Clariant Mt Holly Plant - Executive Summary |
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At the Clariant Corporation Mt. Holly Plant, we are committed to operating and maintaining our process 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: 7 A description of our facility and use of substances regulated by EPA's RMP regulation 7 A summary of results from our assessment of the potential offsite consequences from accidental chemical releases 7 An overview of our accidental release prevention programs 7 A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 7 An overview of our emergency response program 7 An overview of recent improvements at the facility to help prevent accidental chemical releases from occurr ing and adversely affecting our employees, the public, and the environment Stationary Source and Regulated Substance: Our facility uses Ethylene Oxide, Propylene Oxide, Methylamine, and Formaldehyde to produce a wide variety of soaps, detergents, dyes, and agricultural products for use in consumer and industrial products. The EPA has identified these chemicals as having the potential to cause adverse offsite consequences in the event of a substantial accidental release. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the potential hazards that are posed to our employees, the public, and the environment by our use of these chemicals. Offsite Consequence Analysis Scenarios: EPA's RMP rule requires that we provide information about the worst-case release scenario (as defined by the EPA) and alternative release scenarios for our facility. The following are brief summaries of these scenarios, including information about the k ey administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Ethylene Oxide Our worst-case toxic release scenario is complete failure of an ethylene oxide railcar and all our safety systems while unloading ethylene oxide. A railcar holds 180,000 pounds of liquid ethylene oxide. The evaporating ethylene oxide could potentially reach offsite endpoints and nearby public receptors. The site has implemented a process safety management system, including railcar inspection, security, physical barriers and unloading procedures intended to prevent this type of incident from occurring. Worst-case Release Scenario - Methylamine Our worst-case flammable release scenario is complete failure of the methylamine storage tank and all our safety systems. The methylamine tank holds 80,000 pounds of liquid methylamine. The evaporating methylamine could be involved in a vapor cloud explosion, however, according to the EPA's off-sit e consequence analysis software, the effects would not reach public receptors. The site has implemented a process safety management system, including tank inspection, security, physical barriers and operating procedures, intended to prevent this type of incident from occurring. Alternative Release Scenario - Ethylene Oxide One RMP alternative release scenario involves the rupture of an ethylene oxide piping connection, resulting in the release of approximately 15,930 pounds of ethylene oxide over a period of 45 minutes. Our on-site emergency response team would use automatic and manually operated valves to stop such a release. Per the EPA's off-site consequence analysis software, ethylene oxide released in this scenario could impact public receptors within 0.6 miles of the facility. The public receptors that could be impacted by such a release are nearby residences. The site has implemented a process safety management program that includes inspection and scheduled replacement o f piping connectors to prevent this type of scenario from occurring. Alternative Release Scenario---Methylamine A second RMP alternative release scenario involves the rupture of a methylamine pipe, resulting in the release of approximately 77,265 pounds of methylamine over a period of 85 minutes. Per the EPA's off-site consequence analysis software, the effects of this methylamine release would not impact public receptors. Again, the site has implemented a process safety management program that includes inspection and scheduled replacement of unloading hoses to prevent this type of scenario from occurring. Alternative Release Scenario - Formaldehyde A third RMP alternative release scenario involves the rupture of a formaldehyde piping connection, resulting in the release of approximately 123,000 pounds of formaldehyde into a dike over a period of 50 minutes. Our on-site emergency response team would use on-site emergency response equipment to reduce the effects of such a release . Per the EPA's off-site consequence analysis software, formaldehyde released in this scenario could impact public receptors within 0.06 miles of the facility. The public receptors that could be impacted by such a release are nearby residences. The Mt. Holly Plant has implemented a process safety management program that includes inspection and operating procedures to prevent this type of scenario from occurring. Alternative Release Scenario - Propylene Oxide Our last alternative release scenario involves the rupture of a propylene oxide piping connection, resulting in the release of approximately 15,400 pounds of propylene oxide over a period of 45 minutes. Our on-site emergency response team would use automatic and manually operated valves to stop such a release. Per the EPA's off-site consequence analysis software, propylene oxide released in this scenario could impact public receptors within 0.18 miles of the facility. The public receptors that could be impacted by such a r elease are nearby residences. The site has implemented a process safety management program that includes inspection and scheduled replacement of piping connectors to prevent this type of scenario from occurring. 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. Chemical Release Prevention Program: At Clariant Corporation's Mt. Holly Plant we take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: 7 Process safety information 7 Process hazard analysis 7 Operating procedures 7 Training and certification of operators 7 Mechanical integrity 7 Management of change 7 Pre-startup review 7 Compliance audits 7 Incident investigation 7 Employee participation 7 Hot work permit 7 Contractor safety As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: 7 Dual, independent safety controls on the ethylene oxide systems 7 Operators are specifically trained and certified on the chemical systems they operate. Training is conducted each year in safety and chemical processing, and operators must recertify on the systems they operate every three years. 7 Contractors are selected for their safety record and maintenance capabilities 7 All processes undergo extensive safety analysis by teams of engineers, chemists, plant operator, and maintenance personnel before beginning operation. Systems are reanalyzed at least every five years. 7 All plant modifications and procedure changes undergo a management of change process that involves operators, maintenance, engineering, and chemists in a safety review 7 Hazardous materials handling procedures 7 Ethylene oxide, propylene oxide, formaldehyde, and methylamine storage tank inspection, certification and maintenance program These indivi dual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to maintaining these management systems and recognize that this is the way we do business. We have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. Five Year Accident History: There have been no RMP-level releases of ethylene oxide, propylene oxide, methylamine, or formaldehyde in the past five years at our facility. However, we have a system in place to investigate and keep records of significant incidents, including accidental chemical releases that might occur at our site. If a significant release should occur, we will conduct a formal incident investigation to identify and correct the root cause(s) of the event. We also gather information on other significant incidents at other facilities, and implement changes if necessary in our facility to prevent incidents. Emergency Response Planning: We maintain emergency response plans, which address 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 workers, the public, and the environment during emergency situations. Our plan also includes specific procedures for responding to a release of RMP chemicals. Furthermore, we coordinate our plan with the Gaston and Mecklenburg County Local Emergency Planning Committee (LEPC). Emergency response drills have also been conducted with the local emergency response organizations. Seventy Clariant Mt. Holly employees are trained in emergency response, fire fighting, and hazardous materials response and must pass a physical exam and proficiency tests. Training for a typical emergency responder is over 70 hours per year. The plant has an extensive fire fighting system with two fire trucks, monitor nozzles, hoses, foam generating capab ility, and sprinkler systems. In addition, the site has an emergency command vehicle complete with air monitoring equipment, radio and cellular phone systems, emergency response, and decontamination materials. Recent Changes to Improve Safety: The following is a list of improvements that have recently been made at the facility to help prevent accidental chemical releases: 7 Ethylene Oxide equipment has been updated and new safety systems installed, reducing the probability of a release 7 The methylamine storage system is under revision to reduce the probability and severity of a release 7 Revised safety permits and procedures have been put in place at the plant. In summary, Clariant is committed to the safe operation of our facility, and we take the actions necessary to ensure the safety of our employees, members of the community, and the environment. |