Albemarle Corporation - Executive Summary |
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Albemarle manufactures pharmaceuticals and specialty chemicals at the Orangeburg, South Carolina facility. In the course of manufacturing these products, six flammable and four toxic materials as defined in the Risk Management Planning (RMP) list of chemicals are utilized and stored in greater than threshold quantities. Although there have been no incidents associated with Albemarle operations, the RMP regulations require these materials to conform to Program 3 requirements. Thus a Hazard Analysis, a prevention program, and an Emergency Response Program are in place for all RMP materials on site. Albemarle has established a strong, comprehensive safety program. This includes process safety, employee health and safety, and emergency action plans that provide a strong and effective prevention and remediation program to minimize the risk of Albemarle's operations. The process safety program was developed based on the requirements contained in the OSHA Process Safety Management regul ations, and the Chemical Manufactures Association Responsible Care Code of Management Practices. The program is reviewed and modified to continuously improve it's effectiveness and in turn Albemarle's safety performance. More recently Albemarle's procedures have been reviewed and updated to include the requirements of the EPA Risk Management regulations. Process safety along with employee health and safety programs have been in place for many years and are a result of a corporate culture that continues to commit significant resources to ensure that its operations pose a minimum of risk to its workers, the community, or the environment. The worst case scenarios represent very low probability events and in some cases are scientifically infeasible. The RMP regulations require the worst case scenarios "... principally to support a dialogue between the source and the community on release prevention , and not to serve as the sole or primary basis for local emergency planning". [RMP Rule Preamble FR 31683]. Although worst cases scenarios are required by the regulations to promote a creative dialog, the EPA does not expect industry to consider these events for the purpose of emergency response planning. The worst case scenarios for all RMP materials at Albemarle's facility would have endpoints off site. This did, as expected by the EPA, prompted an evaluation of the tanks and transportation containers to assure that the worst case events conform to the EPA's assumption i.e., that these events are improbable and actually represent events that would never be expected to occur. The requirement for RMP materials was evaluated; however, the demands of the production units make storing some materials on site above the threshold quantity a necessity. Based on this evaluation, it was concluded that storage quantities have been minimized and that Albemarle's worst case scenarios are all highly improbable or infeasible. The alternate release scenarios for toxic and fl ammable materials would have end points off site but well within the area covered by Albemarle's emergency response plan. Albemarle has for may years maintained an effective emergency response system consisting of community sirens, trained response personnel, 24-hour a day command center and a fully equipped alternate command center which can respond to any of the alternate release scenarios and other emergency situations. Although Albemarle has never experienced an event that had an effect off site, it has for many years coordinated its emergency response plans with community response agencies and personnel. Albemarle communicates with the public the significance of the siren system by annual mailings of calendars. The siren system is tested monthly, the command center personnel receive annual refresher training, and annual unannounced drills are conducted to test the system and personnel to ensure the emergency response system will be effective in an emergency. |