DuPont Beaumont Plant - Executive Summary
DUPONT BEAUMONT WORKS RISK MANAGEMENT PLAN |
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
At the DuPont Beaumont Plant, we are committed to operating and maintaining all our processes in a safe and responsible manner. Our plant adheres to the DuPont Corporate policies, which are summarized as follows:
> All Safety and Environmental incidents are preventable
> The Goal is Zero - Zero Incidents Period
> All employees and contractors are responsible for their safety.
The DuPont Corporate policies are embodied in numerous Safety, Health and Environmental (SHE) and Engineering Standards, which apply globally. At the Beaumont Plant, the policies are implemented through the Beaumont SHE manual called "Safety How". This manual is available to all site employees via the computer intranet system. Safety How Volume III in particular deals with Process Safety Management systems and requirements and contains the complete Emergency Response Plan for the Beaumont
Our facility is located on Highway 347 between the cities of Beaumont and Nederland, Texas. The DuPont Beaumont site consists of three manufacturing processes: An Anhydrous Ammonia plant, an Acrylonitrile Plant and an Aniline plant. The products from these plants are Anhydrous Ammonia, Carbon Dioxide, Acrylonitrile (ACRN), Hydrocyanic Acid (HCN), Acetonitrile Azeotrope and Aniline. Anhydrous ammonia, ACRN and HCN are regulated toxic substances. In the production of these products, the following additional regulated substances are used as raw materials, intermediates or additives:
Toxics - Sulfur Dioxide and Chlorine
Flammables - Propylene
KEY OFF SITE CONSEQUENCE ANALYSIS SCENARIOS
Worst Case Toxic Release Scenario
The worst case release scenario for a toxic chemical is the failure of the cold anhydrous ammonia storage tank. The maximum capacity of this tank is 34,000,000 lbs, with no mitigation assumed. This release has off site impact, as determined by the
use of the OCA Guidance. This release is highly unlikely due to the double-wall, double integrity tank construction and the high-integrity design of the tank and associated equipment.
Worst Case Flammable Release Scenario
The worst case release scenario for a flammable chemical is failure in propylene storage. releasing the contents of seven tanks, or failure of a barge used for interim storage. Amount released is 1,400,000 lbs. The entire content is released in 10 minutes and assumed to vaporize and ignite. The release has off site impact as determined using the OCA Guidance. This scenario is unlikely as it ignores the vessel cooling by evaporation and flow restriction due to two phase flow. No mitigation is assumed. There are propylene detectors and water cannons surrounding the storage area and remotely operated shut off valves.
Alternate Toxic Release Scenarios
Anhydrous Ammonia - A 1 inch hole develops in any of the piping associated with the Ammonia transer facilities. The rele
ase rate is 600 lbs./min based on the system pumping capability and typical pipeline pressures. Because the leak may be in a remote location, the release was assumed to last 60 minutes. The presence of perimeter leak detectors and emergency response was assumed. This release has off site impact as determined using the OCA Guidance Tables. However no residential populations are affected.
Hydrocyanic Acid - A 1 inch branch connection is ruptured in any of the piping associated with HCN transfer. The release rate of 125 lbs./min. is based on normal pumping rates. There are HCN sensors located throughout the HCN handling areas, so a leak will be detected and located quickly. The release duration used was 10 minutes. Emergency response drills have confirmed a leak can be detected and isolated in 10 minutes. This scenario has off site impact as determined using the OCA Guidance Tables, but has no affect on residential populations.
Acrylonitrile - A 1 inch hole develops in one of the ACRN sto
rage tanks. The release rate of 698 lbs./min was calculated based on the maximum static pressure in the tank. A release duration of 15 minutes was assumed since the storage tanks are monitored continuously. The storage tanks are diked. No other active mitigation was assumed. The vapor release rate was calculated to be 276 lbs./min based on the evaporation rate from the pool. This scenario has off site impact as determined using the OCA Guidance Tables, but does not impact any residential populations.
Sulfur Dioxide - The loading hose ruptures releasing a maximum of 700 lbs./min. of liquid SO2 for a maximum of 15 seconds. The actual flow rate will be much lower because flashing will severely choke the flow. Since the unloading operation is manned 100% of the time, the emergency valve will be shut within 15 seconds. Approximately 18 lbs./min. of SO2 vapor is generated from the spill for ten minutes. No other mitigation was assumed. The scenario will have off site impact as determined usi
ng the OCA Guidance Tables, but no residential populations are affected.
Chlorine - The connecting tubing from a one ton chlorine cylinder to the supply header is ruptured releasing 22 lbs./min. for 60 minutes. The release is detected by operator patrols, the operations area responds in full acid suits with SCBA and shuts off the cylinder. No other mitigation was assumed. This release has off site impact as determined using the OCA Tables, but no residential populations are affected.
Alternate Flammable Release Scenarios
Propylene - A propylene relief valve lifts in the storage area releasing 530 lbs./hr at ambient temperature. Propylene detectors sound an alarm and operations personnel isolate the tank using remote operated shut off valves and use available water monitors to cool down the tank and stop the release in 15 minutes. If the vapor cloud finds an ignition source, the impact area has off site impact to traffic on the Neches River immediately adjacent to the propylene storage
area, but has no effect on residential populations.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
DuPont Beaumont operations follows the requirements of DuPont Corporate SHE Standard S21A, "Process Safety Management". This standard includes and embraces the requirements of 29 CFR 1910.119 and 40 CFR Part 68. Our safety management systems address all the key features of successful prevention programs including:
Designing for Safety...
- A documented process technology system covers hazards of materials, equipment design basis and process design basis.
- Applicable codes and standards are met or exceeded
- Materials of construction are selected to provide mechanical integrity
- Process hazards reviews are conducted at several stages of the design process
- Quality assurance ensures fabrication according to design specifications and proper assembly
- Extensive accident prevention and mitigation systems are strategically located.
- Operators are trained and job qualifie
- Operators follow approved written procedures.
- Technical resources are available and utilized as required.
- The site is fenced and patroled. All visitors are logged in and out at the gate and logged in and out at the areas they visit.
Maintaining Our Plants
- Maintenance personnel are trained and qualified.
- Contractors are trained and qualified.
- A hot work permit system controls hazards.
- Safety critical equipment is set up on a periodic, appropriate inspection frequency to ensure ongoing mechanical integrity.
- Quality assurance ensures the correct replacement materials are used for maintenance and repairs.
- A management of change system is in place to review safety aspects of all changes.
Auditing Our Operations...
- Process hazards analyses are conducted periodically by experienced PHA teams.
- Pre-startup safety reviews are conducted before starting any new or modified equipment.
- Routine safety inspections are conducted.
- Corporate, independent, governmental and int
ernal audits of our systems are conducted.
- All incidents are investigated and actions are taken to prevent recurrence.
FIVE YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at our facility. We have experienced no deaths, injuries or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage or environmental damage from a release of any of the regulated chemicals in the last five years.
EMERGENCY RESPONSE PROGRAM
The Beaumont DuPont facility maintains a comprehensive, integrated Emergency Response program that includes a written plan which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. The DuPont facility is a participant in the Beaumont Industrial Park Emergency Response Team. This 70 member plus team is trained to the HAZ-MAT Technician level for chemical response and Advanced Interior and Exterior level
for fire fighting. The Emergency Response Team also has members trained and certified as EMTs and Confined Space Rescue technicians. Emergency response plans are current. The Beaumont Industrial Park has an emergency alarm system that consists of in-plant horns and bells. The community is alerted through the LEPC, which uses the Federal Emergency Alerting system. Local emergency responders are notified whenever the site Emergency Response Team is committed to perform actual emergency response operations. The Emergency Response program is coordinated with the local community response plan. Beaumont facility personnel actively participate in the Jefferson County Emergency Planning Committee (LEPC) and the Sabine Neches Chiefs Association. The Industrial Park excercises its plan annually and also participates in county wide drills staged by the LEPC and other local emergency response organizations. Critiques are held on drills and actual events and the findings are used to improve site pl
ans and procedures. The Beaumont Industrial Park program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations.
PLANNED CHANGES TO IMPROVE SAFETY
The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases:
- Continued focus on "The Goal is Zero" for injuries and incidents.
- Initiate a program to conduct one shift emergency response drill per year in the dock area in addition to the site wide emergency response drills.
- Improve the reliability of the Anhydrous Ammonia plant flare system.
For all the Beaumont DuPont covered processes the undersigned also certifies that, to the best of my knowledge, information, and belief formed after reasonable inquiry, the information submitted in this RMP plan is true, accurate and complete.
Roy E. Wells