Morton International Moss Point ACS - Executive Summary |
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Introduction It is Morton International's policy to achieve continuous improvement in health and safety performance. The Corporation will conduct its worldwide business in a manner, which is protective of the health and safety of its employees, the communities surrounding its facilities, the general public and its customers. Morton recognizes that a commitment to health and safety will result in the optimization of all activities. It is Morton's policy to be a responsible citizen of the global community by operating all of its businesses in a manner, which is protective of the environment. Morton recognizes that the commitment to a sound environment is as essential as the commitment to profitability. It is based upon these policies and in accordance with the United States Environmental Protection Agency's (EPA) Risk Management Program (RMP) Rule that Morton has prepared the enclosed Risk Management Plan. The governing RMP regulations can be found in the Code of Federal Regula tions at Title 40 Part 68. The purpose of this plan is to outline how Morton is using and storing specific chemicals safely and to further explain what Morton does to prevent a release of these chemicals. This RMP plan will also provide information on potential consequences of a catastrophic release and what measures Morton has in place to respond to these emergencies. This Plan is specifically prepared for the Morton Adhesives and Chemical Specialties facility located in Moss Point, Mississippi. Facility Description Morton International, Inc. owns and operates a chemical manufacturing facility located in northeast Jackson County, Mississippi. The street address is 5724 Elder Ferry Road located within the city of Moss Point. The facility is located (approximately 250 yards) north of the Escatawpa River and (approximately 0.2 miles) east of Mississippi State Highway 63. The facility covers approximately 120 developed acres and the operation requires the employment of approximatel y 250 people full time. The chemical facility operates 24 hours per day, 7 days per week, and 52 weeks per year. Its principal products include rubberized sealing products, urethane coatings, and industrial and commercial chemicals. Raw materials and chemical feedstocks used in large quantities are brought to the facility via tankers and railcars and are offloaded for storage into above ground tanks. Raw materials consumed in lesser quantities arrive in 55-gallon drums or smaller containers and are stored in warehouses at the facility prior to processing. Raw materials and intermediate feedstocks are pumped and/or metered from storage tanks or smaller containers (i.e. 55-gallon drums) through above ground piping into reactors and/or distillation columns where finished materials are produced. The products made at the facility require various degrees of washing, drying, and or filtration before they are packaged or stored ready for sale. Finished products are sold in both bulk quantities pumped from storage tanks into tankers, and in smaller quantities packaged on site and shipped from the facility in totes, drums or smaller pails. Commitment to Chemical Safety, Accidental Release Prevention and Emergency Response Morton has been located in Moss Point since 1951 when the Thiokol Corporation first constructed its facility. Morton operates its facility in Jackson County with the highest regard for the safety of all 250 employees and the protection of the local community and the environment of Moss Point. Morton prevents accidents and protects the health and natural resources of Moss Point by designing its equipment for safe operations; maintaining its equipment in safe working order; training its employees to operate equipment safely; auditing its procedures for continual improvement; and planning with and training on comprehensive emergency response procedures. Regulated Substances Morton currently uses seven chemicals at the Moss Point facility, (in quantities greater than the regulatory thresholds) that are regulated by the Environmental Protection Agency's Risk Management Program (RMP) Rule. The following six chemicals are used at the facility as raw materials and are regulated as toxic chemicals in accordance with the RMP rule: * Epichlorohydrin * Ethylene Oxide * Formaldehyde * Hydrochloric Acid * Hydrogen Sulfide * Toluene diisocyanate The following flammable chemical is used at the facility as a raw material and is regulated in accordance with the RMP rule: * 1,3-Butadiene. The following paragraphs provide further details regarding the regulated substances used at the facility. 1,3-Butadiene Morton uses 1,3-butadiene as a feedstock and receives 1-2 railcars of the material each year. 1,3-butadiene is stored at the Morton facility 3-5 months out of the year. The 1,3-butadiene is off-loaded from the railcar into an above ground storage tank where it is then pumped to a reaction vessel through above ground piping. The maximum volume of material that is stored in one vessel at any given time is 160,000 pounds of 1,3-butadiene. The chemical abstract services number (CAS #) that identifies 1,3-butadiene is 106-99-0. Under atmospheric conditions, 1,3-butadiene is a colorless gas with a mild aromatic odor. It is normally stored as a liquid under pressure. It is a highly flammable material and must be kept away from heat, sparks, and other potential sources of ignition. 1,3-Butadiene will quickly evaporate to the air as a gas if it is leaked to the environment. It evaporates very quickly from water and soil. It breaks down quickly in air by sunlight; in sunny weather, half of it breaks down in about 2 hours. Breathing very high levels of 1,3-Butadiene for a short time can cause central nervous system damage, blurred vision, nausea, fatigue, headache, decreased blood pressure and pulse rate, and unconsciousness. There are no recorded cases of accidental exposure at high levels that caused death in humans, but this could occur. Breathing lower levels may cause irritation of the eyes, nose, and throat. Epichlorohydrin Morton uses epichlorohydrin as a raw material and receives approximately one tanker of the material each year. Epichlorohydrin is stored at the Morton facility 12 months out of the year. The epichlorohydrin is off-loaded from the tanker into an above ground storage tank where it is then pumped to a reaction vessel through above ground piping. The maximum volume of material that is stored in one vessel at any given time is 40,000 pounds of epichlorohydrin. The chemical abstract services number (CAS #) that identifies epichlorohydrin is 106-89-8. Under atmospheric conditions, epichlorohydrin is a colorless liquid with an irritating, chloroform-like odor. It is a highly flammable material and must be kept away from heat, sparks, and other potential sources of ignition. Epichlorohydrin vapors may cause irritation to the eyes and skin. Breathing epichlorohydr in vapors may cause severe irritation to the nose, throat and respiratory tract. Ethylene Oxide Morton uses ethylene oxide as a feedstock and receives 4-5 railcars of the material each week. Ethylene oxide is stored at the Morton facility 12 months out of the year. The ethylene oxide is off-loaded from the railcar into an above ground storage tank where it is then pumped to reaction vessels through above ground piping. The maximum volume of material that is stored in one vessel at any given time is 440,000 pounds of ethylene oxide. The chemical abstract services number (CAS #) that identifies ethylene oxide is 75-21-8. Under atmospheric conditions, ethylene oxide is a colorless and odorless gas. It is normally stored as a liquid under pressure. It is a highly flammable material and must be kept away from heat, sparks, and other potential sources of ignition. The liquid vaporizes very rapidly and can produce severe eye and skin burns. Ethylene oxide may cause a delayed skin bu rn. Short-term exposure to vapors can result in difficulty in breathing, coughing, lung irritation, dizziness, nausea, vomiting, unconsciousness, and even death. Longer exposure to lower concentrations may cause severe damage to the lungs, nervous system, reproductive system and other organs. Formaldehyde Morton uses formaldehyde as a raw material and receives approximately one tanker of the material each day. Formaldehyde is stored at the Morton facility 12 months out of the year. The formaldehyde is off-loaded from the tanker into an above ground storage tank where it is then pumped to a reaction vessel through above ground piping. The maximum volume of material that is stored in one vessel at any given time is 500,000 pounds of formaldehyde. The chemical abstract services number (CAS #) that identifies formaldehyde is 50-00-0. Under atmospheric conditions, formaldehyde is a colorless gas with a pungent odor. It is normally handled as a solution in water. Symptoms of for maldehyde exposure include nausea, vomiting, abdominal pain, or diarrhea. Symptoms are both immediate and severe. The prognosis for recovery is very good, unless the dosage is very large. For less severe exposure, a short amount of time can often suffice for treatment. Hydrochloric Acid Morton uses anhydrous hydrogen chloride as a feedstock and receives approximately 2 railcars of the material each week. Anhydrous hydrogen chloride is stored at the Morton facility 12 months out of the year. The hydrogen chloride is stored in the absence of water (anhydrous) and kept under pressure. It is off-loaded from the railcar into a receiver where it is mixed with water and forms hydrochloric acid that is used directly in the process. The maximum volume of material that is stored in one vessel at any given time is 145,000 pounds of anhydrous hydrochloric acid. The chemical abstract services number (CAS #) that identifies anhydrous hydrochloric acid is 7647-01-0. Under atmospheric cond itions, hydrochloric acid is a colorless and extremely irritating gas, which fumes, strongly in moist air. In the anhydrous state, hydrogen chloride is relatively inactive and non-corrosive. However, if it leaks to the air it is readily absorbed by moisture in the air and yields the highly corrosive hydrochloric acid. Hydrochloric acid is corrosive to the eyes, skin, and mucous membranes. Short-term inhalation of high levels of hydrochloric acid may cause coughing, hoarseness, inflammation and ulceration of the respiratory tract, chest pain, and pulmonary edema. Hydrogen Sulfide Morton produces hydrogen sulfide and uses it as a feedstock in its processes. When Morton cannot produce enough hydrogen sulfide to feed its process additional material is received by railcar. During the last several years Morton has greatly reduced the number of hydrogen sulfide railcars that are received at the Morton facility. The hydrogen sulfide is off-loaded from the railcar into reaction vesse ls where it is used in the process. The maximum volume of material that is stored in one vessel at any given time is 130,000 pounds of hydrogen sulfide. The chemical abstract services number (CAS #) that identifies hydrogen sulfide is 7783-06-4. Under atmospheric conditions, hydrogen sulfide is a colorless and flammable, poisonous gas with a rotten egg odor. It is a highly flammable material and must be kept away from heat, sparks, and other potential sources of ignition. Exposure to hydrogen sulfide can irritate the eyes and respiratory tract. Symptoms of exposure to hydrogen sulfide include headache, nausea, vomiting, and coughing. Short-term exposure to very high levels of hydrogen sulfide can cause immediate respiratory arrest. Toluene diisocyanate Morton uses toluene diisocyanate as a raw material and receives approximately 4 tankers of the material each year. Toluene diisocyanate is stored at the Morton facility 12 months out of the year. The toluene diisocyanate is off- loaded from a tanker into an above ground storage tank where it is then pumped to reaction vessels through above ground piping. The maximum volume of material that is stored in one vessel at any given time is 80,000 pounds of toluene diisocyanate. The chemical abstract services number (CAS #) that identifies toluene diisocyanate is 26471-62-5. Under atmospheric conditions, toluene diisocyanate is a white to pale yellow liquid with a sharp pungent odor. Toluene diisocyanate tends to remain in the liquid state and will react slowly with water in moist air to liberate carbon dioxide. Airborne vapors and aerosol mists of toluene diisocyanate are irritating to the upper and lower respiratory tracts. Symptoms of overexposure to toluene diisocyanate vapors may include tightness of the chest and difficult or labored breathing. Exposure to higher concentrations may result in chemical bronchitis, pneumonitis, and pulmonary edema. Effects may be immediate or delayed for hours after expos ure. Symptoms may increase or intensify for a few hours, but usually disappear within a day or two. Brief contact with low concentrations of toluene diisocyanate vapor may cause mild tearing or a slight burning sensation in the eyes. Worst Case Release Scenarios The EPA requires an RMP plan to include a description of the one "worst case release scenario" for all the RMP regulated toxic chemicals handled at a facility and a separate "worst case release scenario" for the RMP regulated flammable chemicals handled at a facility. The EPA applied the following definition to a worst case release: The instantaneous release of the largest quantity of a regulated chemical from a vessel or process line failure that results in the greatest impacted distance. The worst case analysis does not consider the possible causes or the probability that such a release might occur; the release is simply assumed to take place and it is assumed nothing is done to minimize the release. All active safe ty systems must fail simultaneously during the release and the release occurs during the worst possible weather conditions. This scenario is HIGHLY UNLIKELY but must be considered and communicated in the RMP plan. Flammable Chemical The worst case scenario (as strictly defined by EPA above) for the RMP regulated flammable chemical at the Morton facility is the following: A railcar located at the Morton facility containing 160,000 pounds of 1,3-butadiene catastrophically fails. The entire contents of the railcar are released immediately and the total mass is consumed in a vapor cloud explosion. This scenario DOES NOT take into account Morton's safety and prevention systems, and assumes nothing is done to minimize the release Using the referenced EPA look-up tables, the resulting vapor cloud explosion potentially results in a 1-psig-overpressure impact to the immediate community outside of the facility. The expected impact from the overpressure could include pictures or similar i tems falling off walls, items falling off shelves, windows and/or glass dishes rattling and eventually falling and breaking. Toxic Chemical The worst case scenario (as strictly defined by EPA above) for the RMP regulated toxic chemicals at the Morton facility is the following: A catastrophic vessel failure causing the release of the entire contents of a railcar (approximately 145,000 pounds) within 10 minutes. The railcar contains pressurized liquefied hydrochloric acid and the resulting hydrochloric acid vapor cloud disperses as a dense gas. The gas hypothetically migrates outside the facility before dissipating below the calculated endpoint concentration. This scenario DOES NOT take into account Morton's safety and prevention systems, and assumes nothing is done to minimize the release The calculated endpoint is the level below which no harm should come to the community. For the regulated toxic chemicals the EPA has established the endpoint as the concentration in air to whi ch a person could be exposed for up to one hour without serious health effects. Alternative Release Scenarios The EPA recommends an RMP plan include a description of "alternative release scenarios" for all the RMP regulated toxic chemicals handled at a facility and for the RMP regulated flammable chemicals handled at a facility. The EPA applied the following definition to alternative release: An emergency planning release scenario that must result in an impact outside the facility boundary. This scenario is based on a facility's use of a regulated chemical. This emergency planning scenario may account for implementation of a facility's safety systems and emergency response plan (or components) to minimize the release, provided the final results of the scenario meet the above definition. These scenarios ARE NOT likely but must be considered and communicated in the RMP plan. Flammable Chemical The following is an emergency-planning scenario for 1,3-butadiene. This scenario is hypothetical and has not occurred at the facility but is used for planning and preparation. 1,3-Butadiene A 2-inch diameter flexible hose protected with outer wire mesh is connected to a railcar containing 1,3-butadiene. The hose fails and releases material at a rate of 577 pounds per minute. The railcar continues to release material for 5 minutes as the Morton operator overseeing the unloading operation observes the release and responds by immediately shutting off the railcar and isolating the unloading line. A total of 2,884 pounds of butadiene is released and all the material ignites, and is consumed in a vapor cloud explosion. Using the referenced EPA look-up tables, the resulting vapor cloud explosion could results in a 1-psig-overpressure impact outside of the facility. Toxic Chemicals The following are the emergency planning scenarios for the RMP regulated toxic chemicals used at the facility. These scenarios are hypothetical and have not occurred at the facility but are used for planning and preparation. Epichlorohydrin A 2-inch diameter flexible hose connected to epichlorohydrin tank truck fails releasing liquid epichlorohydrin at a rate of approximately 1000 pounds per minute. The tanker continues to release material for 8 minutes as the Morton operator overseeing the unloading operation observes the release and responds by shutting off the unloading pump. The epichlorohydrin is released at an average ambient temperature and forms a pool of liquid that is contained within a concrete unloading station. The epichlorohydrin evaporates from the pool of liquid at a rate of 50 pounds per minute and forms a vapor cloud that dispenses as a buoyant gas. Using the reference EPA look-up tables, the resulting vapor cloud dissipates below the calculated endpoint concentration within the Morton facility. The resulting vapor cloud could impact outside the facility. Ethylene Oxide A 2-inch diameter flexible hose connected to an ethylene oxide railcar fails , and the excess flow valve (which seals the railcar up if the flow rate exceeds 120 gal/min) closes within 10 seconds. Approximately 146 pounds of ethylene oxide is released from the railcar and an additional 95 pounds of ethylene oxide backflows from the process, resulting in a total release of 241 pounds. Approximately 3 percent of the material is consumed in a flash and the remaining liquid spills into the unloading area and creates a thin pool of liquid. The liquid evaporates and the ethylene oxide disperses downwind as a vapor cloud. Using the Gaussian plume model, the resulting vapor cloud dissipates below the calculated endpoint concentration within the Morton facility. The resulting vapor cloud could impact outside the facility. Formaldehyde A 2-inch diameter flexible hose connected to a formaldehyde tank truck fails releasing liquid formaldehyde at a rate of approximately 1000 pounds per minute. The tanker continues to release material for 2 minutes as the Morton ope rator overseeing the unloading operation observes the release and responds by shutting off the unloading pump. The formaldehyde is released at an average ambient temperature and forms a pool of liquid that is contained within a concrete unloading station. The formaldehyde evaporates from the pool of liquid at a rate of 0.75 pounds per minute and forms a vapor cloud that dispenses as a buoyant gas. Using the Gaussian plume model, the resulting vapor cloud dissipates below the calculated endpoint concentration within the Morton facility. The resulting vapor cloud could impact outside the facility. Hydrochloric Acid A 2-inch diameter flexible hose (protected with wire screen) fails during the unloading of a hydrochloric acid railcar. The increase inflow rate causes the excess flow valve to lock up within 10 seconds. Hydrochloric acid backflows from the process line and releases approximately 628 pounds of hydrochloric acid to the atmosphere. The liquid released remains entirely i n a vapor cloud and disperses as an aerosol. Using the SLAB dispersion model, the resulting vapor cloud dissipates below the calculated endpoint concentration outside of the Morton facility. The resulting vapor cloud could impact the local community. Hydrogen Sulfide A 2-inch diameter flexible hose (protected with wire screen) fails during the unloading of a hydrogen sulfide railcar. The increase inflow rate causes the excess flow valve to lock up within 10 seconds. Hydrogen sulfide backflows from the process line and releases approximately 259 pounds of hydrogen sulfide to the atmosphere. The liquid released remains entirely in a vapor cloud and disperses as an aerosol. Using the SLAB dispersion model, the resulting vapor cloud dissipates below the calculated endpoint concentration outside of the Morton facility. The resulting vapor cloud could impact the local community. Toluene diisocyanate An above ground storage tank catastrophically fails releasing 80,000 pounds of liquid toluene diisocyanate instantaneously. The liquid pool spreads to an unconfined pool of liquid and evaporates at a rate of 1.4 pounds per minute. The resulting vapor cloud will disperse as a buoyant gas. Using the reference EPA look-up tables, the resulting vapor cloud dissipates below the calculated endpoint concentration within the Morton facility. The resulting vapor cloud WILL NOT impact outside the facility. Accidental Release Prevention Morton International prevents accidents at its Moss Point plant by designing equipment for safe operation, maintaining equipment in safe working order, training personnel to operate safely, and finally auditing to check and improve equipment and procedures. The following are just some of the ways that Morton ensures that the hypothetical scenarios described in this plan will not occur: Designing for Safe Operation * Industry and engineering standards are applied to all aspects of equipment design and applications. * Rigorous safe operating limits are established and implemented for each system. * Alarms, monitors, and safety interlocks are designed into systems where appropriate. Maintaining Plant Equipment * The mechanical integrity of equipment is tested against engineering standards. * Preventative maintenance is established and conducted for all equipment. * Necessary spare parts are maintained to keep equipment running. * Railcars and tankers are inspected using checklists. * An on-site maintenance staff is trained and qualified to maintain equipment to design specifications. Operating Safety * Operators are trained and certified to operate in process areas before beginning work. * Operators receive continuous training and regular recertification while working in a process area. * Operation personnel monitor process conditions. * Written operating procedures detail safe operating conditions. * Critical work such as hot work and line breaking is controlled by permit systems. Auditing Operations * Period ic independent audits are conducted by the United States Environmental Protection Agency, Occupational Safety and Health Administration and Department of Transportation. * Corporate audits are completed using Process Safety Management and Environmental Quality Standards. * Internal Process Safety Management audits are conducted. * Process Hazard Analysis is conducted on all processes and equipment. * All process changes follow an established management of change system. Accident History (5-year) Morton maintains a dynamic safety program; we are constantly reviewing our programs and looking for ways to strengthen and improve them. Protecting our neighbors is very important. Within the last 5 years, Morton has not experienced an off-site release of any of the regulated chemicals. No persons have been injured outside the facility due to any release that has occurred at the facility. Emergency Response Procedures Morton works hard to develop and maintain its emergency response syst em so that we are prepared in the event of an emergency. Some of the components of the emergency response program include: * Plant wide fire protection and water deluge systems are maintained and inspected regularly. * Vapor recovery and neutralization systems are maintained to capture potential releases and keep them from the environment. * A plant wide emergency response plan is reviewed annually and updated when improvements are possible. * All plant personnel are trained to respond to the various types of emergencies that might occur. * Employees trained in first aide are on-site at all times. * The emergency response plan is practiced regularly * The facility works with the Moss Point fire department to ensure emergency responders are familiar with facility. * Morton actively participates in the Jackson county local emergency planning commission Planned Changed Safety programs are constantly reviewed, evaluated, and updated to ensure continuous improvements and regulatory comp liance. Employee input and suggestions are welcome and evaluated for implementation. Morton will continue to adhere to its policies outlined in the introduction to this document and will always seek ways to improve its safety program and minimize the potential impact to the environment. Morton International, Inc. Moss Point, MS Risk Management Plan Executive Summary June, 1999 13-13 - |