Zeeland Chemicals, Inc. - Executive Summary |
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ZEELAND CHEMICALS INC. ZEELAND, MI RISK MANAGEMENT PLAN EXECUTIVE SUMMARY INTRODUCTION Section 112(r) of the Clean Air Act establishes a Risk Management Program (RMP) to address the prevention of accidental chemical releases that can affect public health and the environment. The program covers industrial facilities having more than a threshold quantity of certain specified hazardous or flammable chemicals. The program focuses on chemical release prevention, detection, and accident response, and requires each facility to develop and implement a site-specific risk management plan including a hazards assessment, an accident prevention program and an emergency response plan. The program requires facilities to review worst case release scenarios no matter how unlikely those scenarios may be, and identify ways to minimize impacts from such releases. The Zeeland Chemicals, Inc. facility currently has two processes covered under this program. The covered processes are as follows: 7 On-s ite storage and usage of methyl chloride, which is a primary raw material in the manufacture of certain chlorinated quaternary ammonium compounds. 7 On-site storage and usage of ethylene, a primary raw material in the manufacture of a co-polymer product which has final application in photographic film. Zeeland Chemicals is committed to minimizing the risk of adverse impacts from its operations, and our commitment to responsible operations is built directly into our business objectives. This commitment is manifested further in our use of sound operating and maintenance practices, use of safety-conscious designs as well as extensive employee training. In addition, the performance of periodic safety audits and incident investigations are designed to review and minimize risks to employees, the environment, and the community. Zeeland Chemicals continually strives to be an industry leader in environmental stewardship. We continuously improve our practices in light of advances in technol ogy and new understandings in safety, health and environmental science. We make consistent, measurable progress in implementing this commitment throughout our operations. Our focus on continuous improvement in the areas of safety, health, and environmental affairs is also demonstrated by our commitment to the Chemical Manufacturers Association's Responsible Care initiative. Zeeland Chemicals has voluntarily adopted Responsible Care as its environmental, health and safety code of ethics. We measure our success by our record of improvement in safety performance, reductions in waste and emissions, and increased involvement with the community. COMPANY HISTORY In 1935, a company named Chemical Specialties, Inc. was formed to manufacture the bulk active sedative Carbromal for the US market. This company operated at the Centennial Avenue location where Zeeland Chemicals, Inc. has now operated. Chemical Specialties, Inc., a privately held company, owned and operated the plant from 193 5 to 1947. Miles Laboratories, Inc. owned and operated a unit at the same location from 1947 to 1977. Hexcel Corporation owned and operated a division at the same location from 1977 to 1992. Zeeland Chemicals, Inc., a subsidiary of Cambrex Corporation, has owned and operated the manufacturing plant since 1992 and provides the pharmaceutical and specialty chemical industries with the highest quality active ingredients, intermediates, chiral synthons, resolving agents, and services. Our facility is registered with the United States Food and Drug Administration (FDA) and we maintain systems for full compliance with the US FDA's Good Manufacturing Practices (GMP) guidelines. Today, Zeeland Chemicals sells approximately half of its products to customers for use as active ingredients or as intermediates and auxiliaries that are used to produce pharmaceutical products, such as antibiotics, cough suppressants, antifungal drugs, analgesics and protease inhibitors for the treatment of HIV. The specialty chemicals produced by Zeeland Chemicals are used in a variety of consumer products, including personal care products such as mouthwash, photocopier chemicals, automotive brake components and photographic film. RESPONSIBLE CARE Responsible Care is a cornerstone of Zeeland Chemicals' environmental, health and safety (EH&S) management systems. It is a chemical industry initiative through which companies commit to a continuous effort to improve their responsible management of chemicals. The program began in Canada in the late 1980s and has since spread across the globe. It has rapidly become the single most important performance improvement program within the chemical industry. In adopting Responsible Care, Zeeland Chemicals has agreed to conduct its business according to the following principles: 7 To recognize and respond to community concerns about chemicals and our operations. 7 To develop and produce chemicals that can be manufactured, transported and disposed of safely 7 To make health, safety and environmental considerations a priority in our planning for all existing and new products and processes. 7 To report promptly to officials, employees, customers and the public, information on chemical related health or environmental hazards and to recommend proactive measures. 7 To counsel customers on the use, transportation and disposal of chemical products. 7 To operate our plants and facilities in a manner that protects the environment, health and safety of our employees and the public. 7 To extend knowledge by conducting or supporting research on the health, safety and environmental effects of our products, processes and waste material. 7 To work with others to resolve problems created by past handling and disposal of hazardous substances. 7 To participate with the government and others in creating responsible laws, regulations and standards to safeguard the community, workplace, and environment. 7 To promote the principles and practices of Responsible Care by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of chemicals. While these principles give shape to Responsible Care, they require supporting action. All Responsible Care signatories agree to enact six codes of management practice. Zeeland Chemicals is proud of its record of accomplishment in this regard by having implemented all six codes. Community Awareness and Emergency Response Code (CAER): Zeeland Chemicals was instrumental in the establishment of a local CAER group formed by Zeeland area businesses, public agencies, hospitals and emergency response agencies. The facility continues to maintain an open dialogue with local first responders and has regularly hosted site visits. Zeeland Chemicals recently hosted a hazardous materials emergency drill at its site, which included its own Emergency Response Team, as well as local hospital, fire, police, ambulance and Red Cross personnel. Process Safety Code: Zeeland Chemicals has invested in process safety by acquiring the latest state-of-the-art computer software tools for conducting process safety reviews. In addition, extensive training of its personnel on this software and Process Hazard Analysis (PHA) methodologies has laid the foundation for continued improvement in its safety performance. Employee Health and Safety Code: Our overall injury rates are consistently well below the average rates for similar sized companies in the chemical industry. In 1999, Zeeland Chemicals employees set a new site safety record after working over 2 million hours without a lost-time injury. Due to the active involvement of employees at all levels, the company has had only one lost-time injury in the past seven years. Pollution Prevention Code: Zeeland Chemicals maintains a system to establish process specific and facility-wide waste reduction and pollution prevention goals and to track their progress. Our successes achieved through employee dri ven teams include significant increases in the amount of recycled by-products and reductions in the amounts of waste requiring off-site disposal. Distribution Code: We maintain a carrier and distribution facility qualification and selection program to minimize risks from the handling and shipping of our products. In fact, Zeeland Chemicals expanded our program to include our contract warehouses. Product Stewardship Code: Zeeland Chemicals places strong emphasis on proper handling of our products throughout the organization. We continue to place our Sales and Marketing organizations as the focal point for customer contact on safety information, allowing them to focus internal resources to best assist customers. FIVE YEAR ACCIDENTAL RELEASE HISTORY Zeeland Chemicals has worked hard to ensure that our products and manufacturing operations meet or exceed industry standards of excellence for protecting both the community and the environment. As a socially responsible company, we ha ve set aggressive goals to continue improving our EH&S performance into the next decade. It is through these efforts that our initiatives have helped us protect and enhance health and safety -- for our employees, neighbors and the public. As a result, we are proud of our record of accomplishment in not having had an accidental off-site release of any of the 112(r) regulated substances within the last five years. REGULATED SUBSTANCES As stated previously, the Zeeland Chemicals facility has two process covered under the 112(r) program. The first process utilizes ethylene as a raw material in the production of a copolymer and the second process utilizes methyl chloride that is used as primary raw material in the manufacture of chlorinated quaternary ammonium compounds. Ethylene is being used in the manufacture of an ethylene / maleic anhydride (EMA) co-polymer product that is used to make photographic film. The ethylene is stored under pressure in two (2) transport tube trailers, e ach of which is capable of holding 14,000 pounds of ethylene. The ethylene is connected directly from the transport trailer to the manufacturing operation through a piping manifold located in the EMA facility. Methyl chloride is primarily used in the manufacture of two chlorinated quaternary ammonium compounds: Phenyltrimethylammonium Chloride (PTMAC) and Methyltributylammonium Chloride (MTBAC). The methyl chloride is stored in a bulk storage tank with a maximum capacity of 41,540 pounds. The methyl chloride is directly connected to the production operations through a piping manifold. ACCIDENT PREVENTION PROGRAM For the last several years, Zeeland Chemicals has embraced the use of Hazard and Operability (HAZOP) and "What-If" analyses in support of our periodic safety reviews of our chemical processing operations. As part of our compliance effort with OSHA's Process Safety Management (PSM) Standard (29 CFR 1910.119) and Michigan's Department of Labor (R325.18302) regulations, we have completed detailed reviews of our critical plant operations in order to assess their inherent safety readiness. Similar to 112(r), these programs are specifically aimed at minimizing and/or eliminating the consequences of catastrophic releases. This is done by stating our policies and procedures for the management of process hazards in design, construction, start-up, operation, inspection, maintenance, employee training, and emergency response. Key to the success of these programs is the active involvement and participation of our employees in the completion of the process hazard analyses. Our commitment to the use of the latest process hazard analysis techniques, detailed and accurate procedures and regular employee training, ensures that each critical safety component of our chemical processing operations is reviewed in detail. EMERGENCY RESPONSE PROGRAM Zeeland Chemicals is committed to conducting operations at the Zeeland facility in a safe and environmentally responsibl e manner. This policy is implemented by active security and environmental, health and safety programs, well-designed and maintained facilities, trained employees and planning for emergency incidents. Extensive precautionary measures have been taken to reduce the risk of the occurrence of significant accidents or large-scale emergencies at the facility. If such an event occurs, these programs are designed to effectively respond to the incident and minimize potential impacts. Zeeland Chemicals' emergency preparedness program consists of an integrated emergency response plan and procedures. The plan has been designed for use by managers and emergency responders to assure that timely and proper emergency planning is carried out and to document that the necessary resources are available in the event of an emergency. The associated emergency response procedures have been developed to assist plant employees, members of the Zeeland Chemicals Emergency Response Team (the ERT) and managers in responding to an emergency to protect employees, the general public, and the environment. These procedures ensure that proper notification to state, federal and local authorities is made in a timely manner. Of equal importance is the amount of time and resources Zeeland Chemicals has invested in its on-site Emergency Response Team. At the time of writing, 35 plant employees are ERT members and all receive extensive, ongoing training. The team regularly conducts drills to ensure that their skills remain sharp and to maintain a high level of confidence in their ability to execute the Company's emergency response plan. Zeeland Chemicals' ERT personnel played a pivotal role in an October 1998 hazardous materials drill conducted in conjunction with local emergency response, hospital, ambulance and Red Cross personnel. Another similar drill is planned for mid-September of 1999. Zeeland Chemicals believes strongly that proper attention to these fundamental response concepts can mit igate any emergency that may develop at the facility. In the unlikely event of an accidental release, Zeeland Chemicals is well prepared to manage such an incident and is confident that protecting employees, community residents, the environment, and plant facilities from personal injury or property damage will receive priority attention. RELEASE SCENARIOS In accordance with guidance provided by the USEPA for determining the worst case scenario for the two regulated substances, ethylene and methyl chloride, Zeeland Chemicals must assume that the entire contents of the largest storage vessel will be released. While this is considered as extremely unlikely, even by the USEPA, the rule does not allow facilities to take into account active mitigation systems and safe work practices that could prevent or limit the entire contents from releasing. It is intended to ensure that no potential risks to public health are overlooked. As a result, the mathematical models used to analyze the wor st-case release scenario as defined in the rule will tend to overestimate the distance and area that would be impacted by an accidental release. It should be noted, however, that the distance to an endpoint estimated under worst-case conditions should not be considered a "public danger zone." In addition to the worst case release scenario, USEPA also requires the identification and analysis of one alternate release scenario for each covered chemical, in our case ethylene and methyl chloride. Zeeland Chemicals has appropriately used information from its process hazard analysis in selecting an alternate release scenario for each regulated substance. Zeeland Chemicals continues to utilize specific systems (e.g., monitoring, detection, control, pressure relief, alarms, and active mitigation) in the design and operation of its processes that will likely limit a release or prevent a failure from occurring. Hazard assessments and release scenarios for a hazardous substance are described in USEPA guideance documents. Under the worst case release scenario that must be considered, the entire contents of the largest single vessel is released in 10 minutes. For flammable gases such as ethylene, this release would result in a vapor cloud that is assumed to ignite. For hazardous substances, such as methyl chloride, this release would result in evaporation of the material that will then be dispersed. Hazardous substances have endpoints established by USEPA. The distance to the endpoint must be calculated and compared to the plant layout to determine whether there are off-site impacts caused by the release. Ethylene Worst Case Scenario For flammable substances, such as ethylene, the endpoint established by the USEPA for the consequence analysis is an overpressure of 1 pound per square inch. This endpoint is considered the threshold for potential serious injury to people as a result of property damage caused by the ethylene igniting. Consistent with USEPA guidance and the mitigating effects of the storage building enclosure, the estimated distance to the overpressure endpoint from a worst case release of ethylene is 183 yards. Even under this worst case scenario there are no residences or sensitive off-site receptors such as schools, hospitals or nursing homes located within the distance noted. Ethylene Alternate Release Scenario In the alternate release scenario it is assumed that a 1/8 inch by one inch leak develops at a gasket in the supply line in the ethylene storage building. Through multiple levels of prevention and mitigation systems, such as flammable gas monitoring devices, alarms, remote control shutoff valves, ventilation systems, structural enclosures and trained on-site personnel, the leak is detected and safely stopped. No ignition occurs from the accidental release. No off-site impacts will occur. Methyl Chloride Worst Case Scenario For hazardous substances, such as methyl chloride, the endpoint established by the USEPA for t he consequence analysis is a concentration of 0.82 parts per million (ppm). The USEPA considers this endpoint as the threshold for potential serious injury to people as a result of a short-term exposure to the methyl chloride vapors. Using the USEPA guidance, and including, as set forth in the rule, consideration for the use of passive mitigation measures (containment by diking and evaporation control), the estimated distance to the endpoint from a worst case release of methyl chloride is 176 yards. Zeeland Chemicals has implemented a passive vapor suppression system, which minimizes the potential impact zone under the worst case scenario. Even under this worst case scenario there are no residences or sensitive off-site receptors such as schools, hospitals or nursing homes located within 176 yards of the storage tank. Methyl Chloride Alternate Release Scenario In the alternate release scenario, it is assumed that a 1/4 inch diameter leak develops at a valve packing in the supply line near the methyl chloride storage tank. Using EPA guidance tables for modeling this release, the endpoint is 0.82 ppm and results in an impact distance of less than 176 yards. Through multiple levels of prevention and mitigation systems, such as monitoring devices, alarms, remote control valves, and trained on-site personnel, the leak would be detected and safely stopped. Under this alternate scenario, there are no residences or sensitive off-site receptors such as schools, hospitals or nursing homes located within the distance noted. CONCLUSION Zeeland Chemicals believes strongly that all safety and environmental incidents are preventable. We will continue to assess the environmental impact of each of our processes and propose to design, build, operate and maintain all of our operations so they remain safe and acceptable to local communities and are protective of the environment. We will be prepared for emergencies and will provide leadership to assist our local first respo nders to assist with their emergency preparedness. We will promote open discussion with our neighbors about the products that we make, use and transport as well as the impacts of our activities on their safety, health and the environment. We will continue to adhere to the highest standards for the safe operation of our facility and the protection of our environment, our employees, our customers and our neighbors in Zeeland, Michigan. |