Goldschmidt Chemical Corporation - Mapleton Plant - Executive Summary |
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INTRODUCTION: On August 31, 1999, the WITCO CORPORATION'S Oleochemicals portions of the Mapleton Plant and the WITCO CORPORATION'S Metal Alkyl portion of the business at the Mapleton facility were divided into separate ownership. The Oleochemicals portion of the Mapleton Plant site is now owned by Goldschmidt SKW Oleochemicals, LLC and operated as Goldschmidt Chemical Corporation. The Metal Organic portion is now owned and operated by CK Witco Corporation. This RMP document covers the portion of the Mapleton Plant owned by Goldschmidt SKW Oleochemicals, LLC. The previously submitted RMP Document I.D.# [1000 0014 7405] under Witco Corporation ownership covered both of these operations. For purposes of brevity, in this document the owner and operator of the Oleochemicals portion of the Mapleton Plant will be referred to as "Goldschmidt". Goldschmidt is committed to providing the processes, facilities, standards, resources, training, discipline, and work culture to ensure 1) A safe environment for all employees and for the communities in which we operate, 2) Safe, effective products for our customers, 3) Conservation of energy and natural resources, 4) Responsible Waste Management, and 5) Protection of shareholder assets. At Goldschmidt, we are committed to operating and maintaining all of our processes in a safe and responsible manner. The Mapleton facility property consists of 515 acres of land, while production facilities occupy approximately 45 of these acres. Approximately 275 employees operate this 24 hour per day, 7 day a week facility, which processes natural fats and oils into intermediates for consumer products and industrial type products. Our finished products are used in hundreds of consumer products, including shampoos, conditioners, skin lotions, sun screens, fabric softeners, and household cleaners, as well as in many industrial processes as lubricants, paper debonders, textile finishes, mining flotation reagents, asphalt emulsifiers, adhes ives, curing agents, biocides, and blowing agents. DISCUSSION: On May 20, 1999, the entire Mapleton Plant representing Witco Corporation joined with our neighboring facility al group lonza to present all Risk Management Plans to the Mapleton Community. There were about 20 members from our plants present, 10 Community Action Program (CAP) Committee members present, and about 10 members from the Mapleton Community. The plan was received well. All questions were answered. The event was covered by the news media with a small article that appeared in the local paper the next day. In our opinion, this event meets the Public Meeting requirement set forth in the new "Site Security and Fuels Regulatory Relief Act", Public Meetings and other Notifications Law, PL 106-40 [August 5, 1999]. This document provides a brief overview of our manufacturing processes that utilize those chemicals that fall under the EPA's RMP regulations. The Goldschmidt Mapleton production facilities fall under the Level 3 Processes. The Mapleton Facility uses four Toxic Chemicals that fall into this program. The Toxic Chemicals are: Acrylonitrile, Anhydrous Ammonia, Formaldehyde, and Methyl Chloride. The values shown in the following scenarios were obtained using computer based modeling with EPA's RMP-Comp,Ver.1.06. The community population numbers were obtained using Landview III, from the Census Bureau. There are many more complicated programs available that should be used for emergency planning but RMP-Comp can be used for the planning for this document. Worst Case Scenario / TOXIC: The Worst Case Scenario involves the potential release of 44,950 pounds of anhydrous ammonia in 10 minutes. This chemical is released onto concrete. This area is equipped with a deluge system and fire fighting equipment. Potential public receptors include the Village of Mapleton residents, Mapleton School employees and students, Mapleton Christian School employees and students, Hollis Park District em ployees and patrons, Kingston Mines residents, Commonwealth Edison Powerton employees, algroup Lonza employees, Caterpillar employees, MG Industries employees, CF Industries employees, Superior Consolidated Industries employees, and CK Witco Corporation employees. The estimated distance to the toxic end point (0.14mg/l) is 3.6 miles according to the EPA's RMP COMP air modeling program. Alternate Release Scenarios / TOXIC: The Alternate Release Scenario for Acrylonitrile involves the release of 1,000 pounds of acrylonitrile from the Adduct Reactor / Blow Tank due to a failure in the control logic for the valve in the acrylonitrile addition line. The Toxic end point (0.076 mg/l) according to RMP COMP is 0.2 mile. The release duration is 30 minutes. The Alternate Release Scenario for Anhydrous Ammonia is 88.1 pounds per minute leaking from a broken pipe on the ammonia transfer pump. The line leaks for 30 minutes until the Emergency Response Team arrives and establishes a water spray onto the pump. The toxic end point (0.14 mg/l) according to RMP COMP is 0.2 mile. The Alternate Release Scenario for Formaldehyde is a 3/8-inch line leaking at the transfer pump at the formaldehyde storage tank. The material leaks into a diked area for 30 minutes until the Emergency Response Team arrives, suits up, and stops the leak. The toxic end point (0.012 mg/l) according to RMP COMP is 0.1 mile. The Alternate Release Scenario for Methyl Chloride is due to an automatic valve opening due to a computer malfunction causing the release of 1,200 pounds of Methyl Chloride over a 30 minute period. The material leaks into a tank vent discharging onto the building roof. The toxic end point (0.82 mg/l) according to RMP COMP is 0.1 mile. General Accidental Release Prevention Program and Chemical Specific Prevention Steps: Goldschmidt complies with OSHA's PSM rule and EPA's RMP rule. We also participate in CMA's Responsible Care program. We take a systematic, proactive approach to p reventing accidental releases of hazardous chemicals. Our management system address each of the key features of successful prevention programs including: -7 Process Safety Information -7 Process Hazard Analysis -7 Training -7 Mechanical Integrity -7 Management of Change -7 Pre-Startup Reviews -7 Compliance Audits -7 Incident Investigations -7 Employee Participation -7 Hot Work Permits -7 Contractor Safety Goldschmidt has "Layers of Protection" to help ensure that an emergency situation with off-site implications will not arise and have put several layers of safety and environmental protection into place. This includes the following elements: 7 Employees are well trained and are our most important resource in operating our facility and in protecting our community. 7 Mechanical Integrity testing for major pieces of process equipment like metal fatigue and thickness testing. 7 Comprehensive Technical Hazard Reviews conducted at least every 5 years on processes using these RMP regulated chemicals and on design changes for production units before the changes are made. An excellent record keeping software program allows similar situations to be compared. 7 Distributed Control Systems are used throughout the plant. They are interconnected which allows control to be shifted to another control station in the event of a computer system failure until full capability is restored. 7 We have highly sensitive monitoring instrumentation available that will detect very low concentrations of these materials. 7 The key to minimizing the effect of an accidental release is to get the right people and equipment to the location quickly. This includes both on-site and off-site emergency responders. All well trained and experienced with our materials. 7 We have in-plant notification systems that can be used to summon our in-plant emergency responders. Working through the Peoria County LEPC and the County Sheriff's Department, we are able to summon necessary responders from the Timbe r-Hollis Volunteer Fire Department and the Pekin Area Fire Departments. The Emergency Notification system can also be used to notify local residents of the need to "Shelter-in-Place" when conditions warrant it. 7 We have an extensive Community Emergency Exercise history involving the above mentioned agencies. Our last Community Emergency Exercise occurred just last October 15, 1999. It involved an anhydrous ammonia leak from a storage tank. 7 Several years ago, the plant constructed a 100-year flood protection dike to protect the plant property from serious floods. Five Year Accident History: We keep accurate records for all accidental releases involving all chemicals from our facility. Goldschmidt Mapleton Plant believes there have been NO accidents or incidents according to the RMP Rule definition for releases or incidents involving covered chemicals during the past five years that has resulted in injuries, evacuations, sheltering-in-place, property damage, or environmental dam age off site. We are using this information to help us ensure that our emergency response plan and the community emergency response plan addresses all reasonable contingency cases. |