1. 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 scott.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 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

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 combustor image courtesy PNNL Higee Separator image 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. 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/http://www.cepmagazine.org/

19. Web Links  Responsible Care Toolkit: Security Assessment http://www.responsiblecaretoolkit.com/security_guidance_siteSec.asp 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 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 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 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 http://www.ems.org/chemical_plants/facts.html  Environmental Media Services – Inherently Safer Processes http://www.ems.org/chemical_plants/inherent_safety.html http://www.ems.org/chemical_plants/inherent_safety.html