ICI Americas, Inc. - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

EXECUTIVE SUMMARY - RMP SUBMIT 1999 
 
Abstract 
 
The following is the Executive Summary of the Accidental Release Program at ICI Americas, Inc.  As required under US-EPA 40 CFR 68.155, it outlines the following aspects of Accidental Release Prevention at our facility: 
 
' 68.155(a):    The accidental release prevention and emergency response policies; 
' 68.155(b):    The stationary source and regulated substances handled; 
' 68.155(c):    The worst-case release scenarios and the alternative release scenarios for each regulated toxic and flammable material subject to regulation; 
' 68.155(d):    The general accidental release prevention program and chemical-specific prevention steps 
' 68.155(e):    The five-year site accident history 
'68.155(f):    The Emergency Response Program 
' 68.155(g):    Planned changes to improve safety 
 
40 CFR 68.155(a): Site Release Prevention and Emergency Response Policies 
 
ICI Americas, Inc. (ICI-Bayonne) has implemented an Accidental Release Prevention Program which includes Pro 
cess Safety Information according to a documentation plan. 
 
Process Hazard analyses are conducted on a five-year schedule by a process hazard analysis team, using HAZOP techniques.  The team is composed of a HAZOP Team Leader, Process Supervisors, Process Operators, Maintenance Personnel and other personnel familiar with site production and safety.  Results of these Hazard Analyses have been recorded on the HAZOP 1, 2 and 3 ProFormas.  Recommendations resulting from these HAZOPs are recorded, assigned to specific personnel and tracked by the Process Safety Supervisor. 
 
Operating Procedures are written by process supervisors, operators and others with input from all affected parties.  These Operating Procedures are reviewed by representatives of the site Safety, Health and Environment; Site Management; Site Production Management, Site Engineering; and Research & Technical Departments before they are adopted into the site's Catalogue of Standard Operating Procedures.  Operating procedure 
s are maintained and are available on local computer networks on a read-only basis.  Any changes to Operating Procedures must be made via the site's Management of Change Procedure, where they are reviewed by the above noted departments before adoption onto the site's computer network. 
 
40 CFR 68.155(b) Site Description and Regulated Substances Handled 
 
ICI-Bayonne occupies approximately 34.5 acres in the Constable Hook area of the city of Bayonne, NJ, a heavily industrialized area bordered on three sides by New York Bay.  The site employs 137 full-time staff and one part-time employee.  The site manufactures only one product, polytetrafluoroethylene, an adhesion-resistant plastic used in numerous consumer, medical and industrial applications whose trade name is Fluon. 
 
The regulated substances handled at the site are approximately eighteen thousand pounds of Anhydrous Ammonia, CAS # 7664-41-7  which is used as a refrigerant gas in the sites refrigeration and chiller system; thirty tho 
usand pounds of Tetrafluoroethylene, CAS  
# 000116-14-3, a raw material which is polymerized to form Fluon; and approximately thirty seven thousand one hundred twenty five pounds of Anhydrous NH3 Equivalent dissolved in water to form a 27.5% solution of Aqueous Ammonia,  CAS# 7664-41-7, which is utilized in the plants Wastewater Treatment system. 
 
40 CFR 68.155 (c): Worst-Case and Alternate Release Scenarios 
 
The Worst Case Release Scenario (WCS) for Anhydrous Ammonia is estimated to reach a Toxic Endpoint of 1.6 miles, determined using the Lookup Tables in the EPA RMP Guidance for Ammonia Refrigeration Document.  This may result in impacts on public receptors within the city of Bayonne and possibly Staten Island.  Diking of the bulk Ammonia receiver is used as passive mitigation. 
 
The WCS for Tetrafluoroethylene is expected to reach a 1 psi overpressure at 260 feet from the source point.  While this technically crosses the sites nearest property line, it is not expected to have an 
y appreciable offsite impact. 
 
The WCS for Aqueous Ammonia will result in a Toxic Endpoint at approximately 0.05 miles, and is not expected to any appreciable offsite impact.  Diking of the Bulk Storage tank is used as passive mitigation. 
 
The Alternate Scenario (ACS) for Anhydrous Ammonia is predicted via dispersion modeling to reach a Toxic Endpoint of  0.22 miles at 11 minutes into the release.  This ACS was based on a 1/8 inch diamter pipe leak on theCondenser Bank.  A total of 754 pounds of Ammonia was released over the course of 60 minutes. 
 
The ACS for Aqueous Ammonia reaches the Toxic Endpoint of .08 miles at 60 minutes.  This release was given a duration of two hours, and does not account for mitigation features ordinarily in place. 
 
40 CFR 66.155(d): Accidental Release Prevention Program 
 
Release prevention steps at the site include relief valves, check valves, manual shutoff systems, automatic control interlocks, alarms, written procedures, direct attendance by process ope 
rations personnel, keyed bypasses, emergency air supplies, emergency power systems, grounding equipment, rupture disks, excess flow monitors, alarms and controls, purge systems, and excess pressure and temperature control interlocks. 
 
Mitigation systems used are water deluge systems, sprinkler systems, firewalls, and neutralization systems. 
 
The process areas are monitored by a system of continuous leak detection sniffer systems, which are interlocked with readouts and alarms in the production Control Room.   
 
Operator initial and refresher training is actively revised and reconducted as changes to these and other production systems are made.  This retraining is encompassed within the sites Operator Training program. 
 
All Release Prevention, Mitigation and area sniffer systems are subject to the sites Preventative Maintenance program.  Equipment reliability information is used in scheduling routine inspections and tests  of these systems to ensure their uninterrupted operation. 
 
Th 
e sites Management of Change program, monitored by the ICI Safety, Health and Environmental manager, ensures that equipment, process or software changes are not made without the direct input of all affected individuals.  All changes are screened by the SHE Manager to determine if further HAZOP studies are required for a particular change.  No changes are made which do not conform to corporate standards for safe design and operation. 
 
All incidents are investigated to determine root cause and identify any potential system deficiencies requiring correction. 
 
40 CFR 68.155(e) Five-Year Accident History 
 
There were no EHS accidents during the five-year period in question. 
 
40 CFR 68.155(f)    The Emergency Response Program 
 
ICI-Bayonne maintains an Integrated Contingency Plan known onsite as the FEPP or Facility Emergency Preparedness Program.  The plan defines the structure of ICI-Bayonnes on-site response team, its coordination with the local emergency response agencies such as the Bayon 
ne OEM which is managed by the Bayonne Fire Department, equipment inventories and locations on site, response procedures, site emergency notification procedures, and emergency response drills.  The FEPP is updated as necessary based on results of emergency response drills, response team staffing, or other detail changes. 
 
40 CFR 68.155(g)    Planned Changes to Improve Safety 
 
While current site control and safety systems reflect the state of the art for design, it is recognized that safety is a continuing process.  To this end, ICI-Bayonne actively maintains a Behavior-Based Safety Management program known as SABRE.  Other changes include those items resulting from the latest HAZOP Revalidation, conducted in May 1998.
Click to return to beginning