Olin Corporation Niagara Falls, NY - Foote Yard - Executive Summary |
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OLIN NIAGARA FALLS FOOTE YARD EXECUTIVE SUMMARY The Foote Yard Rail storage area is located 2.7 miles from the Olin Niagara Falls facility. This rail storage yard is enclosed with perimeter fencing and is inspected once every eight hour shift by plant security. This rail yard is used to hold railcars for shipment and is contolled by the Olin Niagara Plant. Maintaining open, positive relationships with the communities is a priority at Olin. 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 en hance 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. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Olin Niagara, we are committed to maintaining our railroad storage yard 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 STATIONARY SOURCE AND REGULATED SUBSTANCES The Foote Yard facility is leased from CSX railroad and is used for storage of 90 ton Chlorine railcars. At Foote Yard, we store 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; stored in 90 Ton rail cars awaiting assignment to customers. Caustic, a non RMP chemical is also stored in Foote Yard awaiting shipping orders. On occasion we will also store empty Chlorine and Caustic cars. 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 storage of this chemical. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide 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 rail yard is fenced and secured. Worst-case Release Scenario, Foote Yard Chlorine The worst case scenario is a rupture of a 90 Ton Chlorine Rail car. The release is the entire contents, 90 tons of chlorine 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 and residential neighborhoods. The rail cars are loaded on scales, which automatically shut off when they reach 180,000 lbs. The loading scales are certified. The rail cars are equipped with safety relief valves which are replaced every two years. The rail cars are built to U.S. Department of Transportation and Chlorine Institute standards for transporting chlorine. Alternative Release Scenario, Foote Yard Chlorine The alternate release scenario or more likely scenario at Foote Yard is a gasket leak on a gas angle valve. The estimated amount of release is 180 lbs. The physical properties of the chlorine are a gas, at 70 F, at a pressure of 85 psig. The meteorological data for the alternate case scenario assumes urban conditions, D stability and a wind speed of 3.0 meters per second. This model indicates an impact radius for this release of 0.1 miles. Depending on wind direction the impacted receptors include public golf course and a residential neighborhoods. The railcars are equipped with safety relief valves which are repalced every two years. The cars are built to U.S. Department of Transportation and Chlorine Institute standards for transporting chlorine. Chlorine angle valves are replaced periodically as required by Olin standards. The angle valves are also changed before loading if there are any signs of leakage or possible failure. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Prevent ing accidental releases of hazardous chemicals is our culture. Foote Yard is a storage yard only with no operations. Our management systems address successful prevention programs including: Process hazard analysis Training Management of change Compliance audits Incident investigation Hot work permit Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Hazard Reviews: Conducted 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. Emergency Response: The key to minimizing the effect of an accidental release is to get the 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 con junction with the Niagara Falls Fire Department and the Niagara County L.E.P.C. to respond to any off site releases. Security: The Foote Yard is patrolled once each eight hour shift by Olin's contract security. 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 Foote Yard. 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 conduct formal incident investigations to identify and correct the root causes of the events. EMERGENCY RESPONSE PROGRAM We maintain an emergency response plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program 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. |