Cytec Industries, Mobile Plant - Executive Summary |
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Mobile (a) ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Cytec is a leader among chemical manufacturers in its safety, health and environmental programs. Our commitment to protect our employees and the communities that are home to our operations is an integral part of Cytec's way of doing business. Cytec has established safety, health, emergency response and environmental policies and standards to meet or exceed all regulatory requirements. As a member of the Chemical Manufacturers' Association (CMA), Cytec subscribes to the codes established for Responsible Care .. (b) THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED Our facility has 3 processes that involve regulated substances. The Synthetic Size process makes resins that are used to produce consumer paper products such as paper plates and bathroom tissue. Regulated substances involved with this operation are hydrochloric acid and formaldehyde The Surface Size process makes coatings that are used in the manufacture of high quality paper such as that found in magazines. The regulated substance involved with this operation is ammonium hydroxide solution. The Specialty Chemicals process makes water-soluble organic polymers that are used to remove solids from a number of different wastewater applications. The regulated substances involved with this operation are hydrochloric acid and ammonium hydroxide solution (c) WORST-CASE RELEASE SCENARIO AND ALTERNATIVE RELEASE SCENARIOS The toxic worst-case scenario is the failure of a storage tank and the release of 69,300 pounds of hydrochloric acid. The mitigating effect of a dike was included in the evaluation of the possible consequences. The evaporating hydrochloric acid could reach offsite endpoints and nearby public receptors. The alternative release scenario for hydrochloric acid is the failure of a pipe during unloading and the release of 962 pounds of material. The mitigating effect of an emergency shutdown was include d in the evaluation of the possible consequences. The evaporating hydrochloric acid could reach offsite endpoints and nearby public receptors. The alternative release scenario for formaldehyde is the failure of a pipeline during unloading and the release of 2,752 pounds of material. The mitigating effects of a dike, drain, sump, neutralization and an emergency shutdown system were included in the evaluation of the possible consequences. The cloud formed by the evaporating formaldehyde could reach offsite endpoints and nearby public receptors. The alternative release scenario for aqua ammonia is the failure of a pipeline during unloading and the release of 1,480 pounds of material. The mitigating effects of a dike, enclosure, drain, sump and an emergency shutdown system were included in the evaluation of the possible consequences. The evaporating formaldehyde could reach offsite endpoints and nearby public receptors. (d) THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND C HEMICAL-SPECIFIC PREVENTION STEPS Cytec's general accidental release prevention program includes: 7 EPA 40 CFR 68 - Risk Management Plans 7 OSHA 29 CFR 1910.119 - Process Safety Management of Highly Hazardous Chemicals 7 OSHA 29 CFR 1910.120 - Hazardous Waste Operations & Emergency Response 7 Other EPA, OSHA, DOT and State regulations 7 Generally recognized & accepted engineering codes and standards, and 7 Cytec Safety, Health, Environmental and Engineering standards The following engineering and administrative controls help prevent a release of aqua ammonia. - Storage tank high level alarm - Loading/unloading vapor return system - Written process instructions for using aqua ammonia - Diking around the storage tank - Storage tank equipped with conservation vent - The following engineering and administrative controls help prevent a release of hydrochloric acid. - Sealess magnetic drive transfer pump - Storage tank designed to API 620 specifications with rubber interior coating - Written process instructions for using hydrochloric acid - Diking around the storage tank - Storage tank equipped with conservation vent - Storage tank high level alarm interlocked with pump flow switch. - Loading/unloading vapor return system The following engineering and administrative controls help prevent a release of formaldehyde. - Storage tank designed to API 620 specifications - Storage tank high level alarm - Diking around storage tank - Loading/unloading vapor return system - Written process instructions for using formaldehyde (e) 5-YEAR ACCIDENT HISTORY There have been no incidents at the Mobile Plant that meet the criteria for reporting in the five-year accident history. (f) EMERGENCY RESPONSE PROGRAM The Cytec Mobile Plant maintains emergency procedures that are designed with the primary purpose of protecting, to the greatest extent possible, the employees of the plant and the surrounding community. The procedures are designed to be implemented in case of fire, explo sion, chemical release which may arise as a result of our own operations, adjacent operations or the forces of nature. These procedures are set up to be implemented in two primary areas; 1.) In plant and 2.) in conjunction with the community. The in plant portion of the emergency response plan provides for employee notification of an emergency through an alarm system and in plant response with a trained emergency response team. The in plant emergency response protocols also provide for communications, notifications, procedures for emergency shut down, and mitigation. The in plant system is tested on a frequency ranging from weekly, for the alarm and communications system, to bi-annually for in-plant musters and drills. In addition to the in plant portion of the emergency response plan, the Mobile Plant also maintains an active community based emergency response program. This is done through monthly participation in the Mobile County LEPC as well as with the Mobile County Emergen cy Management Agency which coordinates mutual aid for the entire Mobile area chemical manufacturing community. Participation is achieved through planning meetings, public forums, bi-annual countywide emergency drills. The Cytec Plant also interfaces frequently with community based emergency response groups such as the fire department and local hazardous materials response team. Plant tours and readiness evaluations for these organizations are conducted on an annual basis. (g) PLANNED CHANGES TO IMPROVE SAFETY CYTEC Industries is constantly striving to upgrade its processes, control technology, employee training, inspection, repair and maintenance of process equipment in order to improve safety. We are also executing a well-organized plan to ensure minimum possible negative impact from Y2K. Specific capital improvements currently planned that will directly improve safety in the plant include: -Fully automated digital batch process control -Centralized process control area -New infrastructure to include modernized process cooling and heating capabilities -Digitized Material Safety Data Sheet System |