Olin Corporation Niagara Falls, New York Plant - Executive Summary |
|
OLIN NIAGARA FALLS PLANT EXECUTIVE SUMMARY The Olin facility, located on Buffalo Avenue in Niagara Falls, NY is part of Olin Corporation, headquartered in Norwalk, CT. The plant is situated on 42 acres of land between Buffalo Avenue and the Niagara River. The Niagara Falls Plant has over 100 years of operations, starting up on Thanksgiving Day, in 1897. 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 near neighbors, business, and education. Quarterly, members gather with plant management to share information on topics of mutual interests. Annually, representatives of the Niagara 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 Niagara Falls Plant. Our primary products, chlorine and caustic soda, are used to make everything from paper products, textiles, water treatment, household bleach, pharmaceuticals, vinyl products and household goods. Olin has 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 off-site implications is unlikely to occur, Olin has put six layers of safety and environmental protection in place: Employees, Mechanical Integrity, Process Hazard Reviews, Process Controls, Safety Systems, and Emergency Preparedness. ACCIDENT AL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Olin Niagara, we are committed to operating and maintaining our Chlor/Alkali process 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 off site 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 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 Our facility produces chlorine, caustic, hydrogen, 32% HCl and bleach as a Chlor/Alkali manufacturing facility. Chlorine is produced using twelve membrane electrolyzers. Caustic is produced at 33% strength and is evaporated to 50%. The chlorine produced is loaded directly into 90 Ton rail cars, with minimum on site storage. We do consume chlorine on site in the manufacture of bleach and HCl. In our process, we use the following chemical that EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release: Toxics Chlorine: Chlorine is shipped via 90 Ton rail cars to customers. Chlorine is used on site in the production of 32% HCl (~60 Tons/day) and Bleach (~18 Tons/day). Also included in the RMP list of Regulated Substances and handled at the Niagar a Falls facility, but exempt from the regulation are Hydrogen, and Hydrochloric Acid solutions. In the case of Hydrogen, the volume on site is slightly less than 30 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 regulation in concentrations of 37% or greater. At the Niagara Falls facility, we produce for internal consumption and for sale, a maximum concentration of 32% HCl. 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 of this chemical. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS We are providing information about the worst-case release scenario and alternative release scenario 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. The impact on public and environmental receptors for the scenarios is based on the United States boundaries and does not include receptors in Canada. Although Canadian receptors were not included we did an outreach with the Ontario CAER group and the NF Ontario Regional Fire Departments. The Niagara County LEPC also has a cross border emergency response plan which would be enacted, if either senario would impact the Canadian borders. Worst-case Release Scenario, Chlor/Alkali Chlorine The worst case scenario is the failure of a 200 Ton Chlorine storage tank. The release is the entire contents, 200 tons of liquefied chlorine, 14 F at 90 psig, in 10 minutes. The scenario assumes urban conditions, F stability and a wind speed of 1.5 meters per second. The impact radius was greater than 25 miles. The 25 mile radius impacts public parks, schools, hospitals, prisions, other industrial areas and residential neighborhoods. There are three chlorine storage tanks. Under normal conditions only one tank has a minimum chlorine level. The storage tank is controlled administratively to a maximum of 100 tons, although we used 200 tons for the worst case scenario. Total nominal capacity of one storage tank is 200 tons. The other two storage tanks are empty; one for operations and the other as a backup for equipment evacuation. The storage tanks are located in a concrete dike. Relief valves are piped to secondary containment tanks. The storage tanks are constructed for chlorine service and are inspected externally every 2 years and internally every 5 years, as part of the critical service program. The dike is 80 ft. x 56 ft. with a 4" curb around the perimeter. A center section of the concrete dike is dug out to a 4 foot depth, this section is 36 ft. x 56 ft. Alternative Release Scenario, Chlor/Alkali Chlorine The alternate release scenario or more likely scenario is a gasket failure of the liquid chlorine header. The estimated amount of release is 1100 lbs. The physical properties of the chlorine are a liquid, at 14 F, at a pressure of 180 psig. The meteorological data for the alternate case scenario assumes urban conditions, D stability and a wind speed of 3.0 meters per second. The RMP Comp model indicates an impact radius for this release of 0.3 miles. The impacted receptor is an industrial manufacturing neighbor. The liquid chlorine header has isolation valves that close on loss of pressure in the header if the pressure falls below 50 psi. The gaskets used are spiral wound, to minimize the potential of the gasket blowing out or failing. The line is 3" schedule 80, welded, with 300 lb. flanges. There are isolation block valves at each end and an automatic valve at the mid point. There are two sets of expansion tanks located between the block valves and the mid point automatic v alve on the two sections of the line. 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 each 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 As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Employees: Well trained experienced employees are our most important resource in operating our plant and in protecting the community. Mechanical Integrity: The comprehensive inspection and testing program greatly reduces the probability of equipment failures. We employ a full time, certified and acc redited inspector for inspection and testing. We also have input from our Area Equipment Integrity Team (AEIT) which meet to discuss equipment issues. Hazard Reviews/PHA's: Hazard Reviews/PHA's have been conducted on all systems handling hazardous materials, as well as on all new designs prior to operation. Hazard Reviews identify things that could possibly go wrong so that these situations can be addressed before an incident occurs. Process Controls: The plant operations are computer controlled, which provides precise control of processes, maintains tight operating parameters, automates shutdowns, and includes redundant operating stations. Monitoring Systems: Chlorine detectors are installed in process areas, at the plant fence line and also in the community which can identify impending problems, giving operators early warning and enabling them to provide a quick and more effective response. Emergency Response: The key to minimizing the effect of an accidental release is to get t he right people and equipment to the scene quickly, including both on-site and off-site emergency responders. Olin Niagara maintains our own response team (OCEAN) and equipment to minimize response time. We also work in conjunction with the Niagara Falls Fire Department and the Niagara County L.E.P.C. to respond to any off site releases. 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. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. During the past five years, we have had no off-site accidental chemical releases involving materials covered under EPA's RMP rule. If such an incident should occur, we do c onduct formal incident investigations to identify and correct the root causes of the events. 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 Niagara Falls Fire Department and the Niagara County Local Emergency Planning Commission. PLANNED CHANGES TO IMPROVE SAFETY Below is an example of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases. Typically we conduct PHA's and implement suggested changes or improvements that are identified in those reviews. Therefore we don't keep a long list of future changes. We like to take action so that we minimize the potential of releases. A recent PHA in our chlorine loading and storage identified these two recommendations. 1) Keep water from accumulat ing in the dike below the chlorine storage bullets. 2) Reroute the discharge from the safety relief valve located on the reservoir of the sniff compressor to secondary containment. |