back-up our prevention activities. We use this combination of prevention programs and emergency response capability to help ensure the safety of our employees and the public as well as protection of the environment.
This document provides a brief overview of the compr
ehensive risk management activities that we have designed and implemented, including:
- A description of our facility and use of substances regulated by EPA's Risk Management Program regulation;
- A summary of results from our assessment of the potential off-site consequences from accidental chemical releases;
- An overview of our accidental release prevention programs;
- An overview of our emergency response program;
- A five-year history of accidental releases of chemicals regulated by EPA's RMP rule;
- An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment;
Stationary Source and Regulated Substances
The DuPont Chambers Works facility first opened in the early 1900's as a dye manufacturing plant. We now produce in excess of 500 different products using a variety of chemicals and processing operations. Our products are used to make clot
hing and textiles, computer chips, personal care products, agricultural chemicals and paint. We also make unique types of rubber, greases and oils to meet the special needs of other manufacturing industries.
In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant off-site consequences in the event of a substantial accidental release:
Hydrochloric acid greater than 37% strength
Hydrofluoric acid greater than 50 % strength
Nitric acid greater than 80% strength
Key Off-site Consequence Analysis Scenarios
To help with understanding the potential impact on the community due to a release of chemicals from DuPont Chambers Works, we have provided information about the worst-case release scenarios and alternative release s
cenarios for our facility.
These scenarios were developed using the guidance and technical data supplied by the EPA. Scenario information similar to that described below has been used on Chambers Works for many years as part of our process safety management program. In the past we have modeled potential releases and analyzed the results to help us continuously improve our processes and reduce risk. We continue to do these assessments as part of our internal process safety management systems.
The EPA defines the worst case scenario as a hypothetical release of the largest quantity of a regulated chemical. The scenario assumes the entire quantity is released in ten minutes, even if it is impossible to do so.
Using the methods described by the EPA, the worst case release of a flammable chemical from Chambers Works would be the release of the entire contents of our vinylidene chloride storage tank in a 10-minute period. The scenario assumes the cloud would igni
te, resulting in a vapor cloud explosion of the released material. The pressure wave generated from the explosion would barely leave the site boundary. This event would not be expected to expose the public to the amount of pressure of concern to the EPA, but an explosion like this would be heard and possibly felt off the Chambers Works site.
Also using the methods described by the EPA, the worst case toxic scenario is the release of the entire contents of a chlorine railcar in a 10-minute period. Using EPA guidelines, a release like this could significantly impact the public off the Chambers Works site. Depending on the wind direction at the time of the release, New Jersey, Delaware, Maryland or Pennsylvania could be effected.
The worst case scenarios described above underscore the need for very rigorous process safety management systems. It is important to note however, that none of the prevention and mitigation equipment, practices, and procedures that have been
put in place by DuPont Chambers Works to prevent or respond to releases such as these are taken into account for these worst case scenarios.
In order to facilitate emergency response planning with the community, the EPA has included the requirement for companies to report alternate case scenarios. These alternate case scenarios provide a realistic picture of what could actually happen if the safety systems used by a facility were to fail.
The EPA requires that companies include one alternate release scenario for regulated flammables as a group and one for each regulated toxic chemical. This is because the impact of a flammable scenario on the public is expected to be similar for all the different types of flammables. The toxic chemicals can vary in their effects and so must be reviewed individually. In the data elements section of this report you will find a detailed description of all these alternate release scenarios.
The alternate case for flammables on
Chambers Works is the complete, catastrophic failure of an unloading flex hose while transferring vinylidene chloride to the storage tank. In this scenario, 419 pounds of vinylidene chloride is released and ignited, resulting in a flash fire. This scenario has an impact distance of about 300 feet and does not extend off-site. Of course, we still have accident prevention activities in place to protect our employees from injury.
The largest and most significant toxic alternate case scenario for DuPont Chambers Works is a large leak at the man-way cover gasket on our 67% Oleum storage tank. This could result in over 1,000 pounds of Oleum spilled into the tank secondary containment. Under the normal weather conditions at the site, this release could go almost a mile before the toxic concentration falls below a level of concern. Because of the tank location, about a half mile of the release distance is off the Chambers Works site. The chemical would travel in the direction of
the wind, and be more concentrated closer to the site. Depending on the wind direction, the release could impact residences and a small park just outside the plant fence line. It could also impact several businesses and restaurants along Route 130 near the Chambers Works site, and the NJ Turnpike approach to the Delaware Memorial Bridge.
Knowing the impact of a release like this, DuPont Chambers Works has many things in place to prevent releases from ever occurring. For this release scenario, examples of preventive measures include:
- An understanding of process technology to make sure the design and materials of construction of the tank, gasket and all the other components are more than adequate;
- Mechanical training and procedures to ensure that tank components are installed correctly;
- Quality assurance programs to make sure the right replacement parts are used every time;
- Preventive maintenance testing to detect a potential problem before a leak; and
Daily operator inspections to detect leaks immediately.
In addition to all we do to prevent releases, we maintain a highly trained and equipped emergency response department around the clock. They are able to respond to any releases we might have and mitigate the impact. To address a situation like the oleum storage tank, Chambers Works has an emergency response and fire truck equipped with chemical resistant foam. This foam can be sprayed over the spill and smother the fume release.
The next section contains more information about our release prevention activities.
Accidental Release Prevention Program
For many years, employees at DuPont Chambers Works have applied rigorous process safety management practices to all our processes, not just those covered by regulations. These
- A thorough understanding of our process technology including the safe limits of the processes and the proper materials of constriction for equipment;
- Proper design and installation of equipment;
- Systematic process hazard review studies to identify and manage process hazards;
- Written operating and maintenance procedures;
- Extensive training for all individuals involved in operating or maintaining a chemical process;
- Mechanical integrity testing and preventive maintenance to detect potential equipment problems early;
- Mechanical quality assurance programs to ensure the correct spare parts are installed every time maintenance work is done;
- Procedures to assess and manage the safety and environmental impact of changes to the process technology or equipment;
- Pre-startup safety reviews for equipment that is newly installed or modified;
- Compliance audits to ensure process safety management procedures are effective and impleme
- Investigation of actual and potential incidents to identify and implement corrective actions;
- Participation of all employees in the process safety management system;
- Documented safe work practices, including hot work permits; and
- A contractor management system to ensure work done by contractors is done safely and meets DuPont quality standards.
In addition to the practices described above, we have designed our processes to include multiple layers of safeguards. Examples of these include:
- Automatic valves for rail cars, which isolate the supply of materials form the rail car in event of a process upset;
- Computer display and control of process parameters;
- Process alarms to warn operators of process deviations;
- Interlocks to automatically shut down processes for certain process deviations;
- Low concentration chemical detectors that either provide alarms to operators or automatically isolate leaks if the chemical is detecte
- Relief valves to prevent over-pressuring of equipment;
- Emergency scrubbers to prevent emissions from emergency systems from reaching the environment;
- Excess flow valves that close automatically if the chemical flow rate indicates a potential line leak;
- Deluge systems built into the process to quickly suppress chemical fumes or fires;
- Check valves to prevent cross contamination of chemicals;
- Camera surveillance of process areas in central control rooms;
- Fire prevention activities like electrical grounding, inerting flammables with nonflammable gasses and hot work permitting;
- 100% operator surveillance during transfer of hazardous materials from shipping containers; and
- Minimization of hazardous material storage inventories, including manufacturing some highly hazardous materials only when we can immediately consume them to make products.
All of these individual elements of our prevention program work together to prevent accidental
Emergency Response Program
In addition to all we do to prevent potential accidental releases, DuPont Chambers Works is committed to maintaining strong emergency response capabilities to back-up our prevention activities. The site has an on-site emergency response and fire department, staffed 24 hours a day. The emergency responders are thoroughly trained and properly equipped to respond to releases of any chemicals used on our site. The site also maintains an emergency response brigade comprised of specially trained operators that can lend additional support if necessary.
Chambers Works conducts practice drills with the local community and their emergency response organizations. These drills simulate potential accidental releases and test emergency response plans. Chambers Works also supports
a siren system in the local community that would provide early warning for a potential release. This system is coordinated with the Salem County Office of Emergency Response.
In addition to these on-site activities, Chambers Works also maintains transportation emergency response capability, which allows the site to respond to chemical transportation incidents outside the Chambers Works site.
Five-year Accident History
There have been no off-site injuries, evacuations, sheltering in place, property damage or environmental damage due to the accidental release of regulated substances from the DuPont Chambers Works plant in the past 5 years.
However, Chambers Works did have one internal incident in the past 5 years that meets the criteria for reporting. In October of 1996, two operators were injured
by nitric acid when one of the operators removed the end cap on an acid drain line. The drain line cracked at the base of the pump, spraying both operators with the acid.
As a result of this incident, equipment has been upgraded, operating and maintenance procedures have been revised, and additional training was provided.
Planned Changes to Improve Safety
As part of our process hazards review procedures, all of our processes are thoroughly studied on a periodic basis to identify risk reduction opportunities. As a result of these studies, we are currently implementing, or are in the planning stages to implement, the following risk reduction activities:
- Installation of more chemical specific monitors for early leak detection;
- Upgrading the materials of construction of some process equipment;
- Improving the control of the process by installing better instrumentation, more automatic process shutdown interlocks, and upgraded computer control systems;
- Improving pr
eventive maintenance inspections and data analysis;
- Improving our training programs; and
- Conducting process safety audits to identify any deficiencies in our management systems.