ALBEMARLE CORPORATION - Executive Summary |
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EXECUTIVE SUMMARY - ALBEMARLE CORPORATION ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At the Albemarle Pasadena plant, we are committed to operating and maintaining all of our processes in a safe and responsible manner. The release prevention program and the emergency response and planning program are tools that assist us in assuring the safety of our employees, the general public and the environment. This document provides a brief overview of the risk management activities that are in place at the Pasadena plant, including: * a description of our facility and use of substances regulated by EPA's RMP program, * a summary of results from our assessment of the potential offsite consequences from accidental chemical releases, * a summary of our release prevention program, * a five-year release history of EPA RMP regulated chemicals, * a summary of our emergency response program, and * planned improvements that may assist in preventing accidental releases. FACI LITY AND REGULATED SUBSTANCES The Albemarle Pasadena plant produces organic and inorganic specialty chemicals, including two families of chemicals known as aluminum alkyls and aluminum alkyl halides. The primary use of these chemicals is as catalyst. The aluminum alkyls and aluminum alkyl halides are produced in specialized process equipment which are designed to maximize safety and efficiency of operations. The manufacturing process is also controlled by a computerized system which is monitored by highly trained operators. The following chemicals that EPA has identified as having the potential to cause significant offsite consequences should a substantial accidental release occur are used: Toxics: Methyl Chloride Flammables: Isobutylene Isopentane Our contingency planning and release prevention programs are tools that we use to manage the potential hazards posed by these chemicals to our employees, the public and the environment. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS We are required by the EPA to provide information about the worst-case scenarios and alternative release scenarios for our facility. To accomplish this, we are providing summaries of each scenario and information about the critical administrative controls and measures that we have in place to mitigate the distance of any release. Worst-case Scenario - Methyl Chloride (regulated toxic) The worst case scenario for methyl chloride is defined as the failure of a 20,000 gallon rail car and subsequent release of all contents in ten minutes. Per EPA guidance, the release scenario assumes that all active safety systems fail, the worst weather condition occurs (stable, low wind speed), and that there is no emergency response to reduce impact and risk. The worst case scenario was modeled using the OCA Guidance provided by the EPA. Under the conditions of this scenario (including the most likely wind direction), areas northwest of the plant, the ship channel and areas on the north bank exte nding to approximately the old ARMCO Steel site may be impacted. Alternative release Scenario - Methyl Chloride (regulated toxic) The alternative scenario that involves methyl chloride is defined as the failure of a 3 inch feed line. In this scenario, all active and passive safety systems function properly and emergency shutdown systems operate quickly to isolate the release. The weather conditions for this scenario are the more common moderate winds from the southeast. Under the conditions of this scenario, we impact our industrial neighbors who share our Pasadena chemical complex (i.e. BP-Amoco, Ethyl Corporation and MEMC Pasadena, Incorporated). The release does not extend to residential areas. Worst-case Scenario - Isopentane (regulated flammable) The worst-case scenario for isopentane involves the instantaneous failure of a 25,000 gallon storage tank and the release of its contents in 10 minutes. Per EPA guidance, the release scenario assumes that all active safety system s fail, the worst weather condition occurs (stable, low wind speed), and that there is no emergency response to reduce impact and risk. The worst case scenario was modeled using the OCA Guidance provided by the EPA. If the resulting vapor cloud from this failure were to ignite, the over pressure damage would be limited to our industrial neighbors who share our Pasadena chemical complex. The release does not extend to residential areas. Alternative release Scenario - Isobutylene (regulated flammable) The alternative scenario involves the chemical isobutylene. This scenario, which is more realistic than the worst-case scenario, involves the failure of a gasket in a transfer line. It is assumed that all active and passive safety systems work and the emergency shutdown systems function to isolate the release. The weather conditions for this scenario are the more common moderate wind from the southeast. In this scenario, we impact an industrial neighbor (BP-Amoco) who shares our Pas adena chemical complex. The release does not extend to residential areas. GENERAL ACCIDENT RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Albemarle has always believed in taking a structured, proactive approach to preventing accidental releases of chemicals. The most significant management system in place is the Process Safety Management program. Key features of this prevention program include: * Process safety information, * Process hazards analysis, * Operating procedures, * Training, * Mechanical integrity, * Management of change, * Pre-startup safety reviews, * Compliance, safety and housekeeping audits, * Incident investigations, * Employee participation, * Safe work permit procedures (including ignition source, confined space and "cold" work permitting programs) * Contractor safety program, * Relief valves (that vent to a flare system which is designed to destroy any relief gases/vapors so that they will not contaminate the atmosphere), * Remot ely actuated isolation valves to minimize any release. Additionally, we implement the following chemical-specific prevention steps: Methyl chloride - * Methyl chloride is purchased and inventoried in a manner which minimizes the time the chemical is on the plant site or in the manufacturing process. * The unloading equipment is designed to minimize the potential for releases. Isopentane - * Deluge systems have been designed and installed to protect the storage vessels and pipe racks, by minimizing fire damage through dilution and confinement. Isobutylene - * Deluge systems have been designed and installed to protect the storage vessels and pipe racks, by minimizing fire damage through dilution and confinement. These prevention steps, together with our Process Safety Program, form the nucleus of our release prevention program. Albemarle and its employees are committed to operating within this system to maintain a safe work environment for our employees and to minimize the ch ances of a release that may affect our neighbors. FIVE-YEAR ACCIDENT HISTORY Albemarle Corporation maintains records of all significant chemical releases that occur. We have had no significant releases of any RMP regulated chemicals in the past five years. EMERGENCY RESPONSE PROGRAM The Albemarle Pasadena plant maintains an integrated contingency plan which consolidates all federal, state and local regulatory requirements for emergency response planning. The plant program provides the essential planning and training to effectively protect workers, the public and the environment during an emergency. Our emergency response plan is coordinated with that of the community, the Pasadena LEPC, the Channel Industries Mutual Aid Association, and industrial neighbors who share our fenceline (BP-Amoco, Ethyl Corporation, MEMC Pasadena, Incorporated). The shared fenceline defines our chemical complex. The site emergency response team which consists of members from all companies operating on the complex, includes a fire brigade, rescue team and an emergency medical team. The members of the emergency response team are trained to the hazardous materials technician level, which allows them to not only respond to fires, but also to any spill of hazardous material. In addition, we conduct frequent drills with our neighbors in the complex to ensure that our plan is comprehensive and our people are prepared for incidents which may occur. While our emergency response team is primarily designed for on-site use, it is available to the community via the Channel Industries Mutual Aid Association. To support these groups, a highly equipped ambulance, two fire trucks and a rescue vehicle are maintained. Albemarle has the responsibility for maintaining the mobile emergency response equipment and for training and certification of the members of the team. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we have completed, or are implementing at the f acility to prevent and/or better respond to accidental chemical releases: * Upgrading the Process Safety Management Program - The Process Hazards Analysis section of the Process Safety Management program is being modified to include additional methods for analyzing our processes. This change also allows us to perform analyses more frequently. * Auditing and inspecting all systems to ensure Y2K compliance * Upgrading instrumentation |