Crosfield Catalysts - Executive Summary |
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CROSFIELD CATALYSTS EXECUTIVE SUMMARY FOR EPA'S RISK MANAGAMENT PROGRAM May, 1999 FACILITY DESCRIPTION The site, located on the southwest side of Chicago, is a manufacturer of industrial inorganic catalysts. It began operations in 1942 making fluid cracking catalysts. Although there have been several different owners over the years, the site continues to specialize in inorganic catalyst manufacturing. The products are used in the petroleum refining and specialty petrochemical industries. All of the products produced at the site are non-volatile and non-flammable. The oil industry uses these products to remove sulfur, nitrogen, and other impurities form crude oil. Our products, therefore, help reduce the amount of sulfur and nitrogen oxide emissions during the refining stage and also in the consumption of gasoline and other petroleum based products. COMMITMENT TO SAFETY, HEALTH & THE ENVIRONMENT Throughout the years, there has been very strong commitment to operating in a manner that is safe for its employees, contractors, neighbors and the environment. Attached is a copy of our Environmental Policy Statement and Guiding Principles. We are proud of our efforts, some of which have received recognition. These include: > The creation of a Community Advisory Panel to provide a forum for open discussion with local schools, businesses, community leaders, and residences. > In 1994 we were recognized for our pollution prevention efforts by the Hazardous Waste Research and Information Center (division of the Illinois Department of Energy and Natural Resources). > In 1997 we were one of the few companies chosen by the Illinois Environmental Protection Agency to demonstrate pollution control techniques to a pollution prevention delegation from China. > We have been one of the few industrial representatives serving on the Chicago LEPC since its inception. > Participated in Chicago's Adopt-A-School program, science fair judging, and career development progr ams. > Conducted a mock emergency with local entities to test our emergency response plan. Continue to have mock emergencies quarterly. > Have conducted 2 open house days to allow community members to see our facilities and learn what we do. > Recognized this year by the Illinois Safety Council for achieving 1 million hours worked without a lost time injury. EPA'S RISK MANAGEMENT PROGRAM Section 112(r) of the Clean Air Act Amendments requires the U.S. EPA to develop regulations that mandate industry to implement actions that minimize the chance for an accidental release of either toxic or flammable materials. The is called the Risk Management Program (RMP). The final RMP rule applies to all major stationary sources with processes that store or handle a regulated substance (63 listed flammable and 77 listed toxic substances) at or above the threshold quantity. Crosfield Catalysts has only one chemical that falls under this regulation. This is ammonia water which is stored in an outside storage tank within a concrete dike. There are three levels of compliance for the RMP that must be addressed by all who fall under this regulation. Due to our safe operations and the fact that we pose no risk to the public, Crosfield qualifies for the level I program as described below: FIVE YEAR HISTORY Crosfield has had no incidents involving toxic or flammable materials that have had any off site impact in the last 5 years. WORST CASE RELEASE SCENARIO Crosfield hired an independent consulting firm to evaluate the worst case release scenario for our single regulated material, aqueous ammonia. It was assumed that the entire contents of the ammonia storage tank would release instantaneously and is contained within the dike (which can hold 1 1/2 time the contents of the storage tank and, due to its dimensions, limits the surface area of any liquid spill). Per EPA requirements, worst case meteorological conditions were also assumed. Using sophisticated gas dispersion comput er modeling, it was determined that it is not possible to have an adverse impact to any offsite public or environmental receptor. ALTERNATIVE RELEASE SCENARIO Although not required by the EPA regulations, Crosfield also evaluated an alternative release scenario. In this case, it was assumed that there would be a break in the connecting hose while pumping ammonia from a delivery tank truck into our storage tank. The truck would be positioned on our existing spill pad and it was assumed the spill continued for 10 minutes before it was observed and stopped. Again, using worst case meteorological conditions, the computer model determined that there is no adverse impact to any offsite public or environmental receptor. ADDITIONAL SAFEGUARDS Crosfield has many other systems and procedures in place to help assure there are no spills of aqueous ammonia. These include: > A storage tank level device with a direct read out. > A tight inventory control system. > A high level alarm on the stor age tank to prevent overfilling > A secondary high level alarm to prevent overfilling. > A "permit to unload" system. > A padlock on the tank fill line to prevent unauthorized filling. > A preventive maintenance system to maintain tank and instrument integrity. EMERGENCY RESPONSE In the unlikely event of a spill, Crosfield maintains trained emergency response teams on every shift to respond to such situations around the clock. Through rigorous training and regular mock drills, they maintain their expertise and are well equipped to quickly respond to and mitigate spills of this nature. Crosfield's written emergency response procedures are routinely updated and a copy of our coordinated emergency response plan is kept by the Chicago Fire Department, who would respond to any site emergency. We have worked closely with the Fire Dept. to no only develop our written plan, but also to conduct drills with them and have routine preplanning with the local responders. ENVIRONMENTAL POLICY STATEMENT We are committed to meeting the needs of customers in an environmentally sound and sustainable manner, through continuous improvement in environmental performance in all our activities. GUIDING PRINCIPLES As a member of the Chemical Manufacturers Association, we are committed to support the continuing effort to improve the responsible management of chemicals through their Responsible Care program. As such, we subscribe to the following principles: * To recognize and respond to community concerns about chemicals and our operations. * To develop and produce chemicals that can be manufactured, transported, used and disposed of safely. * To make health, safety and environmental considerations a priority in our planning for all existing and new products and processes. * To report promptly to officials, employees, customers and the public, information on chemical-related health or environmental hazards and to recommend protective measures. * To counsel customers on the safe use, transportation and disposal of chemical products. * To operate our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public. * To extend knowledge by conducting or supporting research on the health, safety and environmental effects of our products, processes and waste materials. * To work with others to resolve problems created by past handling and disposal of hazardous substances. * To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment. * To promote the principles and practices of Responsible Care( by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of chemicals. |