Local Public Safety
Plant personnel are trained and equipped to respond to, and correct, many of the potential releases of chemicals used on site. These trained personnel include a site Fire Brigade, Rescue Team, Medical EMT Team and Hazardous Materials Team on all shifts around the clock. In addition, a close relationship is maintained with local county fire and police units with routine training of county fire/rescue on site.
Preventing Chemical Releases
The DuPont Spruance Plant has always set a high priority on the prevention of chemical releases-especially in the prevention of releases that might have off-site community impact. One strong indication of that is our long-standing provision for "secondary" containment for chemical storage. The reinforced concrete dikes and curbs around storage tanks and process vessels exemplify this across the site.
Another is the work the plant has done to find alternate processes for toxic chemical use where possible. Within the past 4 years, routine process use of Carbon Tetrachloride and Tetrachloroethylene have been eliminated (and replaced by a process that does not use chemicals). In 1999, we eliminated the use of Chlorine (for water treatment) and substituted a less toxic chemical. In 2000, we eliminated another toxic chemical used in one of our processes. Where we have not been able to eliminate a hazardous chemical, we have established very stringent procedures for safely handling the material.
Track Record for Accidental Releases
There have been no significant releases from our site that have had off-site/community impact in the past 5 years. In fact, our "No Significant Release" record goes back much further than 5 years, but that is the time period specified in the Environmental Protection Agency's new Risk Management Program regulation. Spruance has detailed risk management programs that meet or exceed the requirements of the regulations at 40 CFR Part 68. Included in these risk management programs are prevention programs, emergency response programs and an overall Risk Management Plan (RMP) summary. The RMP summary contains information on 40 CFR Part 68 chemicals, "Worst Case" and Alternate Scenario potential releases, and condensed versions of the Prevention and Emergency Plans.
The prevention program is a formal and extremely detailed regimen with a purpose of dramatically reducing the probability or impact of a significant release. It consists of these major areas:
Process Safety Information - Including analysis of chemical hazards, technical detail on the process, materials of construction, relief systems, and safety systems.
Process Hazard Analysis - Including detailed analysis of "What If?" cases, identification of potential incidents and how to mitigate, identification of any previous incidents and necessary corrective action, physical location of the process and other detailed information.
Operating Procedures - Consisting of detailed steps for each operating phase of the process, emergency procedures, control measures if releases should occur and a continuous review of all procedures to assure they are up-to-date.
Training - Including initial training for each employee, refresher training and formal training documentation. Contractors working in or on the process also receive training before such work.
Mechanical Integrity - Consisting of written maintenance procedures, training for maintenance personnel, inspection and testing requirements, repair of deficiencies in equipment, quality assurance procedures and spare parts acceptability to the particular process.
Management of Change - A formal process that includes the discipline or examining changes to the process (chemicals used, equipment, technology, employees involved in operating the process etc.) before they are made to help assure all systems continuously operate safely.
Pre-startup Review - Including a safety review of all changes that require a change in the process safety information for the process.
Emergency Response Program
The emergency response program is a formal plan aimed at stopping any potential release as soon as possible and protecting personnel and the environment in the case of such a release. There are trained on-site emergency response teams on all shifts. In addition, all plant personnel receive emergency training. The plan includes procedures for notification of the Local Emergency Planning Council (LEPC) and local emergency fire and police units. If evacuation or "shelter in place" procedures need to be implemented, the LEPC will coordinate with the local fire and police units to communicate to the community. The plant has worked closely with the Chesterfield County LEPC and Fire/Emergency Response organizations in the development of our Emergency Plan. The County emergency response units are familiar with the site and the chemicals used, and have had numerous training exercises on the plant.