P2 and Plant Security: Two Sides of the Same Coin?

1. P2 and Plant Security:Two Sides of the Same Coin? Clean Texas Partnership ConferenceAustin, Texas May 3, 2004 RS ButnerDirector, ChemAlliancePacific NW National Laboratoryscott.butner@pnl.gov

2. 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?

3. 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

4. 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

5. Chemical Plant SecurityThe 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

6. 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

7. 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

8. 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

9. 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)

10. 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

11. 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)

12. “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

13. 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

14. Some Examples of Process Intensification Technology Microchannel combustorimage courtesy PNNL Higee Separatorimage courtesy UCSD

15. 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!

16. 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!”

17. 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

18. 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. 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 DesignChemical 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/

19. Web 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 Processeshttp://www.ems.org/chemical_plants/inherent_safety.html