Johnson Matthey Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At the Johnson Matthey facility in West Deptford, NJ, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation. * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases. * An overview of our accidental release prevention programs. * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule. * An overview of planned imp rovements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public and the environment. STATIONARY SOURCE AND REGULATED SUBSTANCES The Johnson Matthey facility manufactures chemical products containing platinum group metals. These products are commonly referred to as homogeneous and heterogeneous catalysts and other specialty chemical compounds. Spent materials containing precious metals are also processed and refined to the pure element using a variety of chemicals and processing operations. Our processes use the following chemical that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics: Chlorine Chlorine is purchased in 1 ton cylinders as a pressurized liquid. Although storage capacity is a maximum of 8,000 pounds, our normal inventory is maintained at 4,000 to 6,000 pounds. The liquid chlorine is vaporized to a gas, which is distributed to the manufacturing area and used in our processes for dissolution of precious metals. Our accidental release prevention programs, in effect since 1988, and our contingency planning efforts allow us to effectively manage the hazards that are posed to our employees, the public, and the environment by our use of this chemical. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS The RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario(s) - Regulated Toxic Chemicals The worst-case release scenario assumes that the entire contents of a 1 ton cylinder (2,000 lb.) are released within ten minutes. The chlorine would be released as a gas. Since our facility is within an indu strial and residential area, the toxic cloud, as determined by EPA's OCA guidance document, would reach offsite endpoints and public receptors. The chlorine cylinders are stored and used within an enclosed building. However, passive mitigation has not been assumed in this scenario since in transferring from the delivery vehicle to within the building there exists a remote possibility a release could occur. Alternative Release Scenario(s) - Regulated Toxic Chemicals The alternative release scenario assumes that a break occurs in the piping system outside the building. This type of piping failure could cause a release of approximately 330 pounds. This would result in a plume of 0.1 miles (based on OCA guidance). This would have minimum offsite travel in one portion of the property but would not impact any public receptors. Safeguards within our system to eliminate or minimize such a release include: * Excess flow-sensing devices with automatic shutdown. * Chlorine monitors with automatic shutdown. * Remotely operated shutoff valves. * Preventative maintenance programs including pipe thickness testing. * Hazards analysis. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. A management system has been prepared which includes overseeing the implementation of the elements of our risk management program. As part of our system, roles and responsibilities have been assigned to facility personnel. Our system also addresses each of the key features of a successful prevention program including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: * Building enclosure for chlorine cylinder storage and vaporizing process. * Monitoring devices to activate a ventilation system in the building with exhaust air venting to a scrubbing system. * Monitoring devices in cylinder storage area and manufacturing process areas with automatic shutdown of the chlorine system. * Excess flow detection with automatic shutdown of the system. * Remotely operated shutoff valves. * Preventive maintenance programs for process equipment and piping. These individual elements of our prevention program work together to prevent accidental chemical releases. Johnson Matthey and its employees are committed to the standard that these management systems set and we have specific accountabilities and controls to ensure that we are meeting our standards for accident prevention . FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: There has only been one release, which resulted in minor injuries to an employee. There was no other on site or environmental impact and no offsite impact. In July 1995, while attempting to start up a system after a maintenance shutdown, a leak of approximately one-half pound occurred. This resulted from a pipe fitting being improperly tightened. The employee inhaled a small quantity of material. He did not require hospitalization but was restricted from the work area for several days. A formal incident investigation was conducted to identify and correct the root causes of the event. EMERGENCY RESPONSE PROGRAM We have developed and maintain a comprehensive emergency response plan. Our plan, written to meet the New Jersey Toxic Catastrophe Prevention Act, consolidates all of the various federal, state, and local regulatory requirements. Our site personnel are trained on the plan's contents and it is coordinated with the community emergency response plan. In addition, we maintain an emergency response team on site. The team is trained and properly equipped to respond to hazardous material releases and specifically chlorine. The team trains on a monthly basis, which includes a minimum of two simulated drills per year in conjunction with local fire, rescue and emergency management agencies. Our overall program provides the essential planning and training for effectively protecting workers, the public and the environment during emergency situations. PLANNED CHANGES TO IMPROVE SAFETY The chlorine safety systems have evolved to the current level over the past eleven years that the New Jersey accidental release program (TCPA) has been in effect. The most recent changes to the system involv ed the following: * Reduction of inventories to lowest possible levels. * Installation of automatic cylinder shutoff valves upon activation of monitoring devices. A comprehensive audit of our system by NJDEP in February 1999 resulted in no new safety recommendations. |