Croda Inc. - Mill Hall, PA - Executive Summary
1 EPA RMP SUBMISSION DOCUMENT EXECUTIVE SUMMARY |
Croda, Inc. (Croda) seeks to provide a safe work environment for their employees as well as ensure the safety of individuals offsite. In addition, Croda is keenly aware of the potential environmental impacts of their operations and they are committed to minimizing the negative effects of their processes on the environment.
According to EPA 40 CFR 68, part 68.155, the Executive Summary should contain the following items:
a) The accidental release prevention and emergency response policies at the stationary source.
b) The stationary source and regulated substances handled.
c) The Worst-case release scenario(s) and the alternative release scenarios(s), including administrative controls and mitigation measures to limit the distances for each reported scenario.
d) The general accident release prevention program and chemical-specific prevention steps.
e) The five-year accident history.
f) The emergency response program.
g) Planned changes to i
A. Accidental Release Prevention and Emergency Response Policies
Croda, Inc. has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our process. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release.
B. Description of Stationary Source and Regulated Substances Handled
Croda, Inc. is a worldwide supplier for the personal care, household, pharmaceutical, and manufacturing industries. There are five substances regulated by the EPA RMP Rule that is found above threshold quantities at the site, including:
Material Toxic or Flammable, per EPA Guideline Endpoint, per EPA Guideline
Ethylene Oxide Toxic gas 0.09 mg/l
Toxic liquid 0.59 mg/l
Epichlorohydrin Toxic liquid 0.076 mg/l
Methyl Chloride Toxic gas 0.82 mg/l
Trimethylamine Flammable gas 1psi overpressure
C. Offsite Consequence Analysis
The EPA RMP requires offsite consequence analysis to include the worst case flammable and toxic release scenarios as well as alternative cases for at least one flammable and all toxic substances.
Scenario Substance Description Model Used* Distance to Endpoint
Worst Case Toxic Ethylene Oxide Release of the entire 175,000lb rail car inventory within 10 minutes. EPA Guideline and Look-up Tables 9.3 miles
Worst Case Flammable Trimethylamine Release of the entire 40,000lb tank truck inventory within 10 minutes. EPA Guideline and Look-up Tables 0.26 miles
Alternate Case Toxic Ethylene Oxide Catastrophic rupture of 2" liquid unloading hose caused by movement while still connected (or other cause). Excess flow valve and/or detectors with process interlocks isolate system in approximately 2 minutes. PHAST 5.22 1.26
Alternate Case Toxic Propylene Oxide Catastrophic rupture of 2" liquid unloading hose caused by movement while still connected (or other cause). Liquid pools in sloped unloading area. PHAST 5.22 0.42 miles
Alternate Case Toxic Epichlorohydrin Catastrophic rupture of 2" liquid unloading hose caused by movement while still connected (or other cause). PHAST 5.22 0.4 miles
Alternate Case Toxic Methyl Chloride Catastrophic rupture of 2" liquid unloading hose caused by movement while still connected (or other cause). PHAST 5.22 0.54 miles
Alternate Case Flammable Trimethylamine Catastrophic rupture of 2" liquid unloading hose caused by movement while still connected (or other cause). PHAST 5.22 0.11 miles
*PHAST is a product of Det Norske Veritas.
D. General Accidental Release Prevention Program Steps
The following describes the prevention steps in place at the Croda Mill Hall, PA Site.
Croda complies with OSHA PSM by completing Process Hazard Analysis Studies. The date of the
last PHA was April, 1999 and the method used was What-If/Checklist as well as Root Cause Analysis. These studies involve employees and are available for the employees to review.
Croda utilizes many systems to control their process. Some systems include one or more of the following: vents, relief valves, check valves, scrubbers, flares, manual shut-off valves, automatic shut-off valves, interlocks, excess flow valves, rupture disks, alarms and procedures, and inhibitor addition.
Croda utilizes systems to mitigate the consequences. Some systems include one or more of the following: dikes, enclosures, sprinkler systems, and deluge systems.
In addition, Croda is up to date and/or reviewing other elements of the Prevention Program, including:
7 Employee Participation
7 Operating Procedures
7 Compliance Audits
7 Accident Investigations
7 Management of Change
7 Safe Work Practices
7 Contractor Safety
E. Five-Year Accident History
The Croda Mill Hall Site is very c
oncerned about maintaining a safe work environment for their employees and preventing any negative impacts on the surrounding community.
There has been one accident in the last five years, however, it was not due to a chemical release, but rather a vessel explosion resulting in localized consequences. Human error caused the incident. Design changes to the process were made as a result. This incident caused:
7 2 on-site injuries
7 No known onsite deaths or significant property damage
7 No known offsite deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place.
F. Emergency Response Program
Croda in Mill Hall, PA maintains a written emergency response program that is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and account
ing for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs.
The overall emergency response at the site is coordinated with the Clinton County Emergency Response. This organization is the Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The site has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations.
G. Planned Changes to Improve Safety
Croda, Inc. is constantly seeking to improve the safety of the plant. The safety recommendations resulting from the Process Hazard Analysis and compliance audit are to be completed by April, 2000.
Many safety recommendations result from Process Hazard Analyses and the following highlight some of the changes being considered:
1. New ethylene oxide storage tank,
distribution, and measuring system
2. New propylene oxide measuring system
3. Storage tank water deluge systems
4. New bulk storage tank farm with improved concrete diking and sumps
5. Overfill protection systems for bulk storage tanks
6. Critical location vapor sensors with alarms
7. Remotely actuated valves for critical system isolation