Transcript ChemAlliance
P2 and Plant Security: Two Sides of the Same Coin?
Clean Texas Partnership Conference Austin, Texas May 3, 2004 RS Butner Director, ChemAlliance Pacific NW National Laboratory [email protected]
Overview 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?
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…
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 Security The 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 Represent 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 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 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 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 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 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” 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 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 Process Intensification Technology
Microchannel combustor image courtesy PNNL Higee Separator image courtesy UCSD
Examples of Process Intensification (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 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!”
Summary
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
References
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. Kimmerle
Chemical Plant Safety - Applying the Tools of the Trade to New Risk
Chemical 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 Links
Responsible Care Toolkit: Security Assessment
http://www.responsiblecaretoolkit.com/security_guidance_siteSec.asp
Site Security Guidelines for the US Chemical Industry
http://www.socma.com/PDFfiles/securityworkshop/SecurityGuideFinal10-22.pdf
US EPA Strategic Plan for Homeland Security
http://www.epa.gov/epahome/downloads/epa_homeland_security_strategic_plan.pdf
A Checklist for Inherently Safer Chemical Reaction Process Design and Operation
http://home.att.net/~d.c.hendershot/papers/ccps10-02.htm
Environmental Media Services – Fast Facts on Plant Security
http://www.ems.org/chemical_plants/facts.html
Environmental Media Services – Inherently Safer Processes
http://www.ems.org/chemical_plants/inherent_safety.html