Witco Fort Worth Plant - Executive Summary |
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i Offsite Consequence Modeling Date: 3/25/99 Risk Management Program Witco Corporation INDUSTRIAL SPECIALTIES GROUP 611 East Northside Drive, Fort Worth, Texas 76106 RISK MANAGEMENT PLAN August 1999 Prepared by: Robert Durden Witco Fort Worth Plant (817)-625-1500 TABLE OF CONTENTS RISK MANAGEMENT PLAN: EXECUTIVE SUMMARY 1 1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 1 1.2 DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES 1 1.3 OFF-SITE CONSEQUENCE ANALYSIS RESULTS - TOXIC SUBSTANCES 3 1.3.1 WORST-CASE RELEASES 3 1.3.2 ALTERNATIVE CASE RELEASES 3 1.4 OFF-SITE CONSEQUENCE ANALYSIS RESULTS - FLAMMABLE SUBSTANCES 4 1.4.1 WORST-CASE RELEASE 4 1.4.2 ALTERNATIVE CASE RELEASES 5 1.5 ADDITIONAL PREVENTIVE AND MITIGATING MEASURES 5 1.6 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 6 1.6.1 D-425 CONDENSATION PROCESS SAFEGUARDS 6 1.6.2 DI-ISOPROPYL NAPHTHALENE PROCESS SAFEGU ARDS 6 1.6.3 EMPLOYEE PARTICIPATION 7 1.6.4 PROCESS SAFETY INFORMATION 7 1.6.5 PROCESS HAZARD ANALYSIS (PHA) 7 1.6.6 OPERATING PROCEDURES 8 1.6.7 TRAINING 8 1.6.8 CONTRACTOR SAFETY PROGRAM 9 1.6.9 PRE-STARTUP SAFETY REVIEWS 9 1.6.10 MECHANICAL INTEGRITY 9 1.6.11 SAFE WORK PRACTICES 10 1.6.12 MANAGEMENT OF CHANGE 10 1.6.13 INCIDENT INVESTIGATION 10 1.6.14 COMPLIANCE AUDITS 11 1.7 CHEMICAL-SPECIFIC PREVENTION STEPS 11 1.7.1 SPECIALIZED SAFETY FEATURES 11 1.8 FIVE-YEAR ACCIDENT HISTORY 12 1.9 EMERGENCY RESPONSE PROGRAM INFORMATION 12 1.10 P LANNED CHANGES TO IMPROVE SAFETY 12 LIST OF TABLES TABLE Page 1 Table 1 Largest Quantity of Regulated 2 Substances 2 Table 2 Parameters for Calculating Worst- 3 Case Release Toxic Endpoint. 3 Table 3 Parameters for Calculating 4 Alternative Release Case Toxic Endpoint. 4 Table 4 Parameters for Calculating Flammable 5 Substances Worst-Case Release Endpoint (Vapor Cloud Explosion to 1 psi overpressure). 5 Table 5 Parameters for Calculating 5 Alternative Release Case for Flammable Substances Endpoint. Risk Management Plan: Executive Summary 1.1 Accidental Rele ase Prevention and Emergency Response Policies Witco Corporation is committed to worker and public safety as our first priority. It is our belief that those things which contribute to safe operations also improve quality and reduce costs. This commitment to safety can be seen in the investment of resources made for accident prevention. These efforts include extensive employee training, and a systematic approach to safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement effective controls to prevent foreseeable releases of dangerous substances. To supplement these controls, additional safeguards are provided to reduce the impact of a release should one occur in spite of all precautions. Plant employees and managers are trained to take appropriate action in an emergency to protect the welfare of the public, our employees and surrounding environment. 1.2 Description of the Stationary Source and Regulated Substances Witco's Fort Worth Plant is a specialty surfactant manufacturing facility located at 611 East Northside Drive in Fort Worth, Texas. The plant is situated on approximately 5 acres in north Fort Worth. The immediate area surrounding this plant is open undeveloped land to the north, industrial development including Ferro Corporation and residential zoned areas lie to the west, commercial/residential zoned areas to the south, and the Trinity River to the east. Specialty surfactant manufacturing has been conducted at this location since 1974. This facility makes a variety of specialty surfactants that are used in industrial and agricultural applications throughout the world. The plant is operated 24 hours per day, seven days per week. Plant manufacturing activity can be categorized into 4 major product lines employing a total of 44 people. During normal operations, the plant is staffed by 5 hourly plant operators and 1 quality control technician. Four m aintenance personnel and nine managers are present during normal office hours. Maintenance and management personnel are on call after normal office hours. Operators are organized as teams with extensive cross training enabling personnel to function in multiple roles. One of the four major product lines produced at this facility is the Morwet D-425 Dispersant. This product was first produced in 1978. 35% formaldehyde solution is reacted with a sodium naphthalene process intermediate in two batch reaction vessels. The final product of this process is a water based surfactant with highly efficient dispersant properties. This product is used in agricultural product formulations to retard sedimentation of water dispersible granules such as herbicides, insecticides, and fungicides.. The formaldehyde solution is supplied from a 10,400 gallon storage tank. The maximum intended inventory is limited to 9824 gallons due to the presence of high level warning s ystems and procedures which prevent material additions beyond this level. A minor product line involves the manufacture of naphthalene based products. One of those products, scheduled for initial production in August 1999, is Di-Isopropyl Naphthalene. This product is a process intermediate which is further processed at another Witco facility before being sold as an oil field drilling aid. This initial manufacturing phase involves the reaction of propylene gas with naphthalene in the presence of a catalyst. These two processes were identified during an evaluation of this facility's inventory of raw materials, finished products, and process intermediates to determine if any regulated flammable or toxic substances used or stored on site exceeded the threshold quantity. The facility uses two regulated substances in two processes equal to or greater than the listed threshold quantities. This chemicals, process units, largest quantity on site, and listed thresho ld quantities are presented in Table 1. Table 1 Largest Quantity of Regulated Substances Regulated Substance Largest Thresho or Mixtures Quantity On ld Containing Process Unit Site Quantit Regulated (lbs.) 1 y Substances (lbs) Formaldehyde 35% R331 & R332 32,000 15,000 Solution Propylene R332 40,000 10,000 Based on worst-case analyses, the distances to endpoints [i.e., Emergency Response Planning Guideline level 2 (ERPG- 2)] for formaldehyde exceed the distances to public receptors (i.e., off-site residences, institutions, industrial and commercial office buildings, parks, or recreational areas inha bited or occupied by the public). Worst-case analysis for a propylene vapor cloud explosion also indicate distances to endpoints [i.e., distance to 1psi overpressure], which exceed the distance to public receptors. The process using formaldehyde is exempt from coverage under the Occupational Safety & Health Administration (OSHA) Process Safety Management rule based on the concentration of the formaldehyde solution being less than 37%. 2 This facility's SIC code is 2841 (NAICS code 325611) which is not among those listed in 68.10 (d) (1). The process using propylene is covered by the PSM rule and therefore requires level 3 prevention programs. Although the first process may be classified as a program level 2, both are addressed with existing level 3 prevention programs already in place for PSM covered processes to maintain consistency. 1.3 Off-Site Consequence Analysis Results - Toxic Substances 1.3.1 Worst-Case Releases The worst-case release scenario of formaldehyde assumes a catastrophic failure which spills the entire contents of the storage tank. Endpoints for toxic substances are based on the ERPG-2. These values are listed in Appendix A to 40CFR Part 68 (Table of Toxic Endpoints). The conditions at the Fort Worth Witco Plant were reviewed to develop a model of the air dispersion pattern of toxic concentrations in the worst-case release. Table 2 shows the calculation parameters and distance to the toxic endpoint of 0.43 miles using the EPA Offsite Consequence Analysis Guidance and lookup tables. The 35% formaldehyde solution is contained in an atmospheric storage tank. Under the ARP Program [68.25(d)(3)], a regulated toxic substance that is normally liquid at ambient temperature is spilled instantaneously to form a liquid pool. The surface area of the spilled liquid is used to calculate the volatilization rate. This rate accounts for the highest daily maximum temperature occurring within the past thre e years, the material's temperature in the vessel and its concentration in solution. The rate of release to air is determined from the volatilization rate of the liquid pool. The duration studied is 10 minutes for worst-case purposes. Passive mitigation for the worst-case release include administrative limitations on the inventory of formaldehyde. The quantity of formaldehyde involved in the worst-case release is less than the capacity of the storage tank. This is due to the employment of high-level warning systems and operating procedures which prohibit filling the storage tank beyond the point where the high level alarm sounds (9824 gallons). This practice ensures a minimum vapor space inside the tank with a capacity of 756 gallons. Additional passive mitigation is provided in the form of a concrete dike around the storage tank which would divert a spill to a containment pit. This confinement of spilled material limits the surface area of a pool to no more th an 4,222 square feet and thus reduces the release rate to 5.25 pounds per minute. Table 2 Parameters for Calculating Worst-Case Release Toxic Endpoint. Regulated Vapor Spill Releas Wind Distance Substances or Pressu Surfac e Rate Speed to Toxic Mixtures re (mm e Area (lbs/m (m/s) Endpoint Containing Hg) (Sq in) s Regulated ft) (miles) Substances 35% formaldehyde Solution 8.79 4221 5.25 1.5 0.43 1.3.2 Alternative Case Releases The alternative case release scenario represents a more likely event than a worst-case. In selecting this scenario, operating experience suggested a scenario involving a hose failure represented a more credible release scenario than others considered. In this scenario, a hose or hose fitting failure results in a release from a tank truck during the process of unloa ding. The release consists of a 200 gallons per minute stream which continues for a period of ten minutes. Endpoints for toxic substances remain the same as for the worst-case. Those parameters which significantly influence differences in the scenario's outcome include wind speed and ambient temperature. In the worst-case release, an ambient temperature of 112x F and windspeed of 1.5 meters per second is assumed. In the alternative release case, more typical conditions are used. This includes a temperature of 77xF and a windspeed of 3 meters per second. The expected reduction in evaporation due to lower ambient temperatures is offset by the greater windspeed. Because of this, the release rate actually increases. However, the greater wind speed also more quickly disperses the toxic concentrations and thus shortens the distance to the toxic endpoint. Table 3 shows the calculation parameters and distance to the toxic endpoint of 0.19 miles using the EPA Of fsite Consequence Analysis Guidance. Passive mitigation for the alternative release case include spill diversion and confinement in a concrete sump pit. The estimated surface area of the spill given the expected diversion path and sump area is approximately 4000 square feet. This surface area is used square feet is used to calculate the evaporation rate. Other factors which mitigate the release include requirements that the unloader be present and attend all unloading operations, the use of standard operating procedures, and hydraulic emergency shutoff valves installed on all trucks which make deliveries to this plant. Table 3 Parameters for Calculating Alternative Release Case Toxic Endpoint. Regulated Vapor Spill Releas Wind Distance Substances or Pressu Surfac e Rate Speed to Toxic Mixtures re (mm e Area (lbs/m (m/s) Endpoint Containing Hg) (Sq in) s Regulated ft) (miles) Substances 35% formaldehyde Solution 7.47 4000 7.31 3.0 0.19 1.4 Off-Site Consequence Analysis Results - Flammable Substances 1.4.1 Worst-Case Release The worst-case release scenario of propylene assumes a catastrophic failure which releases the entire contents of a tank truck container resulting in a vapor cloud explosion. The distance to endpoint is determined as the point where the overpressure drops below 1psi. Table 4 shows the calculation parameters and distance 1 psi overpressure endpoint of 0.28 miles using the EPA Offsite Consequence Analysis Guidance and lookup tables. The largest quantity present on site occurs when a shipping container arrives for offloading. This quantity accounts for the maximum capacity of the shipping container used to transport this material to the Witco Facility.. Under the ARP Program [68.25(e)], a worst-case scenario for a re gulated flammable substance assumes the instantaneous release and vaporization of that substance resulting in a vapor cloud explosion. A yield factor of 10% of the available energy released in the explosion shall be used to determine the distance to the explosion endpoint if the model used is based on the TNT-equivalent methods. Table 4 Parameters for Calculating Flammable Substances Worst-Case Release Endpoint (Vapor Cloud Explosion to 1 psi overpressure). Regulated CAS Molecula Gas LFL Distance Substances or Number r Weight Type (mg/L to 1psi Mixtures ) Overpressu Containing re (miles) Regulated Substances Propylene 115-07- 42.08 Dense 34 0.28 1 1.4.2 Alternative Case Releases The alternative case release scenario represents a more likely event than a worst-case. In selecting this scenario, engineering personnel agreed that a likely release via the shipping container's pressure relief system would represent a more likely event. Although this scenario would not involve significant quantities, the alternative release scenario was calculated using a 5000 pound quantity. The release results in a vapor cloud fire where the offsite impacts were evaluated in terms of the distance to this material's lower flammability limit (LFL). The distance to the LFL represents the maximum distance at which the radiant heat effects of a vapor cloud fire might have serious consequences. Table 5 shows the calculation parameters and distance to the radiant heat exposure endpoint of 0.06 miles using the EPA Offsite Consequence Analysis Guidance reference table 21 assuming a wind speed of 3.0 meters per second. Table 5 Parameters for Calculating Alternative Release Case for Flammable Substances Endpoint. Regulated CAS Molecul Qty LFL Distance Substances or Number ar Releas (mg/L) to Lower Mixtures Weight ed Flammabili Containing (lbs) ty Limit Regulated (miles) Substances Propylene 115-07- 42.08 5000 34 0.06 1 1.5 Additional Preventive and Mitigating Measures A combination of engineering and administrative controls make the occurrence of a worst-case release highly unlikely. They also significantly reduce the possibility of other less serious releases. Process equipment design considers the consequences of a variety of atypical process scenarios and incorporates safeguards to prevent or minimize the effect of deviations in normal operating conditions. Process equipment including vessels, piping, pumps, control systems and safety systems are in spected and maintained in accordance with a mechanical integrity program. Critical operations are performed by trained personnel in accordance with standard operating procedures. 1.6 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The following is a summary of the accident prevention programs in place at Witco's Fort Worth Plant. The first section lists and explains engineering safeguards installed on the D-425 and the DIN processes. The second section describes management systems intended to address process hazards from initial design and construction through on- going operation and maintenance. 1.6.1 D-425 Condensation Process Safeguards Both reaction vessels and storage tank are protected from overpressure conditions with pressure relief devices or conservation vents. During transfers from shipping container to storage tank, releases are prevented by a combination of level indicators and high level alarms which a pprise personnel of the status of the transfer. Process temperature is monitored from a control room where flow rates may be adjusted as needed. Should a release occur in spite of these controls, secondary containment systems are designed to limit the movement and surface area. All process activities are attended by operating personnel who are knowledgeable of process hazards and procedures for conducting emergency shutdowns. 1.6.2 Di-Isopropyl Naphthalene Process Safeguards The shipping container meets strict DOT requirements for containers shipping liquefied petroleum gases. All transfers are carried out in well ventilated areas which limit potential accumulations of flammable gas. Transfers are attended by two operations personnel to ensure proper monitoring of all facets of the operation. Emergency shutoff valves are located away from the unloading connections to facilitate their quick employment if needed. Pressure relief systems prevent overpress ure conditions for both the shipping container and the process reactor. The process reactor is protected from process deviations of pressure or temperatures through a system of interlocks which automatically stop the transfer of propylene under upset conditions. The pressure relief system for the reactor is piped to a safe location away from other processes. The process reactor relief system is connected to an alarm to signal operations personnel if a relief event occurs. The unloading pipeline system is equipped with an emergency shutdown system that may be employed from a safe distance in the event of a hose failure during material transfer. It is also equipped with a fusible link shutoff valve which is designed to automatically close if exposed to the heat of a fire.. Equipment ground systems are installed to prevent static electricity buildup during material transfers. 1.6.3 Employee Participation Witco employees and management work together to manage process safety and accident prevention efforts. Employees participate in safety action committee meetings and the decision making dialog in those meetings. Employees also hold and participate in their own subcommittee meetings and make recommendations to this steering group. Employees participate in process hazard reviews and in the development of operating procedures. They assist in updating and verifying technical documents and chemical information. Employees have access to all information created as part of this facility's accident prevention program. Employees are involved in developing and carrying out training, incident investigations, managements of change, and pre-startup safety reviews. 1.6.4 Process Safety Information Technical information on process equipment, technology, and chemicals is maintained and used to ensure safe operation of the covered processes. These documents address chemical properties and their associated hazards, limits for cr itical process parameters and specific chemical inventories, and equipment design and configuration details. Specific departments are assigned responsibility for maintaining up- to-date process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with inadvertently mixing of chemicals. For specific covered process areas, Witco Fort Worth has documented safety-related limits for specific process parameters (e.g., temperatures, pressures). The plant ensures that the process is maintained within these limits using reliable process controls and monitoring instruments, emergency relief systems and two stage scrubber system, highly trained personnel, and protective instrument systems (e.g., emergency shutdo wn systems). The plant also maintains technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. 1.6.5 Process Hazard Analysis (PHA) The Fort Worth Witco plant has a comprehensive program to help ensure that hazards associated with the various process are identified and controlled. Within this program, each new and altered process is systematically examined to identify hazards and ensure the adequate controls are in place to manage these hazards. Methodologies used to perform these evaluations include the haza rd and operability study (HAZOP) and the What- If/Checklist technique. These analyses are conducted using cross-functional teams having operations and engineering expertise. These teams identify and evaluate hazard scenarios , ranking each scenario's risk level with respect to event likelihood and severity. The team then evaluates prevention and mitigation measures and makes recommendations for additional prevention and/or mitigation measures if they are judged necessary. The findings and recommendations of the team are reviewed by local managers for resolution. Implementation of recommendations in response to PHA findings is based on a relative risk ranking assigned by the team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from those originally planned for in design safety features, Witco's Fort Worth Plant periodically updates and revalidates the hazard analysis studies. These periodic reviews are conducted at least every 5 years for covered processes and will be conducted at this frequency until the process is no longer operating. Findings and recommendations from these updates are documented and retained. Recommendations made by the team updating or revalidating the PHA are again reviewed and resolved by management review with final resolution being documented and retained. 1.6.6 Operating Procedures Witco's Fort Worth plant maintains written procedures that address various modes of process operations, such as (1) initial startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) startup following maintenance activitie s or following an emergency shutdown. Operating procedures are used as a reference by experienced operators and a training resource in training new operators. These procedures are periodically reviewed and certified as current and accurate annually. Operating procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. When creating or reviewing operating procedures, a team of personnel review and comment on the draft's accuracy and completeness. Procedures are available to operators and other personnel in work areas where process operations are carried out. 1.6.7 Training Training is an essential part of the skills development program used for qualifying employees involved in operating a process. New employees receive initial training in plant rules and safety policies, process overviews, chemical and process hazards present at this location, safe work practices, and basic emer gency response procedures. Following classroom orientation, the new employee begins co- worker training with an experienced operator and a review of operating procedures applicable to his job. At the conclusion of this co-worker training period, the new employee is evaluated to ensure he has acquired the skills and knowledge necessary to safely and successfully do his job. To supplement and reinforce job knowledge and skills, all employees undergo refresher training at regular intervals. Refresher training frequency ranges from each year to once every three years. Training is documented and understanding is verified using oral and written tests, performance observation and other means which objectively demonstrate understanding. 1.6.8 Contractor Safety Program Witco employees contractors to perform special construction projects or supplement the maintenance workforce when needed. All contractors receive some level of orientation training depending on the proximity of their work to other process activities or hazards. Contractors are selected in consideration of their safety programs and performance. They are made aware of basic plant rules and safety policies, workplace hazards in the area where they will work, safe work practices applicable to the work they will perform, and basic emergency response procedures. During the initial orientation, contract employees are instructed to report any hazards their work will create or that they discover during the course of their work. Contractors are periodically evaluated to ensure they are fulfilling their safety obligations. 1.6.9 Pre-startup Safety Reviews Witco personnel perform PSSRs for any facility modification that requires a change in process safety information. This generally means following a change in a process or following the construction of a new process. The purpose of the PSSR is to ensure that safety features, procedures, personnel and equip ment are appropriately prepared for startup prior to place the equipment into service. This review provides one additional check to verify that construction is in accordance with design specification and that all supporting systems are operationally ready. Applicable checklists are used to verify all aspects of readiness. A PSSR involves field verification of equipment fabrication and installation, and serves to assure that other accident prevention program requirements are properly implemented. 1.6.10 Mechanical Integrity Witco's Fort Worth Plant assures the mechanical integrity of critical operations equipment such as pressure vessels, storage tanks, piping systems, relief and vent systems, controls, pumps and safety systems through its mechanical integrity program. The basic aspects of the program include: (1) training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying qualit y assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training in (1) overviews of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and 5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Equipment deficiencies, once identified, are corrected prior to further operation of the equipment, or a management team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. As part of the mechanical integrity program, quality assurance measures are incorporated into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. 1.6.11 Safe Work Practices Witco's Fort Worth Plant employs widely accepted safety work practices as a matter of daily routine. Those safe work practices used include (1) lockout procedures for control of hazardous energy, (2) entry/exit control procedures for maintenance, laboratory, contractor, and support personnel, (3) linebreaking/opening process equipment procedures, (4) a hotworks permit program to control possible ignition sources, and (5) a permit-required confined space entry procedure. These procedures are used by all personnel involved in both user and non-user maintenance activities. 1.6.12 Management of Change The Witco management of change program is a system to review and evaluate changes to process chemistry, operating conditions or limits, equipment, and procedures to prevent unexpected adverse impacts. The management of change program uses a quantitative risk assessment to determine the significance of the change. This risk level assessment determines the levels of authorization required to approve the action. Design review checklists are used to evaluate different types of changes to prevent new hazards being created or equipment changes which are not suited to the service as it exists in the process. Another important feature of the management of change program is that is verifies and documents that procedures, records and equipment information are updated and that personnel affected by the change are notified and trained in the change. 1.6.13 Incident Investigation Witco requires that all incidents which result in, or could reasonably have resulted in, the release of a hazardous material, a fire or explosion in a covered process area, major property damage, adverse environmental impact, or serious personal injury be reported and promptly investigated. By investigating accidents and near-misses, important lessons are learned and corrective actions can be used to prevent future similar events. Incident investigations are documented and recommendations tracked to their completion. Incident investigation reports are retained for at least 5 years to facilitate their use during PHA updates and revalidation. 1.6.14 Compliance Audits To assure that the goals of the accident prevention programs are met, program performance is periodically evaluated in the form of compliance audits. An audit team reviews records and documents to determine the degree of program compliance. Compliance audits are conducted at least every 3 years. Audit team findings are documented and presented to plant management for resolution. Corrective actions taken in response to audit findings are tracked until they are complete. The two most recent audit reports are retained. 1.7 Chemical-Specific Prevention Steps The risks associated with the processes described earlier in this executive summary require proper management to prevent accidental releases of regulated substances in this facility. 1.7.1 Specialize d Safety Features Witco's Fort Worth plant has engineered safety features on those units which process highly hazardous chemicals to (1) Prevent a release through early warning of impending upsets, and/or (2) reduce the consequences of (mitigate) a release. The following types of safety features are used in these processes: 1.7.1.1 Release Prevention Systems 1. High level probes with alarms 2. Flow controllers with automatic shutoffs 3. Pressure relief devices on piping, tanks, and reactor vessels 4. Check valves to prevent reverse flow through piping 5. High temperature and pressure warning systems on the reactor vessels 1.7.1.2 Release Containment/Control 1. Dikes and diversion containment which contain spills and limit the surface area of the spill. 2. Manual valves to permit isolation of the process if necessary. 1.7.1.3 Release Mitigation 1. Employees trained to respond as hazardous materials technicians 2. Contracted off-sit e emergency responders available to support employee teams if needed 3. Specialized personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus) 1.8 Five-Year Accident History Witco's Fort Worth Plant has not had any accidental releases during the past five years which meet the criteria for an accidental release per 40CFR68.42. 1.9 Emergency Response Program Information Witco's Fort Worth plant maintains a written emergency response plan designed to protect worker and public safety as well as the environment during an emergency. The plan consists of procedures for responding to a release of formaldehyde, including the possibility of a fire or explosion. These procedures address notification and emergency signals, specific containment actions, and proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agen cies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment. All personnel entering the Witco Fort Worth Plant receive some level of orientation which contains instruction in emergency signals and actions to be taken during an emergency. Specific employees are trained to Hazardous Materials Technician level for actively responding to hazardous materials emergencies. These personnel are sufficiently trained to deal with most hazardous materials emergencies which might occur in this facility. In the event of more serious emergencies, the same personnel are trained and prepared to assist the efforts of other emergency response personnel in a variety of support roles. All employees are trained as first responders at the awareness level and in procedures for cleaning up small spills based on their work assign ments. Overall emergency response programs are coordinated with the Fort Worth Fire Department. This coordination includes briefings and information sharing to address specific concerns in the event of an incident at the plant. The Witco Fort Worth Plant has around-the-clock communications capability with the Fort Worth Fire Department. This department has the capability to communicate to all state, federal and county agencies and may draw on whatever resources or equipment are needed to effectively manage emergency operations (i.e., firefighting equipment, manpower, ambulances, hospitals, law enforcement, and HAZMAT operations). This provides a means of notifying the public of an incident, if necessary, as well as facilitating a quick response to an incident. Witco's Fort Worth Plant conducts drills annually to assess personnel readiness, proficiency and the effectiveness of emergency response plans. 1.10 Planned Changes to Improve Safety Witco's Fort Worth Plant is constantly striving to improve process safety, quality, and efficiency. Several noteworthy improvements scheduled for the future include z Improvements to the tank truck unloading station which involve installation of dedicated pump and hose systems which significantly reduce the risk of an off-loading mishap z Spill containment area reductions which reduces the surface area size of a spill in off-loading areas. Reduced surface area significantly reduces any resulting vapor emissions in the event of an emergency. _______________________________ 1 Quantity represents formaldehyde minus water solution with 1% methanol. 2 OSHA Interpretation, Patricia K. Clark, OSHA Directorate of Compliance Programs, July 28, 1992 and CPL 2-2.45A CH-1 (Dec 13, 1994) |