Clariant Corporation - Martin Plant - Executive Summary |
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1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Clariant Martin Plant, we value the wellness of our employees, their families, and our community neighbors. This plant is committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: o A description of our facility and use of substances regulated by EPA's RMP regulation o A summary of results from our assessment of the potential offsite consequences from accidental chemical releases o An overview of our accidental release prevention programs o A five-year accident history for accidental releases of chemicals regulated by EPA' s RMP rule o An overview of our emergency response program o An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment o The certifications that EPA's RMP rule requires us to provide o The detailed information (called data elements) about our risk management program 2 STATIONARY SOURCE AND REGULATED SUBSTANCES Clariant is a Swiss based specialty chemical company with 130 manufacturing plants worldwide. We are established as one of the world's leading producers of dyes, dye intermediates, pigments and specialty chemicals. The Martin Works is one of Clariant's primary manufacturing plants. The Martin plant is an integrated system of facilities that was constructed between 1976 and 1978 on 4,600 acres in Allendale County. The operational portions of the plant currently occupy approximately 130 acres. We employ approximately 220 Clarian t employees and Fluor Daniel contract personnel. Martin manufactures a broad line of dyes, surfactants, optical brighteners, and specialty chemicals used in the textile, paper, leather, automotive, and electronic industries. Our products go into computers, clothing, carpeting, high quality paper, and cosmetics, as well as other products that enhance our daily lives. In our processes, we use the following chemicals that the Environmental Protection Agency has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxic Chemical Maximum Inventory Use Ammonia 7664-41-7 9,800 lbs. refrigeration unit for cooling Epichlorohydrin 106-89-8 140,000 lbs. manufacture of specialty chemicals Oleum 8014-95-7 440,000 lbs. manufacture of dyestuff intermediates Phosgene 75-44-5 30,000 lbs.* manufacture of paper dye intermediates * in containers of 2,000 lbs. each Flammable Chemical Maximum Inventory Use Propane 74-98-6 110,000 lbs. fuel Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed by use of these chemicals to our employees, the public, and the environment. 3 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's Risk Management rule requires that companies provide information about the worst-case and alternative release scenarios for their facilities. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distance s for each scenario. Worst-case Release Scenarios - Regulated Toxic Chemicals o Anhydrous Ammonia - Written operating procedures and high-level alarms prevent more than 9800 lbs. of ammonia to be present in the refrigeration system. In addition, the largest unit is enclosed in a building. Release of the entire amount of ammonia on plant site, which represents the worst-case scenario, would leave our plant site; however, no public or environmental receptors are within the exposure distance. Model used: EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations. o Epichlorohydrin - Failure of the storage tank filled with the largest amount possible would release 140,000 lbs into a concrete dike that limits the exposed surface area of the liquid pool and thus reduces the release rate. No public or environmental receptors are within the exposure distance resulting from the worst case release. Model used: Areal Locations of Hazardous Atmospheres (ALOHA). o Oleum - Failure of the storage tank filled with the largest amount possible would release 440,000 lbs into a concrete dike that limits the exposed surface area of the liquid pool and thus reduces the release rate. Since no vapors would leave the plant site, no public or environmental receptors are within the exposure distance. Model used: EPA's OCA Guidance Reference Tables or Equations. o Phosgene - This material is used in a one-ton cylinder enclosed in a special room. Failure of the cylinder would release 2000 lbs into the room. A population of 1089 would be affected by this release which consists only of residences with no schools, hospitals, prisons, recreation areas, office areas, or industrial areas in the impacted zone. This cylinder could not catastrophically fail since it can withstand impact of a locomotive. No environmental receptors are within the distance to the endpoint. Model used: Areal Locations of Hazardous Atmospheres (ALOHA). Worst-case Release Sce nario - Regulated Flammable Chemical o Propane - Failure of the storage tank filled with the largest amount possible would release 110,000 lbs. with ensuing vapor cloud explosion. The overpressure of 1psi would fail to leave the plant site. No public or environmental receptors are within this overpressure distance. We are using the Predictive Filing option to indicate that, in the near future, additional propane will be stored at Martin. Two additional tanks, each containing 110,000 lbs. of propane will be installed during 1999. The new overpressure of 1psi would leave the plant site but does not reach any public nor environmental receptors. Model used: EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations. Alternate-case Release Scenario - Regulated Toxic Chemical o Phosgene - A cylinder leak of 50 lbs. would leave the plant site; however, no public receptors would be impacted. It would take a leak of 100 lbs. to impact any public receptors. VanDeMark Chemical Company Inc controls cylinder leaks through detailed mechanical integrity of these vessels. A leak repair kit is maintained on the Martin plant site. The plant's Fire and Emergency Brigade is trained in the use of this leak repair kit. No releases of this chemical have ever been experienced outside the manufacturing area. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The Martin plant complies with all EPA Regulations at 40 CFR Part 68; OSHA Regulations at 29 CFR 1910; Clean Water Act Regulations at 40 CFR 112; RCRA Regulations at 40 CFR 264, 265, & 279.52; and EPCRA Rules and Laws. We maintain a number of programs to help prevent accidental releases and ensure safe operation. Leadership by senior management through policy, participation, communications, a nd resource commitments provide results in achieving continuous improvement of performance. Accident prevention programs are maintained through the Works Management Safety Committee, Works Employee Safety Committee, Works Management Inspection Committee, Process Safety Management Task Force, and the Executive Safety Review Committee. Safety objectives are an annual part of the Martin Results Sharing Success. Clear accountability for safety performance is part of each employee's annual review. Use of the Community Awareness and Emergency Response (CAER) process assures public comments and concerns are considered in both design and operation of the plant's process safety systems. All elements of the RMP and PSM programs are used to ensure that sufficient layers of protection exist through technology, facilities and personnel to prevent escalation from a single failure to a catastrophic event. All plant operators are trained and certified in the jobs that they do. Every employee ha s the authority to shutdown any process or to stop any job, in order to maintain a safe operation. Training programs cover job specific tasks, principles of chemical processing, safety, and regulatory issues. All plant process equipment is subjected to EPA and OSHA mechanical integrity inspections to look for corrosion or wear. All storage and process vessels are protected against over-pressure by safety relief valves. Process shutdown systems are built-in to our process control computers. These safety devices and shutdown systems are periodically inspected and tested. Predictive Maintenance techniques are utilized to address problems before they happen. All plant modifications and procedure changes undergo a management of change process that involves operator, maintenance, engineering, technical and management review. In the unlikely event of a release, we feel the best method of protection for our community is to shelter in place away from the hazard. We have prepared our c ommunity by publishing the steps they should take during a chemical release from our plant boundaries. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems dictate the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5 FIVE-YEAR ACCIDENT HISTORY There has never been a worst-case scenario type event in our history at Martin. No offsite incidents have ever occurred. The Martin plant is approaching five years without a lost time accident. No serious incidents have taken place within the manufacturing unit; however, OSHA recordable accidents have occurred. We keep records for all accidental chemical releases that occur at Martin. The following is a brief summary of accidental chemical releases involving materials covered under EPA's Risk Management Program rule during the past five years. A Phosgene release of 1ppm was detected during January, 1996. For each of these incidents, we have conducted formal incident investigations to identify and correct the root causes of the events. 6 EMERGENCY RESPONSE PROGRAM The Martin plant maintains an integrated emergency response plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting employees, the public, and the environment during emergency situations. In addition, we coordinate our plan with community emergency response plans and local responders. We maintain a mutual aid agreement with the three surrounding fire departments. All Martin plant emergency brigade members are trained in emergency response, fire fighting, hazmat requirements, and must pass a physical exam. The plant has an extensive fire fighting s ystem with monitor nozzles, hoses, foam generating capability, and sprinkler systems. We maintain an E-1, 1,500-gallon pumper, 110-ft. ladder truck equipped with radio and cellular phone systems, emergency response, and decontamination materials. Emergency response personnel are trained in first aid and CPR. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of key improvements that the Martin plant is committed to implementing to help prevent and better respond to accidental chemical releases: o First Step - A video presentation designed to enhance and improve supervision's role in safety. It will teach front line supervisors that they are directly accountable for safety in their areas. This program is expected to minimize the amount of unsafe acts that occur in the plant. o Gas Masks - The type of gas masks worn at Martin will be changed. This change is prompted by our desire to obtain units that have NIOSH approval. The new masks will allow our operators to s witch from negative pressure (air purifying) applications to positive pressure (airline & SCBA) applications without changing units. Additionally, these masks will reduce the volume of part's storage, and the canisters used are for all air purifying applications encountered at Martin. o Air Monitoring Program - The Martin plant's IH will initiate a program to monitor surrounding environments in manufacturing during processes that use highly hazardous materials. All production procedures have been reviewed to identify potential employee exposures. Low hazardous materials and previously monitored materials will be reviewed during subsequent years. It is anticipated that within a five year span, all materials at Martin will have been monitored. o CWTP Monitoring System - Operator exposure risk associated with the CWTP headworks pit was discovered by safety personnel. Vendors have been requested to specify monitoring systems for installation in this area. An on-line system wi ll provide an assessment of the headworks' air quality before entering this area. o ESH Compliance Audit - In August, 1999, a plant wide ESH compliance audit will be conducted at Martin to determine if any deficiencies exist. An audit document will be provided, whereupon, corrective actions will be assigned and completed. This audit team will consist of safety, health and environmental professionals from within the corporation. o High Production Volume Chemicals Testing - Clariant has committed to cooperate in testing four of the High Production Volume Chemicals. Additional testing will be performed as needs arise. |