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 Laboratoryscott.butner@pnl.gov

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