OLIN CORPORATION MCINTOSH, ALABAMA PLANT - Executive Summary |
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OLIN CORPORATION McINTOSH, ALABAMA The Olin facility in McIntosh, AL. is a part of Olin Corporation; headquatered in Norwalk, CT. Most of the 300 employees at the McIntosh facility live in Washington , Mobile, and Clarke counties. Olin employees are involved in the communities and care about the environment which all of us in Southen Alabama share and enjoy. Maintaining open, positive relationships with the communities is a priority at our plant. We understand that we are an intergral part of the community. We support the Olin Community Advisory Panel which was formed in the early 1990's and is comprised of communtiy members who represent business, education, religion, and youth interests. Bi-monthly, members gather with plant management to share information on topics of mutual interests. Annually, representativ es of the McIntosh panel join members from other Olin panels across the country for an Olin Community Advisory Panel Conference. At this conference, community members work with Olin to enhance the panel's effectiveness by sharing success stories. Many items we use every day depend on the products manufactured at the Olin McIntosh Plant. Our primary products; chlorine, and caustic soda, are used to make everything from paper products, clothing, clean water, household bleach, and pharmaceuticals, to plastics, vinyl products, antifreeze, fuels, and paints. 1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: For many years Olin has had a safety and environmental program, which relies on the fundamental belief that all accidents are preventable. Our goal is "Zero" incidents. To help insure that an emergency situation with offsite implications is unlikely to occur, Olin has put six layers of safety protection in place: Employees, Mechanical Integrity, Process Hazard Reviews, Process Controls, Safety Systems, and Emergency Preparedness. At the Olin, McIntosh, Alabama facility, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs 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 comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * An overview of planned improveme nts at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The detailed information (called data elements) about our risk management program 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES: The Olin, McIntosh, Alabama facility produces Chlorine, Caustic Soda, Sodium Hypochlorite, Hydrogen, and Sodium Chloride (Salt), using a variety of chemicals and processing operations. Our facility first began production of chlorine and caustic soda in 1952. In 1977 and again in 1997, Olin completed major expansions of the facility, utilizing the newest technology available at the time. Besides the Chlor-Alkali processes, Olin also operates a facility for Arch Chemical Company (formerly Olin Specialty Chemicals) for the blending and storage of hydrazine components for the United States Air Force. These components are used in the Titan space launch vehicles, which have been the Air Force's principle launch system since the mid 1960's. They are also used in satellites for positioning and to operate on-board power systems . In our processes, we use the following RMP covered chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release (Chlorine and Hydrazine components): TOXICS: Most of the chlorine produced at the Olin McIntosh facility is shipped to our customers via the railroad, except for a small amount that is shipped by pipeline to our local industrial neighbors. Because loaded railcar volumes are also included in the facilitys' process capacity, our on-site volume for chlorine equals approximately thirty-one million pounds. Of this volume, twenty-seven million pounds can be attributed to potential railcar storage volumes. Our actual railcar volumes average between four and eight million pounds per day. Once these railcars are received by the local rail carrier for shipment, they are no longer covered by the RMP regulation, but fall under the jurisdiction of the Department of Transportation. Our on-site stationary storage capacity makes up the other four million pounds, with the average daily volumes near one million pounds. The Arch Chemical Company facility that Olin operates at McIntosh, includes the unloading/loading, blending, storage and repackaging in smaller containers, the hydrazine components, Anhydrous Hydrazine, 1,1-Dimetylhydrazine, and Methyl Hydrazine Also included in the RMP list of Regulated Substances and handled at the McIntosh facility, but exempt from the regulation are Hydrogen, and Hydrochloric Acid solutions. In the case of Hydrogen, the volume on site is slightly more than 100 pounds. The volume for coverage under RMP for flammables is 10,000 pounds or greater. This product is shipped by pipeline to near industrial neighbors to be used as fuel or to be processed into a liquid form. Hydrochloric Acid solution falls under RMP regu lation in concentrations of 37% or greater. At the Olin, McIntosh facility, guidelines are in place to ensure that we do not receive shipments of Hydrochloric Acid that exceed this range. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use, manufacturing or handling of these chemicals. 3.0 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS: We are providing information about the worst-case release scenario and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals A Worst-case Release Scenario ( by EPA definition) for our facility, would be the catastrophic failure of one of four 500 ton (administrative con trols) chlorine storage tanks resulting in a release of its entire contents over a ten minute period. No passive mitigation (containment) is to be assumed in this scenario. The weather conditions would also be unfavorable (as predetermined by the RMP regulation guidance) to dispersing of the released material as it moves to an endpoint. The "distance to the endpoint" is defined as the distance that the released material could travel before dispersing enough to no longer pose a significant hazard to the public. In this case, the distance that this volume of chlorine could impact has been determined by the EPA's OCA Guidance Reference Tables or Equations to be 25 miles. Alternative Release Scenario(s) - Regulated Toxic Chemicals For the McIntosh facility, the alternative release scenarios (one scenario for each regulated toxic chemical) includes chlorine, and the hydrazine components listed above. In the case of chlorine, the alternate release scenario would be the complete rup ture of an one inch rail car transfer hose during loading activities. Immediate response from our operating personnel, who continuously monitor loading activities , coupled with an emergency shutdown system, and excess flow valves built into the rail cars, would limit the amount of chlorine released to 490 pounds for a five minute release. Using the EPA supplied RMP Comp. the distance that could be impacted is estimated to be up to 0.20 of a mile. Potential receptors at this distance would include near residences, and other near industrial sites. The regulated hydrazine chemicals, Hydrazine, 1,1-Dimethylhydrazine, and Methyl Hydrazine are all contained within the A-50 Plant. The activities for loading/unloading, blending, and storage are identical for each of these regulated substances. Therefore, the alternative release scenario for each has been identified as the rupture of a transfer hose during loading/unloading activities. Should such a rupture occur, the released materia l would be captured in a concrete containment area that drains to either a sump or holding tank. Operating personnel would respond by donning the appropriate personnel protective equipment, activating a deluge system to mitigate vapors, and stop the loading/unloading process by activating an emergency shutdown system. Estimated response time for such activities is 5 minutes. Again using EPA's RMP Comp. it has been determined that the impact distances for each of these scenarios would be: ( Hydrazine - 66 lbs. - 0.10 Mile ), (1,1-Dimethylhydrazine - 650 lbs. - 1.0 Mile ) and ( Methyl Hydrazine - 490 lbs. - 0.70 Mile ). Like the chlorine scenario, the potentially impacted receptors would again include the near residences and the other near industrial facilities. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS: We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address e ach of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5.0 FIVE-YEAR ACCIDENT HISTORY: We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: The Olin, McIntosh facility has experie nced one accidental release of a EPA regulated substance; chlorine, in the past five years. On 9/13/97, a 17 pound release occurred, and simultaneously a member of the near community reported a potential exposure and was provided medical treatment. For this incident, we have a conducted formal incident investigation to identify and correct the root causes of the events. 6.0 EMERGENCY RESPONSE PROGRAM: We maintain an emergency response plan, which provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the Washington County, Alabama Emergency Response Plan and work in partnership with the Washington County LEPC (Local Emergency Planning Committee). We maintain an Emergency Response Team onsite at all times. Members of this team are trained in hazardous material, fire, and rescue operations. Most of these members are also trained as medical responder s. Our Emergency Response Team routinely participates in joint training and drills with other members of the industrial park and the local fire departments and rescue squads. We also have a certified HAZMAT team that is capable of responding to offsite incidents involving transportation of our products. Our facility also maintains two methods of notification to the community should an incident occur; the Community Evacuation Alarm system and the Home Alert (Micro Siren Receiver) system. The Community Evacuation Alarm system consists of four alarms that are strategically located throughout the communities at Reed's Chapel School, McIntosh Fire Station, Olin's barge loading dock, and Olin's brinewell field. If needed these alarms would be activated by an operator in our Process Central Control area . The Home Alert (Micro Siren Receiver) system is utilized by members of the McIntosh Industrial Park, and allows for notification directly to individual homes and businesses within a three-mile radius of our facility via hand held radios. Should an incident occur, this sytem would be activated by the on-site Incident Commander, responsible for directing the response activities. 7.0 CHANGES TO IMPROVE SAFETY: The following is a list of improvements that we are planning to implement or have completed implementation at the facility to help prevent and/or better respond to accidental chemical releases: * REPLACEMENT OF THE DIAPHRAGM PLANT (EVS) EMERGENCY VENT SCRUBBER (Completed 2nd Qtr. 1999) : This project provided for a replacement of an existing chlorine gas scrubber with one that incorporates significant advances in scrubber technology. During plant start-ups, shut-downs, and upsets, wet chlorine gas is neutralized in the scrubber using dilute caustic to form, sodium hypochlorite solution, caustic, and salt. *UPGRADE OF CHLORINE MONITIORING SYSTEM (Completed 1st Qtr. 1999) : This enhancement of our existing process area and plant perimeter chlorine gas monitoring provides early detection of chlorine leaks or equipment failures causing chlorine to be released into the atmosphere. Early warning systems with accurate and appropriate information are a critical part of this facility's overall Safety program. This information is necessary for operations personnel to mitigate or minimize the effects of a chlorine release and allows for prompt community notification. *INSTALLATION OF EMERGENCY SHUT-OFF SYSTEM FOR CHLORINE LOADING (Completed 2nd Qtr. 1999): This project provides a positive means to isolate both ends of the flexible chlorine loading hose. The original system allowed for only the automatic isolation of valves upstream of the flexible loading hose requiring the valves on the down-stream side (railcar valves) to be closed manually. This new system will provide isolation for both side s of the flexible loading hose should the railcar move excessively, if a leak occurs in the flexible hose during loading activites (the Alternate Release Scenario), or through manual activation of the emergency shut-off switches. |