Olin Corporation, Charleston Tn Plant - Executive Summary |
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The Olin facility in Charleston Tn. is part of Olin corporation; headquartered in Norwalk CT. The 371 employees at the Charleston facility live in Bradley, Meigs, McMinn, and Polk counties. Olin employees are involved in the communities and care about the environment which all of us in southeastern Tennesssee share and enjoy. Maintaining open, positive relationships with the surrounding communities is a priority at our plant. We understand that we are an intergal part of the community. We support the Olin Community Adivisory Panel which was formed in the early 1990's and is comprised of community members who represent business, education, religion, and youth interests. Bi-monthly, members gather with plant management to share information on topics of mutual interests. Annually, represenatives of the Charleston 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. In addition to community out reach, Olin's safety and environmental program is rooted in the fundemental belief that all incidents are preventable. Our Goal is "Zero" incidents. This commentment helps to insure that an emergency situation with off-site implications will never occur. Olin has put six layers of safety and environmetal protection in place: employees; mechanical intergrity; process hazard reviews; process controls; monitoring systems; and emergency response. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At the Olin Charleston plant, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) 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 offsite 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 The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility produces; chlorine, sodium hydroxide, hydrochloric acid, and sulfur dioxide, using a variety of chemicals and processing operations. The Olin Charleston facility uses mercury cell technology to produce chlorine and sodium hydroxide. We also produce sulfur dioxide through the oxidation of sulfur. We also produce hydrochloric acid by burning hydrogen and chlorine. In our processes, we use and manufacture the following chemicals that EPA has identified as having the potential to cause significant off-site consequences in the event of a substantial accidental release: Toxics Chlorine, 26,000,000 pounds are potentially stored on-site. Normal expected on-site storage of Chlorine is 6,500,000. Olin produces chlorine for sale to other business, as well as on-site manufacturing of hydrochloric acid. Sulfur Dioxide, 3,300,000 pounds are potentially stored on-site. Normal expected on-site storage is 1,200,000. Olin produces SO2 for sale to other business as well as on site manufacturing of sodium hydrosulfite. Hydrochloric acid > 37%, 1,200,000 pounds are potentially stored on-site. Normal expected on-site storage of Hydrochloric acid is 370,000 pounds. Olin produces HCl for sale to other business and on site useage. 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 manufacturing and use of these chemicals. Release Scenarios We have chosen 1 toxic worst case scenario and 3 toxic alternative release scenarios for RMP submission. We modeled a total of 12 toxic release scenarios for consideration. Incident probability, chemical toxicity, quantity stored/inventory, historical data, toxic endpoint, and mapping results were just some of the factors considered in selecting the scenarios for submission. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION 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 pr ograms 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 The 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. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: This facility has experienced 2 incidents associated with a RMP covered process, a nonloss workday chlorine inhalation injury, 10-5-94, and a fire associated with the sulfur dioxide producing reactor, 10/10/98. Neither of these incidents resulted in any off site impacts. EMERGENCY RESPONSE PROGRAM 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 community emergency response plan, and involve local community represenatives and fellow plant employees in the plan development and undates. We practice this plan on a regular scheduled basis, from a basic fire drill to a full scale multiple county CAER drill. SAFETY IMPROVEMENTS The following is a list of recent improvements that we have implemented at the facility to help prevent and/or better respond to accidental chemical releases. In addition, the Olin Charleston facility commitment to continous improvement and internal review process assures the on going generation of improvements such as these. 1. Goal is zero initiative The Charleston facility began work in the third quarter of 1998 on a far reaching initiative to achieve zero safety, environmental, distribution, and process incidents. We have involved all levels of employees in developing the vision in each strategic area and work on action plans to make this vision a reality. 2. BAPP process for continuous improvement. Our behavioral accident prevention process BAPP at Charleston is call PRIDE (people reducing injury developing excellence) and has just celebrated it's third anniversary. In the coming year we will expand the program to observe environmental issues. This process will then develop action plans for continuous Olin Responsible Care improvements. 3. ORC Improvement plans and audits The leadership team of Charleston regularly evaluates the process that will improve our safety and environmental performance and an updated strategic plan is utilized to capture action plans. Periodic internal audi ts are conducted by Olin employees from other locations and outside consultants to review our practices and make recommendations for continuous improvements. 4. ORC Point Person Network In 1997 each of the teams established at Charleston plant, assigned a member to assist the team in ORC related activities. Each of these point persons has received training on how to effectively integrate ORC activities within their team. We will continue to develop this role. As the role is rotated to others over the coming years, it will serve to improve the safety, health, and environmental culture at Charleston. 5. Sulfur dioxide plant oxygen feed system upgrades The oxygen feed system to the SO2 reactor had major instrumentation upgrades and an emergency failsafe shutoff valve installed to reduce the negative impact of an oxygen line rupture. The new instrumentation allows monitoring of the system to help prevent a feed line rupture. As an additional backup, a failsafe valve will shutoff preven ting sulfur from being pressured out. Also added was a block wall around the reactor and feed piping which will act as a personnel barrier. 6. Termal Recovery Unit installation of new filter and pumps We have installed a new(Laufer) filter and associated pumps and other equipment in the TRU facility to process mercury bearing material as a means to reduce mercury levels in this material. Previously this material was manually collected and handled by the TRU operator for processing. This will result in a significant reduction in mercury exposure to these workers. 7. Chlorine railcar automatic shutoff system Olin recently installed an emergency shutdown system for chlorine railcar loading. This system will automatically shut off the chlorine supply to the railcar angle valves. The shutoffs are activated on car movement as determined by "electric eye". This system is recommended by and complies with Chlorine Institue Pamphlet #57. 8. Chlorine remote surveillance system Olin recently installed remote surveillance at the #1 and #2 chlorine railcar reconditioning stations where chlorine transfers take place. Video monitoring and chlorine detection/monitoring equipment provides information to the chlorine operators in the chlorine control room. |