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P2 and Plant Security:P2 and Plant Security:Two Sides of the Same Coin? Two Sides of the Same Coin?
Clean Texas Partnership ConferenceAustin, TexasMay 3, 2004
RS ButnerDirector, ChemAlliancePacific NW National [email protected]
Overview of PresentationOverview of Presentation
Chemical Plant Security – why it’s an issue
Policy & Industry responses to the issue Reducing the risks
inherently safer chemical manufacturing “green” chemistry process intensification
Where do we go from here?
What is ChemAlliance?What is ChemAlliance?
ChemAlliance (www.chemalliance.org) is an EPA-OECA supported Compliance Assistance Center.
Our mission is to help small chemical manufacturers improve their environmental performance
We serve as a clearinghouse for compliance and P2 information access to tools and training emphasis on cost-effective
compliance strategies technical assistance programs trade & professional associations peer-to-peer mentoring
The Threat is Real…The Threat is Real…
FBI warns petrochemical plants on Gulf of Mexico
TEXAS CITY, Texas (AP) — Security was tight early Thursday at petrochemical plants along the Gulf of Mexico following a caution issued by the FBI.
An agency official said that the Texas Coastal Regional Advisory
Chemical Plant SecurityChemical Plant SecurityThe Perspective after 09/11/01The Perspective after 09/11/01
“…according to EPA, 123 chemical facilities located throughout the nation have accidental toxic release ‘worst-case’ scenarios where more than one million people…could be at risk of exposure”
Source: US EPA
Chemical Manufacturing Facilities Chemical Manufacturing Facilities Represent Real Threats for Terror AttacksRepresent Real Threats for Terror Attacks
Routinely process large quantities of materials that are: toxic volatile flammable stored under extremes of pressure, temperature
Often close to population centers Vulnerable to attack
relatively low security numerous critical to the economy
Policy Responses to the ThreatPolicy Responses to the Threat GAO recommends a comprehensive chemical
security strategy identify high risk facilities clarify roles of industry, government pursue legislation to require industry to assess
vulnerability and take corrective action EPA has specifically addressed chemical and
petroleum sectors in its Homeland Security strategic plan working with industry on voluntary initiatives working with SBA, others to develop outreach Including security issues during onsite visits to
manufacturing facilities, including targeted visits to high-risk facilities
Policy Responses to the ThreatPolicy Responses to the Threat
Department of Homeland Security December 17, 2003 Homeland Security Presidential
Directive/Hspd-7 assigns infrastructure protection (including chemical sector) to DHS
balance between DHS and EPA still in question Legislative efforts
Corzine (D – NJ) Bill (S. 157) requires firms to implement “inherently safer technology…to
the extent practicable” for highly vulnerable sites favored by many environmental groups
Inhofe Bill (R – OK) (S. 994) assessment required which “…shall include consideration and,
where practicable in the judgment of the owner or operator…” favored by administration, industry
Industry Responses to Terror ThreatsIndustry Responses to Terror Threats
Industry response stresses site security, “voluntary” action
“Site Security Guidelines for U.S. Chemical Industry” issued October 2001 Joint effort by ACC, SOCMA, and the Chlorine Institute emphasis on site and operational security via
“rings of protection” Security Vulnerability Assessment (SVA)
and related Prioritization Methodologies AIChE/CCPS Sandia National Lab SOCMA ACC Many private companies
(BASF, Air Products, G-P)
Different Threats, Common ThreadsDifferent Threats, Common Threads
Protecting the public from deliberate attacks on chemical plants shares many characteristics with pollution prevention: need to balance short-term and long-term responses non-obvious and often intangible benefits to industry likely to be an evolutionary, rather than revolutionary
response Short-term responses focus on plant security
“Guns, Gates and Guards” Long-term responses are likely to have much
in common with P2 strategies inherently safe chemical processing “green” chemistry process intensification
Inherently Safer Chemical ProcessingInherently Safer Chemical Processing
Has it’s roots in process safety discipline, dating back many decades
Strong emphasis on operational procedures, process control, and root cause analysis
Underlying principles are common to P2 use less hazardous materials when possible reduce inventories of hazardous materials
generate “just in time” reduce inherent risks of reactions
reactor designs, operating schemes to reduce possibility of “runaway” reactions
reduce severity of processing/storage (lower pressure, lower temperature)
““Green” ChemistryGreen” Chemistry
Emphasis of green chemistry tends to be on synthesis routes and solvent selection, rather than equipment engineering biologically-catalyzed reactions low-toxicity reactants and solvents aqueous and solvent-less reaction processes
EPA’s approach to green chemistry stresses early assessment and reduction of chemical risks
Process IntensificationProcess Intensification
Process intensification = “…strateg[ies] for achieving dramatic reductions in the size of the [manufacturing] plant at a given production volume”
specific strategies may include unit integration (combining functions) field enhancement (using light, sound,
electrical fields, or centrifugal force to alter process physics)
micro-scale technology
Some Examples of Some Examples of Process Intensification TechnologyProcess Intensification Technology
Microchannel combustorimage courtesy PNNL
Higee Separatorimage courtesy UCSD
Examples of Process Intensification Examples of Process Intensification (PI) in Industry(PI) in Industry
GlaxoSmithKline has demonstrated 99% reduction in inventory and 93% reduction in impurities by using spinning disk reactors
Studies show that process integration on the Bhopal facility could have reduced MIC inventories from 41 tons to < 10 kg.
ICI has demonstrated byproduct reductions of 75% by using integral heat exchange (HEX) reactors
Use of HEX reactors can result in ~100-fold reductions in chemical inventory!
Some CaveatsSome Caveats Process modification is non-trivial for the
chemical industry Some strategies tend to shift risks, rather than
reduce them e.g., reducing inventories may increase transportation
Even if all risk could be eliminated from chemical manufacturing facilities, other targets exist only 18% of facilities required to report under RMP were
chemical manufacturing facilities! underscores importance of moving towards safer
products, not just safer processes The “risk vs. efficiency” equation has
implications for sustainability. beware of “easy answers!”
SummarySummary
Chemical manufacturing facilities have a heightened awareness of process risks since 9/11
Increasing visibility of the threat is likely to lead to regulatory action and/or increased public pressure
Many of the strategies for reducing risk are also effective sustainable process strategies inherently safer design process intensification “green” chemistry and engineering
ReferencesReferences US EPA, Chemical Accident Risks in US Industry, September 2000 US General Accounting Office (GAO), Voluntary Initiatives are
Under Way at Chemical Facilities, but the Extent of Security Preparedness is Unknown. US GAO Report GAO-03-439, March, 2003.
Ragan, P.T., Kilburn, M.E., Roberts, S.H. and N.A. KimmerleChemical Plant Safety - Applying the Tools of the Trade to New RiskChemical Engineering Progress, February 2002, Pg. 62
Royal Society of Chemistry, Note on Inherently Safer Chemical Processes, 03/16/2000
Bendixen, Lisa, Integrate EHS for Better Process Design Chemical Engineering Progress, February 2002, Pg. 26
Stankiewicz, A and J.A. Moulijn, Process Intensification, Ind. Eng. Chem. Res. 2002, vol. 41 pp 1920-1924.
Note: Chemical Engineering Progress articles are available online to registered users, via http://www.cepmagazine.org/
Web LinksWeb Links
Responsible Care Toolkit: Security Assessmenthttp://www.responsiblecaretoolkit.com/security_guidance_siteSec.asp
Site Security Guidelines for the US Chemical Industryhttp://www.socma.com/PDFfiles/securityworkshop/SecurityGuideFinal10-22.pdf
US EPA Strategic Plan for Homeland Securityhttp://www.epa.gov/epahome/downloads/epa_homeland_security_strategic_plan.pdf
A Checklist for Inherently Safer Chemical Reaction Process Design and Operationhttp://home.att.net/~d.c.hendershot/papers/ccps10-02.htm
Environmental Media Services – Fast Facts on Plant Securityhttp://www.ems.org/chemical_plants/facts.html
Environmental Media Services – Inherently Safer Processes http://www.ems.org/chemical_plants/inherent_safety.html