Ansell Healthcare Products, Inc. - Dothan Plant - Executive Summary |
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The Ansell-Dothan, Alabama plant accidental release prevention and emergency response policy integrates technologies, procedures and good management practices. All applicable procedures of the U.S. Environmental Protection Agency (EPA) prevention program are followed. The Ansell-Dothan emergency response policy involves the preparation of response plans which are tailored to meet the response capability available in the Dothan community, and is in compliance with the EPA requirements. Chlorine is used at the Dothan plant in the manufacture of Nitrile products. The chlorine installation includes a chlorine storage and use shed that contains five (5) ton containers of chlorine. Three (3) containers are in use, and two (2) are in storage. Scales are used to weigh the chlorine. A lifting bar and hoist are used to move the containers from storage to use sites. Trunnions are used to hold the containers not in use, and gas detectors are used to monitor the area for chlorine leaks. In the event of a chlorine leak, gas detectors will activate an alarm in the chlorine shed. A wind sock is prominently displayed on the top of the plant for first responders to identify wind direction. The facility is manned 24 hours/day, 7 days/week. A security guard is located on site at all times, including during plant shut downs. The off-site consequences analysis (OCA) was performed for two chlorine release scenarios - one identified as "worst case" and the other identified as "alternative scenario". The worst case release scenario describes complete (100%) release from the largest container (1-ton) in which 2,000 pounds of chlorine is released over 10 minutes. The alternative release scenario describes partial release of chlorine from a leaking valve. The alternative release predicts a loss of 15 pounds of chlorine over 10 minutes. Atmospheric dispersion modeling for the release scenarios incorporated data contained in the Risk Management Program Guidance for Wastewater Tr eatment Plants (EPA 550-B-98-010, October 1998). The analysis was performed to determine the distance traveled by the chlorine before its concentration decreases to the toxic endpoint of 3 ppm (0.0087 g/cu.m) based on the ERP Guideline 2 (ERPG-2) developed by the American Industrial Hygiene Association (AIHA). The distance for the worst case scenario is 1.3 miles. The distance for the alternative scenario is 0.1 miles. Active mitigation is achieved via three (3) chlorine gas detectors. All chlorinators are vacuum operated so that chlorine is under vacuum on removal from the ton containers as it is fed to the process. A loss of vacuum signal, such as a vacuum line break, would shut the system down at the ton container valve. The general accidental release prevention program at Dothan is accomplished via the following steps: 1. A high level of operator training; 2. A preventative maintenance program; 3. Use of state of the art process and safety equipment; 4. A hazard review with a process safety analysis using a Process Safety Management (PSM) practice in accordance with OSHA 29CFR1910 recommendations; 5. An annual auditing and inspection program; 6. Use of accurate and effective written operating procedures prepared with participation from operators. The Ansell-Dothan plant has used chlorine for seven (7) years. No chlorine-related incidents / accidents associated with leaking chlorine, equipment damage, environmental damage, injury or death have ocurred during the past 5 years. The Ansell-Dothan plant has an Emergency Response Program (ERP) that has been reviewed by the Assistant Marshall of the Dothan Fire Department, who has the responsibility under current Alabama regulations and is a member of the Local Emergency Planning Committee (LEPC). The program includes an emergency response decision tree and notification plan. Emergency response drills will be conducted annually. Emergency response procedures will also be reviewed / evaluated at that time. No changes are currently planned for improving the chlorine storage and handling facilities and procedures. The most recent change was accomplished in January of 1999, when the entire system was upgraded. Future revisions to the system will involve notifications / involvement of the appropriate parties. |