Corning Incorporated, Wilmington Facility - Executive Summary
EXECUTIVE SUMMARY||EXECUTIVE SUMMARY||1. EXECUTIVE SUMMARY 68.155 |
1.1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICES (a)
Corning Incorporated, Wilmington, North Carolina Plant accidental release prevention policy involves a unified approach that integrates technology, procedures and management practices. The prevention program complies with all applicable procedures of the U.S. Environmental Protection Agency (EPA) Risk Management Program (RMP) 40 CFR-68, Prevention Program.
1.1.1. MANAGEMENT SYSTEM (a)(1)
Corning has a management system in place that oversees the implementation and on-going use of the RMP elements. This program, along with other Corning policies, eliminates and /or reduces the likelihood of a hazardous chemical release at the plant.
1.1.2. PREVENTION PROGRAM, LEVEL 3 (a)(2)
Corning maintains policies, procedures and systems as part of their prevention program. The program addresses each of the EPA Program Level 3-listed 12 elements, plus
RMP elements needed to implement the program, and the like elements in place for the OSHA Process Safety Management (PSM) program. These are maintained in Corning's Process Information Management System (PIMS) document control system.
1.2. CORNING STATIONARY SOURCE AND REGULATED SUBSTANCE HANDLED AT THE WILMINGTON, NC SITE (b)
The Corning Plant employs 1,200 full-time employees engaged in the manufacture of glass fiber optics. Chlorine is used as part of the manufacturing process.
1.2.1. SITE DESCRIPTION (b)(1)
The site is owned and operated by Corning Incorporated, Telecommunications Products Division. The site is located at 310 North College Road, Wilmington, New Hanover County, North Carolina. The 60-acre site is bordered by North College Road on the west, and Smith Creek Parkway on the east and north.
The Plant has a chlorine storage and distribution system contained in a specially designed process building. The boundaries of the chlorine system subject to the RMP regulati
on include the Bulk Chlorine Storage and Control Building and the associated vent make up and exhaust scrubber systems.
1.2.2. REGULATED SUBSTANCE (b)(2)
Chlorine is the only regulated substance on site that exceeds the EPA 40 CFR-68 rule threshold quantity. The chlorine process was installed as part of the process of manufacturing glass fiber optics. The chlorine is received, stored and used in two processes that distribute it to six control panels.
Chlorine is an EPA-and OSHA-listed toxic chemical. It is an irritant and it is corrosive. Chlorine is a halogen with the formula Cl2. It is a chlorinating or oxidizing agent that is not flammable. It has a 1 ppm OSHA ceiling Permissible Exposure Limit (PEL) and a NFPA health rating of 4, severe; with immediate and delayed health hazards. Chlorine is not a carcinogen.
1.3. WORST AND ALTERNATIVE CASE RELEASE SCENARIOS (c)
Two offsite consequence analyses were conducted which include two chlorine release scenarios. The first is a
"worst case release". The second is a more probable "alternative release scenario". The first scenario is defined by EPA, which states that "the facility shall assume that the maximum quantity in the largest vessel is released as a gas over 10 minutes" due to an unspecified failure. The alternative scenario is defined as "more likely to occur than the worst-case scenario".
Atmospheric dispersion modeling guidance developed by the EPA for waste water treatment plants was used to determine the distance traveled by the chlorine released before its concentration decreases to the "toxic endpoint." The EPA selected endpoint for chlorine is 0.0087 mg/l equals 3 ppm. The 3 ppm endpoint is the Emergency Response Planning Guideline Level 2 (ERPG-2). This is defined by the American Industrial Hygiene Association (AIHA) as the "maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreve
rsible or other serious health effects or symptoms which could impair an individual's ability to take protective action." The residential population within a circle with a radius corresponding to the toxic endpoint distance was defined, "to estimate the population potentially affected."
1.3.1. WORST CASE (c)(1)
The EPA waste water guidance chlorine toxic end point table for the worst case scenario was used. It includes all EPA Assumptions. Results demonstrate a distance of 1.30 miles to the toxic endpoint. The residential population that could potentially be affected by the release is estimated at 7,024 people.
1.3.2. ALTERNATIVE CASE (c)(2)
The alternative release scenario involves the rupture of the <-inch high pressure tubing connected to one of the one ton-containers. Modeling demonstrated the rate of chlorine release is 3.968 lb./min. The toxic endpoint distances determined is zero (0) miles, or stated another way, no off-site impacts. No public receptor would be impac
ted by this release.
1.4. ACCIDENTAL RELEASE PREVENTION PROGRAM (d)
The Corning accidental release prevention program is based on the OSHA PSM program and EPA RMP Level 3 prevention program. The PSM program has been in place and effectively used for several years. It is part of the plant's operating culture. There are two parts to the program. The first is the general overall site program. The second is the chlorine-specific actions within the site program. This is coordinated with the Hanover County Local Emergency Planning Committee (LEPC) through the City of Wilmington North Carolina fire department.
1.4.1. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM (d)(1)
Facility-wide, many elements of the prevention program are used for all operations. The overviews of these programs are listed below:
7 Corning has detailed process safety information on each of its operations.
7 The PIMS document control system is an integral part of the management of change for all operations on si
7 Training is the backbone of employee knowledge, job operations and is ongoing in each area. Employee training in operations and maintenance emphasizes awareness of the hazardous and toxic properties of all chemicals used.
7 Maintenance and preventive maintenance are used for all operations making mechanical integrity a part of each piece of equipment.
7 Incident investigations of accidents and near-miss incidents ensure learning from each event as well as correcting the causes of the incident.
7 Employees participate in all aspects of the plant as listed below under emergency response.
7 Safe work practices used throughout the facility include: 1) Hot Work Permits, 2) Lock Out Tag Out Permits, 3) Vessel Entry Permits, 4) Site Security, and 5) Breaking Into Chemical lines.
7 Contractors must meet Corning's high safety and technical standards as part of selection and ongoing evaluations. Also, Corning demands training of contractors specific to areas to be worked in.
1.4.2. CHLORINE-SPECIFIC RESPONSE PROGRAM (d)(2)
184.108.40.206. Chlorine-Specific Policies and Procedures
Chemical-specific prevention features of the facility include: the policies and procedures listed above and those of the chlorine specific program. These include:
7 Specific procedures for the operation of the chlorine building.
7 Completion of a Pre-startup Safety Review prior to start up of the modified chlorine system.
7 Specific emergency response procedures for chlorine releases as outlined below under emergency response.
7 Specific training in the properties, hazards, handling requirements, and leak repair for chlorine.
7 Finally, the details of both facility and equipment design are key to the safe operations of the chlorine system.
220.127.116.11. Facility Design
The facility and support equipment of the chlorine storage and control building meet and exceed design codes standards and good engineering practices. The building is equipped with temperature control and vent make-up.
The building is under negative pressure created by the vent scrubber. There are two modes of vent operations, normal and emergency. In the event of a chlorine leak the vent system doubles the air turnover through the building.
18.104.22.168. Equipment Design
The chlorine piping system is made of Hastelloy metal tube. This tube is both chlorine compatible (not corroded by chlorine) and rated to 1,500 psig. The maximum pressure of the chlorine is only 150 psig giving a 10 to 1 safety factor. There is a chlorine monitor that detects the presence of chlorine in the storage building. The monitor along with other detectors in the plant will alarm to alert employees of a potential chlorine leak.
1.5. FIVE-YEAR ACCIDENT HISTORY (e)
Corning has had no accidental releases of chlorine in the past five years per EPA 40 CFR 67.42 (a).
1.6. EMERGENCY RESPONSE PROGRAM (f)
Emergency response procedures are contained in the Corning Contingency Plan (Emergency Response Plan). The plan includes an
emergency response "decision tree" and a notification plan. Emergency response drills and drill evaluations are conducted every month by the operating department and once per quarter by the safety department. Emergency operation and response procedures are also reviewed at that time.
The emergency response program (contingency plan) is coordinated (reviewed by) with the City of Wilmington Fire Department, which is a member of Local Emergency Response Planning Committee (LEPC). Copies of the program are given to ten key local agencies including: fire, medical, rescue, waste management, and police departments in New Hanover County. Besides the specific emergency response program, key elements of the prevention programs are incorporated in the operating culture of the Corning plant.
The Contingency Plan procedures detail the actions and responses to chlorine spills (releases). The plan includes training of all chlorine-area operators, a primary response team, and a backup team. Acti
ons include catastrophic, severe, and moderate leaks. A Chlorine "B" Kit is maintained on site to stop leaks.
1.6.1. PERSONNEL (f)(1)
Personnel are the key resource of Corning's prevention program. Employees make up the operators and emergency response teams. Corning fosters a high level of involvement in every aspect of the chlorine system operations including participation in:
7 Chlorine safety teams,
7 Development of the operation procedures,
7 Hazard evaluations, and
7 On-going training of the operators and other involved staff.
1.7. CHANGES TO IMPROVE SAFETY (g)
Changes to improve safety (recommended actions) were identified in the September, 1996 and June, 1997 internal audit of the PSM program to meet requirements of the Risk Management Prevention Program. These recommended actions have now been evaluated and implemented as required.
Corning continually reviews implemented and potential safety improvements for all of its operations.