Albemarle Corporation West Plant - Executive Summary

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About our Facility: 
    The West Plant Facility is located in rural Columbia County, about five miles west 
of Magnolia, Arkansas.  Land use in the immediate vicinity of the site is primarily 
agricultural, with silviculture and animal operations predominating.  The plant is located 
on the south side of a low hill or ridge between two intermittent streams. 
    The location of the plant is due to the presence of natural brine deposits located 
about 1.5 miles beneath the plant.  These brines are withdrawn through a system of 
wells and processed to produce bromine and hydrogen sulfide, and then replaced into 
the same geologic formation by a second system of wells.   
    The West Plant produces bromine, sodium hydrosulfide, and 
hexabromocyclododecane. 
About our accidental release prevention and emergency response policies: 
    The West Plant Facility has very active accidental release prevention and 
emergency response programs.  It is the policy of the West Plant Facility to reduce the 
r 
isk of chemical release to the extent feasible.  The main vehicle for chemical risk 
reduction is the Process Safety Management (PSM) program.  When the OSHA PSM 
standard was promulgated, existing programs were subsumed into the PSM program 
following the OSHA standard.   
    The Policy of the West Plant is to first prevent the occurrence of emergency 
situations, but if prevention measures are unsuccessful, to respond to those situations 
in a professional and appropriate manner.  The site has an integrated Emergency Plan 
which follows EPA's "One Plan" concept.  West Plant personnel respond to 
emergencies on site with a trained fire brigade, HazMat responders, and a corps of 
trained EMTs.  The emergency plan provides for coordination with local care givers, first 
responders, law enforcement, and the county emergency response infrastructure 
through the county-wide emergency plan.   
    Briefly, if a chemical incident appears to have the potential for off site impact, the 
local County Eme 
rgency Coordinator would assume situational control, while West 
Plant personnel work to mitigate the problem.  If a situation has impact beyond the 
borders of Columbia County, the county-wide emergency plan provides for coordination 
with adjoining counties and parishes. 
    All of our south Arkansas facilities use the same basic accidental release 
prevention and emergency response programs.  Using the same plan makes training 
easier and coordination with local off site responders better.  Details of the emergency 
plans (such as maps; locations of response equipment) are different due to the physical 
differences in the facilities. 
Regulated substances handled at the West Plant: 
    The West Plant was known to handle four listed chemicals in two processes.  
Information on the handling and storage was gathered.  Three chemicals in two 
processes were found to be subject to the RMP rule.  The accidental release prevention 
and emergency response programs are exactly the same for covered an 
d non-covered 
processes; covered and non-covered chemicals are both subject to both programs. 
    The Risk Management Program has been incorporated into the PSM program to 
provide continuity.  A description of our risk management program is found below.   
Our accidental release prevention program: 
    We have included chemical specific steps for release prevention under each 
alternate-case scenario. 
    The West Plant Facility is subject to the OSHA PSM standard.  We have internal 
procedures which drive compliance with both the OSHA PSM standard and the new 
EPA RMP standard. 
    We have compiled detailed information on all process (both covered and non-covered) which includes hazard information on each substance, technical process 
information, and process equipment information.  This information is used in the 
Process Hazard Analysis (PHA). 
    PHA's have been conducted on all processes, and are repeated according to a 
regular schedule (maximum of 5 years) or when certain events t 
rigger performance of 
the PHA.  The PHA identifies any and all possible mishaps, the likelihood and 
consequences of mishaps, and predicts how safety and mitigation systems will perform 
in the event of a mishap.  For each PHA, a team is formed which possesses the 
requisite expertise in engineering, process operations, hazard analysis, industrial 
hygiene, safety systems, and emergency response.  Several standard methods may be 
used to analyze the available information, and more than one method may be applied 
to a process hazard analysis.  The PHA documentation is retained for the life of the 
process.  This information is used to eliminate hazards when possible, and mitigate 
those hazards when elimination is not possible or impractical. 
    Standard Operating Procedures (SOPs) exist when each process is first started 
up, and undergo continual review and improvement.  Some of the items included in 
SOP's are procedures for start-ups, shut-downs, routine or hazardous procedures, 
operation o 
f safety and environmental control systems, and mitigation of process 
hazards.  SOPs are updated to reflect current operating conditions.  Each SOP is 
reviewed no less often than annually. 
    Training is the key aspect of accident prevention.  Each employee in an 
operating process receives job specific and general training on safety and health 
hazards, emergency operations, and safe work practices.  This training is administered 
according to the needs of the employee and the specific requirements of the program.   
    Preventative Maintenance (PM) is an integral part of our accidental release 
prevention program.  Our PM program addresses equipment and controls whose failure 
could lead to injury, significant release, or property loss.  The program includes regular 
inspections and tests of process equipment consistent with manufacturer's 
recommendations, good engineering practices, and field experience.  Documentation of 
the results of tests and maintenance is maintained.   
    When  
a new or modified system is started up for the first time, the likelihood of 
unexpected consequences is increased.  For this reason, pre-start-up reviews are 
conducted with the aim of insuring that: design specifications are adequate and have 
been met; adequate safety, operating, maintenance, and emergency procedures are in 
place; and that employee training is adequate and has been completed. 
    Many historical accidents may be traced to a seemingly minor or inconsequential 
process change.  We manage process changes through a system that insures the 
impact of a change is assessed and appropriately addressed before the change is 
implemented.  Part of this program (Management of Change) is communication of the 
change and anticipated effects to all affected employees, and training provided as 
necessary. 
    To assure compliance with this program, regular audits are conducted.  
    We make every effort to minimize risk through training, preparation, and 
planning.  Yet an incident may o 
ccur.  When an incident occurs, an investigation is 
performed to determine the root causes for the incident and to recommend corrective 
action to prevent a reoccurrence.  These investigations are performed on minor (even 
trivial) incidents.  Lessons learned on trivial (no impact) and "near miss" incidents often 
can often be used to teach us how to avoid more serious consequences.  
Documentation of the investigation is maintained.   
    The best source of information about process hazards is employees who work in 
an existing process.  Line employees are an integral part of our process of chemical 
hazard analysis.  Employee access to the results of PHAs and other aspects of the risk 
management program is insured and encouraged. 
    We use a permit system to insure that all aspects of a job (non-routine) must be 
considered before performing that job.  Each process issues Safe Work Permits for non 
routine jobs done in that area each day.  Permits generally expire at the end of a shift 
an 
d are critical to communicating jobs in progress within a process area.  A Safe Work 
Permit may require the permittee to initiate and complete a Hot Work Permit before 
performing certain tasks.  Sometimes, tasks involving welding, cutting, braising, or other 
flame or spark producing activities, must be performed in areas where flammable 
chemicals are present.  Hot work permits insure fire prevention and protection 
requirements have been implemented prior to beginning the work.  Another essential 
part of the risk management program is the use of "lock out/ tag out" procedures.  
When a safe work permit is issued, the permit requires the permittee to assure that all 
sources of potential energy have been deactivated.  For instance, the permittee may 
perform the following procedures before working on a pump: Check the Safe Work 
Permit to make assure operations has purged and drained the pump; check the red 
tags in place to make sure the pump is isolated from the process; and place a persona 
l 
locking device on the electrical switchgear energizing the pump.  No employee can 
remove a red tag, actuate a tagged component, or remove a personal locking device 
placed by another employee.   
    We depend on contractors and contract employees for many essential services.  
Under our PSM program, we insure that contractor preformed maintenance, repair, and 
general operations are preformed safely.  Contractors are fully informed of the potential 
hazards of the relevant processes and applicable portions of the facility emergency 
response plan.  The contractor, in turn, must control the entry, presence, and exit from 
process areas.  The contractor, as a condition of employment, must adhere to all facility 
safe work standards and practices.   
    You will find specific prevention program information in section 7 of this plan.  
Section 8 does not apply to this facility. 
Facility five year accident history: 
    The West Plant has been relatively free of offsite consequences.  The EPA R 
MP 
program requires reporting on "regulated" chemicals in "covered" processes in the five 
years proceeding the date of RMP submission.  Although the West Plant does not have 
any incidents which meet the EPA criteria, we have had releases of chemicals which 
had offsite consequences. 
    Periodically, neighbors call and report odors.  These reports are investigated and 
a serious attempt is made to determine the origin of the odor.  If the odor is found to be 
originating at the West Plant, all efforts are made to mitigate the odor at the source. 
    There have been releases in the past with potential offsite consequences.  One 
example is the 1984 release of chlorine caused by a failure of a 1.5" chlorine vapor line.  
(This incident was used as the basis for the chlorine ACS.) Stable atmospheric 
conditions carried the vapor cloud to the west, where some vegetation on facility 
property was affected.  A different wind direction could have necessitated an offsite 
response. 
Facility emergenc 
y response program: 
    Our emergency response plan is in the format developed by EPA.  This format is 
commonly known as the "One Plan."  This particular format was developed to address 
the off site responder need for simplicity while complying with all regulatory 
requirements.   
    The emergency response program is based on the principle that the facility 
should respond to incidents within the scope of the facility's expertise, while the local 
authorities respond within the scope of the Columbia County Emergency Response 
Plan.  This means that the facility is responsible for preventing incidents before they 
happen.  But if a incident does occur, the facility is responsible for mitigating the offsite 
consequences of the incident by source control.  The Columbia County Department of 
Emergency Management is charged with implementing the Columbia County 
Emergency Plan and coordinating the response.  The Columbia County Emergency 
Plan was developed by the Columbia County Local Emergency 
Preparedness 
Committee (CCLEPC) under the direction of the Columbia County Emergency 
Response Director with the aid of the Columbia County Judge. 
    The West Plant Emergency Plan contains procedures for response to chemical 
releases, fires, and natural disasters.  Provision is made for informing the public through 
responsible officials according to the provisions of the County Emergency Plan.  The 
emergency plan describes the location and mode of use of specialized emergency 
response equipment.  The plan also describes the delivery of medical treatment for 
injuries. 
    Public awareness is an important component of an emergency response 
program.  The South Plant facility maintains continual contact with the public through 
regular meetings of the Community Advisory Panel (CAP).  The CAP advises the facility 
on the need, frequency, and effectiveness of public communications.  
Planned changes to improve safety: 
    The best way to protect the public is by preventing accidents.  We us 
e the 
Process Safety Management process to identify and prevent chemical releases.  The 
PSM process drives continual improvement in process safety. 
    Offsite, the facility has been active in supporting (through donations, participation 
and membership) the CCLEPC since its formation in 1987.  EPA's implementation of 
the Clean Air Act Amendments of 1990 caused us to examine, and plan for, incidents 
which are extremely unlikely.  As a result of this examination, the entire emergency 
response process has benefitted.   
    Two CCLEPC initiatives are worthy of mention.  The first is the filming of a public 
service video, which instructs the public how to "shelter in place."  The second is the 
purchase and installation of an automated telephone system capable of calling citizens 
likely to be affected by a chemical emergency or natural disaster and delivering specific 
instructions.   
General comments about chemical release scenarios: 
    All release modeling included in this plan comes fr 
om EPA's "Off Site 
Consequence Analysis Guidance," May 24, 1996, extensively revised April 15, 1999.  
Endpoint distances were calculated using the EPA provided tool "RMP Comp, Ver. 
1.06."  Results from other versions of "RMP Comp" may not match the results of Ver. 
1.06, the latest version available in May 1999.  The Worst Case Scenario (WCS) is 
rigidly defined by the RMP rule.   
    For simplicity's sake, we have used the recommendation of EPA guidance for 
atmospheric conditions.  For the WCS, this is a temperature of 77 deg. F., wind speed 
1.5 meters per second, atmospheric stability class F.  For the Alternate Case Scenarios 
these conditions are 77 deg. F., wind speed 3.0 meters per second, and atmospheric 
class D.  In both WCS and ACS, the forested, rolling terrain around the West Plant is 
characterized by a surface roughness factor "urban."  When interpreting impact, it 
should be remembered that an actual release travels in the direction of the prevailing 
wind, and does not disper 
se much toward the sides of the centerline of the direction of 
travel.  Information on the Toxics WCS is found in section 2 of this plan; section 3 
contains Toxics ACSs.  The West Plant does not have flammables reportable under 
sections 4 and 5 of this plan. 
    The Alternate Case Release Scenarios (ACS) were developed by a 
knowledgeable panel of safety, industrial, and environmental professionals.  This panel 
reviewed several sources in developing the scenarios: Actual reported incidents; 
Process Hazard Analyses (PHAs); Data from the EPA ARIP database (nationwide); and 
collective process hazard knowledge.  Although some of the ACS may have roots in 
actual recorded incidents, the scenario may have been intentially manipulated so as to 
have off site consequences which were absent in the real incident.  For instance, two 
real incidents may have been combined to have more serious consequences (for 
modeling purposes) than did the actual incident.  The most weight was given to the 
concerns 
of the process unit leadership. 
    For public receptor identification, we used reports generated for use in the RMP 
program by Environmental Data Resources of Southport, Connecticut.  Public receptors 
were estimated from these reports, and the "Landview III Environmental Mapping 
Software" developed by the EPA and the Department of Commerce.    
Toxic chemical worst-case release scenario: 
    At the West Plant, the Worst Case Scenario (WCS) is a sudden release of all the 
chlorine in the chlorine storage tank.  The conditions are for a wind speed of 1.5 m/sec, 
atmospheric stability class F, air temperature 77 deg. F.  The forested, rolling terrain 
around the West Plant is characterized by a surface roughness "urban."  Results of the 
WCS may be found in section 2. 
    "RMP Comp" estimates the distance to the toxic endpoint as 14 miles.   
"RMP*Comp Ver. 1.06,  Results of Consequence Analysis: 
Chemical: Chlorine   CAS #: 7782-50-5 
Category: Toxic Gas; Scenario: Worst-case; Liquefied und 
er pressure; Quantity 
Released: 180,000 pounds; Release Duration: 10 min.; Release Rate: 18,000 pounds 
per min.; Mitigation Measures: NONE; Topography: Urban surroundings (many 
obstacles in the immediate area); Toxic Endpoint: 0.0087 mg/L; basis: ERPG-2. 
Estimated Distance to Toxic Endpoint: 14 miles (23 kilometers) 
Assumptions About This Scenario:  Wind Speed: 1.5 meters/second (3.4 miles/hour); 
Stability Class: F; Air Temperature: 77 degrees F (25 degrees C)." 
    This scenario is unlikely due to the robust construction of the chlorine tank, and 
the physical properties of chlorine.  A sudden loss of pressure combined with 
vaporization of the tank contents would tend to freeze the chlorine in the vessel, greatly 
reducing the release rate. 
Toxic chemical alternate-case scenario #1: 
    The first West Plant Alternate Case Scenario (ACS) is for a release of anhydrous 
ammonia.  Ammonia is a gas under standard conditions, and is stored liquefied under 
pressure.  The ACS selected postulat 
es a catastrophic failure of an unloading hose or 
pipe resulting in an opening 2" in diameter, with immediate release of 40,000 pounds of 
ammonia in 4.14 minutes.   
"RMP Comp" estimates a distance to Toxic Endpoint of 0.6 miles. 
"RMP*Comp Ver. 1.06, Results of Consequence Analysis: 
Chemical: Ammonia (anhydrous)  CAS #: 7664-41-7 
Category: Toxic Gas; Scenario: Alternative; Liquefied under pressure; Release 
Duration: 4.14 minutes; Storage Parameters: Release from Pipe; Initial Operational 
Flow Rate: 1,333 pounds per min.; Cross-sectional area of pipe: 3.14 square inches; 
Operational pipe pressure: 150 psi; Change in pipe elevation: 0 feet; Release Rate: 
9,670 pounds per min.; Mitigation Measures: NONE; Topography: Urban surroundings 
(many obstacles in the immediate area); Toxic Endpoint: 0.14 mg/L; basis: ERPG-2. 
Estimated Distance to Toxic Endpoint: 0.6 miles (1.0 kilometers) 
Assumptions About This Scenario: Wind Speed: 3 meters/second (6.7 miles/hour); 
Stability Class: D; Air Temperatu 
re: 77 degrees F (25 degrees C)." 
    This scenario has not occurred, and practices are in place to prevent such an 
occurrence.  Some of these are: excess flow valves which shut tight if a preset flow 
occurs; check valves on the storage tank to prevent backflow in the case of a transfer 
hose failure; and remotely activated block valves. 
Toxic chemical alternate-case scenario #2: 
    The second West Plant ACS is for a release of bromine.  Bromine is a liquid at 
standard conditions.  The ACS selected is based on an actual incident which occurred 
in 1980, but did not have known offsite consequences.  The conditions presented here 
were altered from the original incident.  In this scenario, bromine from a bromine 
storage tank is transferred into a bromine tank which is already full, releasing 4,010 
pounds of bromine liquid in 15 minutes.   
    "RMP Comp" estimates a distance to Toxic Endpoint of 0.6 miles. 
"RMP*Comp Ver. 1.06, Results of Consequence Analysis: 
Chemical: Bromine   CAS #: 7 
726-95-6 
Category: Toxic Liquid; Scenario: Alternative; Quantity Released: 4,010 pounds; 
Release Duration: 15 minutes; Release Rate: 267 pounds per min.; Liquid 
Temperature: 77 F.; Mitigation Measures: NONE; Release Rate to Outside Air: 112 
pounds per minute; Evaporation Time: 35.7 min.; Topography: Urban surroundings 
(many obstacles in the immediate area); Toxic Endpoint: 0.0065 mg/L; basis: ERPG-2. 
Estimated Distance to Toxic Endpoint: 1.2 miles (1.9 kilometers) 
Assumptions About This Scenario:  Wind Speed: 3 meters/second (6.7 miles/hour); 
Stability Class: D; Air Temperature: 77 degrees F (25 degrees C)." 
    To keep this incident from happening again, we installed liquid level probes that 
alarm on detection of an overfill condition, and a weigh cell activated alarm to warn of 
impending overfill.  The vent line is connected to a scrubber. 
Toxic chemical alternate-case scenario #3: 
    The last West Plant ACS is for a release of chlorine.  Chlorine is received in rail 
cars and is c 
onnected to rigid piping by a special flexible hose.  A scenario which 
postulates a punctured rail car is not reasonable (lack of history nationwide).  The 
scenario selected postulates a liquid chlorine release from a ruptured line. (1.5" 
diameter opening) This would result in a release of 6,490 pounds per minute.  
Assuming the leak initially went undetected, it could take up to 30 minutes to stop the 
leak.  The actual incident (after which this scenario is modeled) involved a smaller 
opening in a vapor line. 
    "RMP Comp" estimates a distance to Toxic Endpoint of 0.6 miles. 
"RMP*Comp Ver. 1.06,  Results of Consequence Analysis 
Chemical: Chlorine   CAS #: 7782-50-5 
Category: Toxic Gas; Scenario: Alternative; Liquefied under pressure; Release 
Duration: 30 minutes; Storage Parameters: Release from Pipe; Initial Operational Flow 
Rate: 297 pounds per min.; Cross-sectional area of pipe: 1.77 square inches; 
Operational pipe pressure: 100 psi; Change in pipe elevation: 0 feet; Release Rate: 
 
6,490 pounds per min.; Mitigation Measures: NONE; Topography: Urban surroundings 
(many obstacles in the immediate area); Toxic Endpoint: 0.0087 mg/L; basis: ERPG-2. 
Estimated Distance to Toxic Endpoint: 1.2 miles (1.9 kilometers) 
Assumptions About This Scenario:  Wind Speed: 3 meters/second (6.7 miles/hour); 
Stability Class: D; Air Temperature: 77 degrees F (25 degrees C)." 
    To prevent this scenario from happening again, we installed chlorine sensors in 
the chlorine use area to give us early warning and remotely operated block valves at 
the unloading station and storage tank. 
Flammable chemicals: 
    There are no regulated flammables at the West Plant Facility.
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