Morton International, Inc. - Executive Summary |
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Accident Release Prevention Program and Emergency Response Policy It is the policy of the Morton International, Inc's. Taylors, South Carolina facility to implement the requirements of the Risk Management Program (RMP) herein described in accordance with the USEPA regulation 40 CFR Part 68, and the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the potential of a release of hazardous material to occur and if a release occurs, to minimize the impact to Morton employees, the public, the community, and the environment. This objective is met by continuing to use general good operating procedures, providing the appropriate training to empolyees, and coordinating response activities, as necessary, with the local emergency response providers. Morton's management is committed to providing the resources necessary to implement this policy. Facility Description Morton International, Inc. is located at 1116 Tanner Road in Taylor s, South Carolina. The facility operates primarily as a manufacturer of specialty chemicals. Three substances, acrylonitrile, ammonia, and vinyl acetate are utilized at the facility in sufficient quantities to be subject to the RMP requirements. Other chemicals, some of which are regulated as being potentially harmful are also used at the facility. The compounds, including those regulated by RMP, are handled using best management practices. Consequence Analysis An off-site consequence analysis is required to help understand the potential off-site impacts of hypothetical accidental releases. All facilities must prepare a worst-case release scenario analysis. For Program 3 processes, facilities must evaluate and document one worst-case release scenario representing all regulated toxic substance in covered processes; additional worst-case release scenarios if different public receptors are affected by a release from another onsite covered process; and at least one alternative r elease scenario to represent each regulated toxic substances in covered processes. The Risk Management Program (RMP) rule defines key terms and outlines the steps to conducting an off-site consequence analysis, the specific parameters that must be used and the requirements for reviewing, updating and documenting off-site consequence results. Morton performed offsite consequence analyses for acrylonitrile, aqueous ammonia, and vinyl acetate to estimate the potential for an accidental release to affect the public or the environment. The offsite consequence analysis evaluates a "worst-case release scenario" and an "alternative release scenario". Morton feels that it is highly unlikely that a worst-case scenario will ever occur. An alternative release scenario represents a release that (1) might occur at a facility like Morton and (2) would result in the greatest potential offsite consequences if the release occurred. The main objective of performing the offsite consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The endpoint distance is applied to an area map to see if the distance from the tank impacts a public receptor. A public receptor includes "offsite residences, institutions, industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time"A road is not a public receptor. EPA defines the toxic endpoint for all three substances as the ERPG-2 value. The ERPG-2 value, approved by the American Industrial Hygiene Association, represents the maximum airborne concentration below which it is believed nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair their abilities to take protective action. The toxic endpoint for acrylonitrile is 35 ppm (0.076 mg/L); ammonia is 200 ppm ( 0.14 mg/L); and vinyl acetate is 75ppm (0.26 mg/L). The analysis follows procedures presented in the OCA guidance document. For aqueous ammonia, look-up tables from the Guidance for Wastewater Treatment Plants was used to determine the distance to the toxic endpoint. However, for acrylonitrile and vinyl acetate, instead of applying the look-up tables, the distances to the toxic endpoint were computed with the SLAB (June 1990) air dispersion model. Five Year Accident History Morton has not had any release of ammonia, acrylonitrile, or vinyl acetate from the Taylors facility that has met the reportable release definition contained in the USEPA RMP rule. Prevention Program The Taylors, SC facility is subject to the OSHA PSM regulation. Thus, Program 3 requirements of RMP apply. Morton maintains and implements a PSM program in accordance with OSHA 29 CFR 1910. Emergency Response Morton has established procedures for emergency response and notification for accidental relea ses of any hazardous substances. Morton has developed a plan which establishes different procedures for different accidental releases based on the potential threat to human health and the environment. Morton will communicate any accidental releases of hazardous substances with the potential to cause offsite impacts with the surrounding community. The methods used to establish this communication will be determined on a case by case basis as warranted. |