Ciba Specialty Chemicals Water Treatments, Inc. - Executive Summary
Risk Management Plan (RMP) |
Executive Summary - June 17, 1999
Ciba Specialty Chemicals Water Treatments, Inc.
West Memphis, AR.
1.1) Site History
Ciba Specialty Chemical Water Treatments, Inc.'s West Memphis, Arkansas manufacturing facility is located at the junction of interstate highway I-55 and the Mississippi river. The site is approximately 150 acres in size and was originally an Army Corp of Engineers barge repair facility during the 1930's. During the 1970's the site manufactured agricultural chemicals for Chemform, Inc. In 1981, CPS Chemical Co. acquired the site and originally had 10 employees. The site grew to 240 employees by 1997 when CPS was purchased by Allied Colloids. Ciba Specialty Chemical Co. acquired the site in 1998 with the purchase of Allied Colloids.The site was used by CPS and later Allied Colloids and now Ciba for the production of water treatment chemicals.
1.2) Ciba's Accidental Release and Emergency Response Policies
as established an Emergency Response Team (ERT) composed of experienced chemical operators and shift supervisors who are trained to respond to an accidental release, fire, spill, or other emergency at the West Memphis site. In accordance with 29 CFR 1910, Hazardous Waste and Emergency Response (Hazwoper) training requirements, all employees receive Awareness Level training. Chemical operators receive Technician Level training and shift supervisors receive Incident Command Level training. The site ERT operates under the same Incident Command Structure as the West Memphis Fire Department (Designated Mutual Aid Provider).
If an incident requires the site's Emergency Response Team to be activated, the incident commander will determine if the West Memphis Fire Department should be notified. Ciba ensures that local authorities are made aware of our efforts to continuously improve the West Memphis site's Emergency Response Plan (ERP) through annual site inspections and walk through reviews
with the West Memphis Hazardous Material (HAZMAT) responders and the fire fighters who would be called on to respond to an emergency at our facility.
2.0) Regulated Substances Summary
Production area P1 produces monomer diallyl dimethyl ammonium chloride (DADMAC) and Epiamine polymers. Both of these products are produced as solutions in water. These monomers and polymers are used in water treatment applications, for removing color and solids from drinking water, and in paper making. There are two RMP regulated chemicals used in P1 in excess of the threshold quantities, dimethylamine (DMA) and epichlorohydrin (EPI). Dimethylamine (DMA) is stored in tank farm 700 north of the P3 production area. Starting in August of 1999, epichlorohydrin (EPI) will also be stored in tank farm 700 in a new storage facility which is currently under construction.
DMA: MQ* = 263,000 lb.
EPI: MQ = 281,000 lb.
* MQ = maximum quantity
Production area P2 produces the methacrylate monomer FM1
and the quaternary monomer salts of both FM1 and the acrylate monomer FA1. Also produced here are DADMAC polymers made from P1 produced monomer. The quaternary salts and polymers are all made and sold as solutions in water. FM1 and FA1 quats are used in co-polymer applications for water treatment, in coatings, and as lube-oil additives. There is one RMP covered chemical used in P2 in excess of the threshold quantity, methyl chloride (MeCl). Starting in August of 1999, methyl chloride (MeCl) will be stored in a new tank located in tank farm 700 north of the P3 production area.
MeCl: MQ = 341,000 lb.
Production area P3 produces FA1 and the P-monomer products which are high purity acrylate and methacrylate monomers. Also produced in P3 are glycidyl ethers and their intermediates. P-monomers are used in solventless ultraviolet (UV) cure coatings and in printing inks. Glycidyl ethers are used in polysilicone manufacture. Typical uses are tub and tile caulks and automotive finishes
. There are two RMP regulated chemicals used in P3 in excess of the threshold quantities, allyl alcohol (AA) and epichlorohydrin (EPI). Allyl alcohol (AA) is stored in P3. Starting in August of 1999, epichlorohydrin (EPI) will be stored in a new tank located in tank farm 700 north of the P3 production area.
AA: MQ = 304,000 lb.
EPI: MQ = 281,000 lb.
3.0 ) Worst-Case and Alternate-Case Release Scenerios
3.1 ) Worst-Case Release for Toxic Substances - allyl alcohol
Using EPA's recommended method of determining worse case weather and release conditions Ciba's offsite consequence analysis determined that the worst case toxic release scenario could have an impact area within an 8.1 mile radius from the site. This scenario was based on the failure or rupture of an entire railcar containing 180,000 lbs of allyl alcohol (AA), spilling all of its contents to the ground. This unlikely event would cause an endpoint concentration of 0.036 mg/liter. The 8.1 mile radius should no
t be considered a public danger zone but is instead an estimate of the maximum possible distance that could be affected under these extreme, unlikely, and catastrophic conditions.
The endpoints specified by EPA for the regulated substances are intended to be protective of the general public. These endpoints are concentrations below which it is believed that nearly all people could be exposed for one half to one hour without any serious immediate or prolonged health effects.
To prevent such a catastrophe from occurring, rail cars are regularly pressure tested and inspected for damage as part of a rigorous preventative maintenance program mandated under Department of Transportation (DOT) regulations for the transport of hazardous materials. Rail cars are equipped with excess flow valves to automatically shut off the flow of material if a line or hose rupture occurs. Site hose standards ensure that unloading hoses are constructed of the proper materials of construction and pressure rat
ing for allyl alcohol service. In addition, unloading lines are pressure checked before each unloading operation and replaced if damaged or worn out.
All transfer of material from rail cars is continuously monitored by chemical operators stationed at the unloading area. The rail sidings are isolated during transfers with hazard warning flags and stops to ensure that no other rail cars can approach a connected allyl alcohol rail car. Instrumentation, computer, and administrative controls are also in place to immediately isolate the storage tank and remotely stop the transfer of material should a leak develop. An existing fire water system includes the capability to suppress the spread of harmful vapors with a portable foam unit to minimize the effects of a leak. In addition, a major upgrade of the facilities' fire water system is currently in construction which will include a 400,000 gal. fire water storage tank. The new fire water system will become operational during the Fall of 1
3.2 ) Alternate Release of Toxic Substances - allyl alcohol
Utilizing the same EPA guidance manual, an alternative, more realistic release scenario for allyl alcohol (AA) determined an impact distance of 0.19 miles for the same endpoint concentration. The alternative release scenario was based on the failure of a transfer hose which would release 200 lbs./ min. of allyl alcohol (AA) for about 10 minutes until the release could be stopped.
3.3 ) Other Alternate Releases of Toxic Substances
An alternative release scenario was also considered for each RMP regulated toxic chemical on site. The alternative release scenarios were based on process knowledge, accident history, and the process hazard analysis conducted for the unit.
The epichlorohydrin (EPI) alternative release scenario was based on the assumption that the rupture disc on a reactor releases material while at temperature during a reaction in P3. The impact area could have a radius of 0.23 miles for an endpoint con
centration of 0.076 mg/liter.
The methyl chloride (MeCl) alternative release scenario was based on the assumption that a transfer hose has failed in P2. The impact area would have a radius of less than 0.06 miles to an endpoint concentration of 0.82 mg/liter.
3.4 ) Worst-Case Release for Flammable Substances - dimethyl amine
The offsite consequence analysis also considered the worst case flammable release scenario. This analysis used EPA's recommended method of determining worse case weather and release conditions to calculate the distance to the 1 psi overpressure endpoint caused by a vapor cloud explosion. This endpoint is a conservative threshold for determining potential serious injuries to people as a result of property damage (e.g. flying glass and debris) as a result of an explosion. Ciba's consequence analysis indicated that the worst case flammable scenario could have an impact area within a 0.46 mile radius from the site. This scenario is based on the failure of a storage
tank containing 244,000 lbs of dimethylamine (DMA). The 0.46 mile radius should not be considered a public danger zone but instead an estimate of the maximum possible distance that may be affected under extreme, unlikely and catastrophic conditions.
To prevent such a catastrophe from occurring, the following preventative measures are employed. The DMA storage tank is periodically inspected for corrosion and excessive wear. The tank is equipped with excess flow isolation valves, passive fire protective insulation, and a fire monitor which includes the capability to suppress the spread of harmful vapors with portable foam canisters to minimize the effects of a leak. DMA is pumped to point of use with sealed canned motor pumps which are periodically inspected for excessive bearing wear to ensure their continued integrity.
DMA rail cars are regularly pressure tested and inspected for damage as part of a rigorous preventative maintenance program mandated under Department of Transportati
on (DOT) regulations for the transport of hazardous materials. Rail cars are equipped with excess flow valves to automatically shut off the flow of material if a line or hose rupture occurs. Site hose standards ensure that unloading hoses are constructed of the proper materials of construction and pressure rating for DMA service. In addition, unloading lines are pressure checked before each unloading operation and replaced if damaged or worn out.
All transfer of material from rail cars is continuously monitored by chemical operators stationed at the unloading area. The rail sidings are isolated during transfers with hazard warning flags and stops to ensure that no other rail cars can approach a connected DMA rail car. Instrumentation, computer, and administrative controls are also in place to immediately isolate the storage tank and remotely stop the transfer of material should a leak develop.
3.5 ) Alternate Releases of Flammable Substances - dimethyl amine
Utilizing the EPA guid
ance manual, an alternative, more realistic release scenario for dimethylamine (DMA) had an impact distance of 0.15 miles for the same overpressure endpoint. The alternative release scenario was based on the failure of a transfer hose releasing 5400 lbs. /minute.
4.0) General Accident Prevention Program & Chemical Specific Prevention Steps
4.1) Accident Prevention Program
The chemical processes subject to the Risk Management regulation are also subject to the Occupational Safety and Health Administrations' (OSHA) Process Safety Management (PSM) standard. Both regulations establish specific guidelines for safe chemical plant operations. Recommended practices are designed both to prevent accidents from occurring and to effectively respond if an incident or accident does occur. Ciba has a specific course of action and procedures in place to address the PSM and RMP Requirements. These include:
Specific Chemical information is contained in Material Safety Data Sheets (MSDS). Inf
ormation regarding toxicity, reactivity, physical data, reactivity data, corrosivity data, thermal and chemical stability data, and hazardous effects of inadvertent mixing is developed for all covered processes. Information regarding process chemistry, block-flow diagrams, safe upper and lower operating limits for process parameters, and consequences of deviations are included in the standard operating procedures (SOP's).
The Maintenance Department maintains fabrication data for all process plant equipment and tracks equipment repair history to ensure ongoing equipment reliability. A preventative maintenance program requires periodic inspection and testing of all vessels, protective equipment, and interlocks on processes containing hazardous materials.
A Process Hazard Analysis (PHA) is conducted on each PSM and RMP covered process. PHA information is maintained by the Engineering Department, including the priority order and schedule of future PHA's. Process Safety Information (P
SI) and PHA's are available to all employees for their review, input, and training.
Standard Operating Procedures (SOP's) are routinely reviewed and updated as needed. Process training is provided prior to new process introduction. Refresher training is conducted at a minimum of every 3 years.
A Mechanical Integrity program is in place and is administered by the Maintenance Department. Changes to covered processes are implemented in accordance with the Site's Management of Change (MOC) procedure. MOC documentation including Hazard Assessment and Pre-Startup safety reviews, is maintained by the Engineering department.
Incident Investigation Procedures include employee participation to ensure that the fundamental causes of all incidents are correctly identified, corrective actions are identified, appropriate, and implemented in a timely manner to prevent a recurrence.
4.2) Chemical Specific Prevention Steps
The dimethylamine (DMA) storage tank is coated with 2 hour rated passi
ve fire protection and is equipped with excess flow valves and automatic shut-off valves to stop the release of material if a line ruptures. The DMA tank also has high pressure and high level alarms and shut-off to prevent over filling of the tank. Fire monitors are located in the area to extinguish a fire if necessary.
The methyl chloride (MeCl) storage tank is also coated with 2 hour rated passive fire protection and is equipped with automatic shut-off valves to stop the release of material if a line ruptures. The MeCl tank also has high pressure and high level alarms and shut-off to prevent over filling of the tank. Fire monitors are located in the area to extinguish a fire if necessary.
The epichlorohydrin (EPI) storage tank is equipped with a spill containment basin and fire monitors and foam deluge system to extinguish a fire if necessary. The EPI tank also has high pressure and high level alarms and shut-off to prevent over filling of the tank.
The two allyl alcohol (AA)
storage tanks are equipped with a spill containment basin and the tank legs are coated with 2 hour rated passive fire protection. The tanks utilize sealless magnetic drive transfer pumps and vapor recovery systems to minimize fugitive emissions. The tanks also have high level alarms and shut-off valves to prevent overfilling of material. There is a fire monitor in the area to extinguish a fire if necessary.
The maintenance department administers a preventative maintenance (PM) program at the site which ensures that all safety critical equipment associated with these tanks is routinely inspected and repaired or replaced before failures occur.
A distributed control system (DCS) is in place at the site and alarms and interlocks have been set up to alert employees and automatically shut off transfers of hazardous materials from these tanks should a leak or over pressure release occur.
5.0) Five Year Accident History
During the past 5 years (June 1994 to June 1999) there have been no
accidents or releases involving a RMP regulated chemical which qualified for notification under EPA's 40 CFR part 68 rule.
In conjunction with the current RMP and PSM programs in place at Ciba's West Memphis facility, there is a standard management practice in place that requires immediate internal reporting of all unusual events, including those in which any abnormal emissions of regulated chemicals are observed or suspected. Supervisory staff review all incident information and determine whether a release has exceeded a reportable quantity including notification of authorities as appropriate.
6.0) Emergency Response Program
If an abnormal event were to occur which releases or has the potential to release a chemical quantity which could lead to an emergency condition, the site's Incident Commander (IC) will activate the Emergency Response Team (ERT) and notify the West Memphis Fire Department. The Emergency Response Plan (ERP) describes how specific events will be managed and th
e appropriate action to be taken by the Incident Commander and emergency responders. The West Memphis Fire Department is provided a copy of Ciba's emergency response plan for review and comment. Ciba encourages the West Memphis Fire Department and other Emergency Agencies to participate in an annual practice drill and routine site inspections to enable Emergency Responders to become more familiar with the facility and response capabilities. Ciba is an active member of the Local Emergency Planning Committee (LEPC) and participates in the emergency response planning for Crittenden County, Arkansas.
7.0) Planned Changes to Improve Safety
The Ciba West Memphis facility, under the Process Safety Management (PSM) and Risk Management Planning (RMP) programs, has organized a management system to effectively identify and control hazards in the workplace and reduce potential risks. Planning aspects of process design, operating procedures, emergency preparedness, the operational elements of
system maintenance, safe operating practices, and ongoing personnel training are an integral part of and considered necessary to support a continuous improvement in facility safety. Periodic reviews of the management systems and rigorous internal audits ensure continuing compliance.
The management system provides the required and necessary information about the safe handling of all chemicals present at the facility. This information is available to all employees and can be made readily available to emergency responders and the community.
Risk Management Planning (RMP) and the integrated risk management program at Ciba's West Memphis Site help to ensure operations that are safe today, and will be even safer tomorrow by providing methods to continue to identify and address potential risks to employees and the community.
8.0) Conclusion - RMP Data Elements
Each facility covered by the RMP Rule must submit one Risk Management Plan (RMP) that covers all its RMP regulated processes.
The plan will be submitted electronically to the EPA and will follow the format provided by the RMP Data Elements Guidance Document published by the EPA on June 20, 1996. The Ciba West Memphis Accident Prevention Program is adopted directly from OSHA's PSM Standard compliance program which is consistent with EPA's Level 3 RMP Program requirements under 40 CFR part 68. The RMP will be filed electronically on June 21, 1999. Thereafter, the RMP will be updated and resubmitted on/ or:
1) The date that a new regulated chemical is introduced to the Ciba West Memphis site in a reportable quantity.
2) 3 years after the date on which the EPA first adds a new chemical to its regulated chemicals list which is used by this facility in a reportable quantity.