Amerchol Corporation - Executive Summary |
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1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES. Amerchol Corporation, as a wholly owned subsidiary of Union Carbide Corporation, is committed to operating and maintaining all of our processes in a safe and responsible manner. We have implemented 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 to protect the environment. These programs include both Amerchol's Responsible Care requirements and governmental rerquirements, such as the Environmental Protection Agency's [EPA] Risk Management Program [RMP] rule, the Occupational Safety and Health Administration's [OSHA] Process Safety Management [PSM] standard, and the New Jersey Toxic Catastrophe Prevention Act [TCPA] regulations. 2. DESCRIPTION OF THE FACILITY AND REGULATED SUBSTANCES. The Amerchol Corporation plant is a manufacturing facility that annually produces approximately ten millon pounds of speciality chemical products for use primarily in the personal care industry. The RMP rule requires that if a facility, such as the Amerchol plant, has a specific amount [threshold] or more of any one of 140 toxic and flammable chemicals, the facility must follow the RMP rule requirements for that chemical. The Amerchol plant has two RMP regulated toxic substances; ethylene oxide and propylene oxide. The Amerchol plant has no RMP regulated flammable substances. 3. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS. EPA's RMP rule requires that we provide information about the worst case release scenario and the alternative release scenarios for our facility. The following are brief summaries of these hypothetical scenarios. Unless otherwise specified, no credit was taken for administrative controls or mitigation measures in evaluating the off-site impact of the scenarios. Chemical specific steps to prevent these scenarios from occurring, and to mitigate their effects should they occ ur, are shown immediately after the scenario description. The plant's general accident prevention program is described in section 4. A- Regulated Toxic Chemicals Worst Case Scenario-- This scenario assumes a rupture of the ethylene oxide storage tank, releasing 93,700 pounds of ethylene oxide as a gas to the atmosphere. Written operating procedures and a high level alarm system limit the maximum filling capacity of the storage tank to 86 percent. According to EPA's Offsite Consequence Analysis [OCA] Guidance Table, this release could impact off-site public receptors. The following administrative control is used in this analysis: Inventory Restriction: Written operating procedures and a high level alarm system limits the maximum filling capacity of the storage tank to 86 percent [93,700 pounds] In addition, specific steps to prevent this scenario from occurring, and to mitigate its effects should it occur, include: Combustible Gas Detectors Interlocked to an Emergency Shutdow n System: This system is designed to detect flammable vapors, like ethylene oxide, and to automatically shutdown transfer pumps and activate storage tank and pump isolation valves. Deluge System: A water spray system is designed to help suppress ethylene oxide vapors and to direct liquid ethylene oxide to the spill containment, treatment, and disposal system. Spill Containment, Treatment, and Disposal System: A system of dikes, spill pan, liquid containment, and vapor suppression treatment pit, which provides for the containment, treatment, and disposal of an ethylene oxide release. Surveillance: Certified operators routinely monitor the process. Alternative Release Scenarios- Ethylene Oxide and Propylene Oxide: These scenarios assumes an overpressurization of a process reactor through a relief device resulting in a release of 161 pounds of ethylene or propylene oxide as a gas to the atmosphere. According to the Phast 5.22 Model, these releases could impact off-site publ ic receptors. The following active mitigation measures are used in this analysis. Emergency Shutdown System: An emergency shutdown system designed to stop the transfer of ethylene and propylene oxide to the process reactor, shutdown all transfer pumps and isolate the reactor and the storage tank. Operator Surveillance: A certified operator must be present while processing ethylene or propylene oxide. Operating Procedures: Operating procedures detail how to safely react ethylene and propylene oxide. 4. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM. Our general accident prevention program consists of compliance with the EPA RMP rule, NJ TCPA regulations and OSHA's PSM standard and implementation of Union Carbide's Operational Safety Program and Episodic Risk Management System. Key elements include: Equipment Design: Vessels [including shipping containers] and other process equipment are designed according to recognizes industry standards and/or governmental requirement s. Process Safety Information: Chemical hazard, process technology, and equipment information is documented, maintained up to date, and available to operating personnel. Process Hazard Analysis: Process hazard analyses are conducted every five years to identify major process hazard scenarios and to recommend corrective action(s) needed to prevent their occurrence. Episodic Risk Management: Periodic reviews are conducted to identify hazards which could have significant community impact and to recommend corrective action(s) needed to prevent their occurrence. These reviews utilize advanced quantitative risk assessment techniques. Operational Safety Standards: Design requirements for active and passive mitigation controls used to prevent major process hazards area documented in operational safety standards. Operating Procedures: Operating procedures provide detail on how to safely operate a process and are maintained up to date. Operator Training/Certification Program: The plant has a training and testing program which provides operators with the proper skills and knowledge prior to allowing them to independently operate a process. Technical Staff Training and Support: Trained technical staff employees are available 24-hours a day to support operations. Maintenance Procedures: The plant has specific procedures for maintaining process equipment so that it operates safely. Maintenance Training: The plant trains persons who perform routine or complex maintenance tasks on process equipment. Mechanical Integrity Program: Vessels (including shipping containers) and other process equipment are periodically tested and/or inspected to ensure safe operation of process equipment, following recognized industry standards and/or governmental requirements. Management of Change: The plant has a management system to ensure that modified facilities and processes will be safe to operate. Prestartup Safety Reviews: Reviews are conducted just prior to startup to ensure that modified facilities and processes are safe for operation. Incident Investigation: The plant has a program to ensure that accidents and incidents are properly investigated to determine the cause(s) and to implement corrective acctions(s) that are needed to prevent the event from reoccurring. Employee Participation: The plant has a program to involve employees in prevention program elements. Hot Work Permit: The plant has a procedure to ensure that welding, cutting, and brazing are safely performed in all areas of the plant. Contractor Safety Program: The plant has a program to ensure that contractors are properly trained and perform their work in compliance with safety requirements. Compliance Audits: Periodic corporate and plant-led audits are conducted to ensure that process operations comply with governmental and Union Carbide requirements. Operational Safety Program: Union Carbide has a comprehensive program to ensure that all the elements li sted above are implemented at every Union Carbide location. This Program includes accountabilities for timely and proper implementation of the program elements. These general prevention elements and the chemical-specific steps discussed in the previous section are parts of an overall management system to prevent accidental chemical releases. Our company and our employees are committed to the standards that these management systems set. We have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5. FIVE-YEAR ACCIDENT HISTORY. In the last five years there has not been an accident or incident involving an EPA RMP chemcial at the Amerchol Edison Plant that resulted in an on-site death, injury, or property damage; or a known off-site death, injury, evacuation, shelter-in-place, propery damage or environmental damage. 6. EMERGENCY RESPONSE PROGRAM. The Amerchol Plant maintains a written emergency response program to p rotect worker and public safety, as well as the environment. The program consists of procedures for responding to releases of hazardous substances, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including: -- Proper first-aid and medical treatment for exposures; -- Evacuation plans and accounting for personnel after an evacuation; -- Notification of local emergency response agencies and the public if a release occurs; -- Post-incident cleanup and decontamination requirements, and; -- Inspecting, testing, maintaining, and using emergency response equipment. The emergency response program is updated when necessary based on modifications made to facility processes. The emergency response program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Amerchol's emergency response plans ar e coordinated with the Edison Township Fire Department and the Office of Emergency Management and includes annual drills. 7. ON-GOING PROGRAMS TO IMPROVE SAFETY. Amerchol's on-going programs, such as process hazad analysis reevaluations that uses semi-quantitative techniques to insure that controls used for prevention or mittigation of hazards provide adequate protection, continually aim to improve process safety and to help prevent and/or better respond to accidental chemical releases. A corporate program designed to ensure that process safety information is kept up to date. As a result of recent internal reviews and recently developed internal standards, the Amerchol Edison facility has identified opportunities to increase the level of protection provided for the hazards associated with the unloading, storage, distribution, and consumption of ethylene oxide and propylene oxide. These include upgrading the emergency shutdown systems and alarms. Adding new administrative requirement s to improve the mechanical integrity and the test & inspection of existing equipment and piping. Union Carbide continues to implement a corporate-wide strategy to avoid computer hardware and software systems operating disruptions due to the year 2000 changeover. The latest information on the company's Y2K efforts can be found on our Internet site -- www.unioncarbide.com. This information will be periodically updated through the first quarter 2000. |