Zeneca Specialties Mt. Pleasant Site - Executive Summary |
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Introduction The Zeneca Specialties Mt. Pleasant Site has been manufacturing chemicals safely for over 40 years. The site originated as Victor Chemical in 1957. The Site became part of Zeneca Specialties in 1993. The Mt. Pleasant Site has over 180 full-time employees. The chemicals manufactured at the Mt. Pleasant Site are used by industries to make products familiar to our daily lives - copier machines, paints, plastics, acrylics, rubber hoses, make-up, and swimming pools. The Site consists of over 1,000 acres with approximately 100 acres used as manufacturing space. Understanding and managing risks is a fundamental part of how we operate. Zeneca is committed to continuously improve its safety, health, and environmental performance. We take safety very seriously and we have an excellent program in place to prevent accidental releases of all the chemicals we handle. We use a variety of safety and operating procedures to prevent releases from occurring. Our employees are co mmitted to working safely with all the chemicals we handle as evidenced by their having worked over 4 years (2.3 million hours) without a lost workday injury. (a) Accidental Release Prevention and Emergency Response Policies: The Mt. Pleasant Site has four chemicals that are covered by the RMP rule (bromine, chlorine, isoprene, and phosphorus trichloride). Each of these four chemicals are considered hazardous by the EPA. These chemicals are used as raw materials in our manufacturing processes. A review of our past safety performance shows that we have had no accidental chemical release in the past 10 years that has impacted the health and safety of the local community around our facility. It is our policy to meet all the laws and regulations relevant to our industry at the local, state, and federal levels. The properties that make these 4 chemicals valuable as building blocks for our manufacturing processes also make it necessary to observe certain safety precautions. These pre cautions include handling all chemicals to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community. Safety depends upon the manner in which we handle these chemicals combined with the safety devices inherent in the design of this facility combined with safe handling procedures that we use and the training of our personnel. If an accidental chemical release were to occur, Zeneca has a comprehensive emergency response program to respond to such a release. Our plant employees are trained as emergency responders and have both hazardous materials response and fire-fighting training. Our emergency response plan includes procedures for notification of the local fire/police authorities who are responsible for notification of the local community if necessary. (b) The Stationary Source and Regulated Substances Handled The four RMP covered substances are used as raw material s in our manufacturing processes; the chemicals are shown below along with the maximum inventories and process areas where the chemicals are stored and used. Chemical CAS# Process Area Maximum Inventory(pounds) Bromine 7726-95-6 Process B 145,000 Chlorine 7782-50-5 Process A 12,000 Isoprene 78-79-5 Process B 50,000 Phosphorus Trichloride 7719-12-2 Process A 431,000 The primary purpose of the Mt. Pleasant Site is to manufacture specialty chemicals. These chemicals are received by both railcar and truck. The unloading facilities have equipment that is used to unload the chemicals into vessels located in the manufacturing areas. Access to the Site is restricted to authorized facility employees, authorized management personnel, and authorized contractors. (c) Worst-Case Release Scenarios and the Alternative Release Scenarios Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario **Toxic Substance Worst-Case Scenario** The worst-case toxic substance release (scenario resulting in the greatest distance to an endpoint) involves failure of a bromine railcar containing 110,000 pounds. The bromine is spilled into a 320 square foot sump surrounding the railcar which mitigates the off-site impact of the release. The release would reach off-site endpoints and nearby public receptors, including the city of Mt. Pleasant. This event is extremely unlikely to occur. There have been no accidental releases of bromine at the Mt. Pleasant Site that have resulted in any off-site impact. **Flammable Substance Worst-Case Scenario** The worst-case flammable subs tance release (scenario resulting in the greatest distance to an endpoint) involves failure of the isoprene storage tank containing 50,000 pounds of isoprene. It is assumed that the entire contents of the tank are released as vapor which finds an ignition source and results in a vapor cloud explosion. There are no passive mitigation measures considered in this release scenario. Since the Mt. Pleasant Site is located in a relatively remote, unoccupied area, the flammable substance worst-case scenario would not affect anyone beyond our property line. This event is extremely unlikely to occur. There have been no accidental releases of isoprene at the Mt. Pleasant Site that have resulted in any off-site impact. **Bromine Alternative Release Scenario** The alternative release scenario for bromine involves failure of a 1-inch unloading hose at the railcar unloading facility. The release is stopped after 5 minutes. A total of 12,000 pounds of bromine is released with a release rate to outside air of 60 pounds per minute. The bromine is spilled into a 320 square foot sump surrounding the railcar which mitigates the off-site impact of the release. The process operators in the area are alerted to the release by bromine vapor sensor detectors in the railcar area that signal the operator at the process unit. This scenario was chosen because the RMP regulation requires (Title 40-Subpart B-Section 68.28) our facility to develop a scenario that will reach an off-site impact. This scenario has the potential to extend beyond the facility boundary. As evidenced by our past operating history, we have had no bromine accidental releases that have resulted in any off-site impact. **Chlorine Alternative Release Scenario** The alternative release scenario for chlorine involves failure of a 1-inch unloading hose on a 1-ton cylinder at the Process A unit. The release last for a total of 10 minutes. A total of 750 pounds of chlorine is released with a release rate 200 pounds per minute. This release scenario was taken from the EPA Risk Management Program Guidance for Wastewater Treatment Plants (October 1998). This release scenario would not affect anyone beyond our property line. As evidenced by our past operating history, we have had no chlorine accidental releases that have resulted in any off-site impact. **Phosphorus Trichloride Alternative Release Scenario** The alternative release scenario for phosphorus trichloride involves failure of an unloading hose connected to the railcar while unloading (1-inch hole in hose). The release last for a total of 5 minutes. A total of 6,900 pounds of phosphorus trichloride is released with a release rate to outside air of 200 pounds per minute. This scenario was chosen because the RMP regulation requires (Title 40-Subpart B-Section 68.28) our facility to develop a scenario that will reach an off-site impact. This scenario has the potential to extend beyond the facility boundary. Although, we have both pas sive and active mitigation systems in place to prevent accidental releases of phosphorus trichloride, we did not consider these because of the requirement to develop an alternative release that has potential off-site impact. As evidenced by our past operating history, we have had no phosphorus trichloride accidental releases that have resulted in any off-site impact. **Isoprene Alternative Release Scenario** The alternative release scenario for isoprene involves failure of a 1.5" unloading hose connected to a tank truck while unloading. The release last for a total of 5 minutes. A total of 10,000 pounds of isoprene is released with a release rate of 2,000 pounds per minute. As in the worst-case scenario, the alternative release scenario would not affect anyone beyond our property line. As evidenced by our past operating history, we have had no isoprene accidental releases that have resulted in any off-site impact. (d) The General Accidental Release Prevention Program and Ch emical-Specific Prevention Steps The Mt. Pleasant Site manufacturing facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. The Mt. Pleasant site has an existing accidental release prevention program already in place that was developed for the OSHA Process Safety Management regulation. The details of the prevention program are summarized below: **Process Safety Information** Written process safety information has been compiled for both of the covered processes at the Mt. Pleasant Site. This information enables Zeneca management and the employees involved in operating the process to identify and understand the hazards posed by those production facilities involving highly hazardous chemicals. This information is kept current by the Safety, Health, and Environmental Department. The data includes information pertaining to the hazards of the regulated substances, information pertaining to the technology of the process, and information pertaining to the equipment in the process. The information is available to all employees, 24 hours/day. **Process Hazards Analysis** Process hazard analysis (PHA) have been completed on both of the RMP covered processes. These PHAs were completed as part of the OSHA Process Safety Management program. The methods used are from the Zeneca, Process SHE Guide No. 13, Risk Assessment Methodology for Equipment, Plant and Projects and Processes. The PHA methods used include checklists, what if, and HAZOP. Findings that result from the PHAs are promptly addressed. The PHA teams are made up of a cross-section of plant departments and include technicians from both the Production and Maintenance Departments. Refer to Section 7 of the RMP submission for the Mt. Pleasant Site for specific details concerning the PHAs. Any significant process changes include a PHA prior to implementation and startup. Future plans include revalidating the initial PHAs for both covered processes. **Operating Procedures and Training" The Mt. Pleasant Site has developed and implemented written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information. These operating procedures are reviewed as often as necessary to assure that they reflect current operating practice, including those that result from changes in process chemicals, technology, and equipment, and changes to facilities. Production management certifies annually that these operating procedures are current and accurate. Production employees involved in operating the covered processes receive training to assure that the employee understands and adheres to the current operating procedures of the processes. Management in consultation with the employees involved in operating the process, determine the appropriate frequency of refresher training. **Mechanical Integrity** The Mt. Pleasant Site has established written procedures to maintain the on-going integrity of process equipment. The mechanical integrity program includes inspection and testing procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment are consistent with applicable manufacturers' recommendations, Zeneca Group Engineering Procedures, and good engineering practices, and more frequently if determined to be necessary by prior operating experience, and equipment history review. Any deficiencies found during the inspection and testing are promptly corrected. The mechanical integrity program includes training each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner. **Management of Change and Pre-Startup Review** The Mt. Pleasant Site h as established and implemented a written procedure to manage changes to process chemicals, technology, equipment, and procedures; and changes to structures and facilities that affect a covered process. The procedure includes authorization requirements by site management as well as steps taken to assure that employees whose job tasks will be affected by a change in the process are informed of, and trained in, the change prior to start-up of the process or affected part of the process. Site management performs pre-startup safety reviews for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. **Compliance Audits** Site management has completed a recent compliance audit on the PSM prevention program. This audit certified that the site is in compliance with the PSM prevention program elements. The next PSM/RMP compliance audit is scheduled for 2001 to comply with the OSHA and EPA audit requiremen ts. Findings from both previous audits have been addressed. **Incident Investigation** The Mt. Pleasant Site investigates each incident which resulted in, or could reasonably have resulted in a catastrophic release of any highly hazardous chemical in the workplace. An incident investigation team is established immediately following an incident. The investigation team consist of employees involved in the process and includes a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. A report is prepared at the conclusion of the investigation and an established system is in place to promptly address and resolve the incident report findings and recommendations. **Employee Participation** The Mt. Pleasant Site management believes that broad and active employee participation in all elements of the PSM Program will enhance the overall program. A cross section of Mt. Pleasant Site employees from all levels of the organization are involved in the design and implementation of the RMP and PSM Programs. **Hot Work Permit** The Mt. Pleasant Site has a comprehensive hot work permit program to ensure that the proper preparations have been taken to prevent fire or explosions in the work place. The permit documents that applicable fire prevention and protection requirements have been implemented prior to beginning the hot work operations. Both Zeneca and contractor employees receive annual refresher training on hot work permits. **Contractors** Zeneca is committed to ensuring that all of its employees, as well as, all contract employees are provided with a safe place to work. Zeneca expects that all contractors and their employees will support this effort by working within recognized safety standards and actively complying with the Mt. Pleasant Site Safety Manual. Contractors receive training and understand that safe work practices are a condit ion of employment. Prior to starting work on the Mt. Pleasant Site, each qualified contractor employee receives a 5-hour safety orientation. The contractor employees must successfully pass a written safety proficiency exam before he/she can begin work on the Mt. Pleasant Site. **Chemical Specific Prevention Steps** The above summary of the prevention program applies to all four of the RMP covered substances at the Mt. Pleasant Site (bromine, chlorine, phosphorus trichloride, and isoprene). In addition, there are specific prevention steps for these substances; a summary for each is included below: - Bromine The bromine handling system has been designed to prevent accidental releases and the system is in place to respond quickly in case of a release. The bromine is delivered to the site by rail. The bromine railcar is stationed near the process area. The railcar is connected to the unloading facility whenever Process B is operating. The railcar has a sump passive mitigation cont ainment system that is large enough to contain a full release of the railcar. The sump also includes a building to prevent rain from entering the containment system. Bromine vapor sensors are stationed near the railcar to alert the process operator in case of a release. The unloading system is made of the proper materials of construction for bromine (glass lined tanks, teflon and kynar lined pipe and valves). The unloading process is viewed remotely by the process operator in the Process B control room. The operator has the capabilities to stop the unloading process remotely if a problem develops. The bromine handling system includes a weigh tank from which the process technician charges bromine into the Process B reactor. All of the bromine associated equipment is included in the Mt. Pleasant Site's mechanical integrity program; preventive maintenance (PM) and testing is completed on a routine basis. Any deficiencies found during the PM and testing is corrected promptly by pr oduction management. - Chlorine The chlorine handling system has been designed to meet the requirements set by the Chlorine Institute. The chlorine is delivered to the site in 1-ton cylinders by truck. The cylinders are stored away from the process area. The cylinders are taken one at a time to the Process A area and connected to the unloading system. Only one cylinder at a time is in the process area. The unloading system is made of the proper materials of construction for chlorine. All of the chlorine associated equipment is included in the Mt. Pleasant Site's mechanical integrity program; preventive maintenance (PM) and testing is completed on a routine basis. Any deficiencies found during the PM and testing is corrected promptly by production management. - Phosphorus Trichloride The phosphorus trichloride handling system has been designed to prevent accidental releases and the system is in place to respond quickly in case of a release. Phosphorus trichloride is delivere d to the site by rail. The phosphorus trichloride railcar is stationed near the process area. A process technician is stationed at the unloading facility when the railcar is unloaded. The railcar has a sump passive mitigation containment system that is large enough to contain a full accidental release of the railcar. The railcar is unloaded into a storage tank which has a dike containment system. The process technician has the ability to remotely stop the flow of phosphorus trichloride in case of a release. All of the phosphorus trichloride associated equipment is included in the Mt. Pleasant Site's mechanical integrity program; preventive maintenance (PM) and testing is completed on a routine basis. Any deficiencies found during the PM and testing is corrected promptly by production management. - Isoprene The isoprene handling system has been designed to prevent accidental releases. Isoprene is delivered to the site by tank truck. A process technician is stationed at the unl oading facility when the tank truck is unloaded. The tank truck is unloaded into a storage tank; the tank has a dike passive mitigation containment system that is large enough to contain a full accidental release of the storage tank. The process technician has the ability to remotely stop the flow of isoprene in case of a release. All of the isoprene associated equipment is included in the Mt. Pleasant Site's mechanical integrity program; preventive maintenance (PM) and testing is completed on a routine basis. Any deficiencies found during the PM and testing is corrected promptly by production management. (e) The Five Year Accident History There were no reportable accidents in the last five years that meet the criteria of the EPA's RMP regulation. The Mt. Pleasant Site has a comprehensive incident investigation program whereby all incidents, including minor events, are investigated by members of management. While we have had minor incidents involving these chemicals in the past, they have all been contained in the immediate area around the manufacturing process and have not resulted in off-site releases. Since the Mt. Pleasant Site is located in a relatively remote, unoccupied area, it is extremely unlikely that any incident involving the four RMP covered substances could result in an off-site release. The closest public receptor is in excess of 0.5 miles from the manufacturing area where the four covered substances are stored and processed. (f) The Emergency Response Program We have a very comprehensive emergency response system in place. We take safety very seriously and we have an excellent program in place to prevent accidental releases of all the chemicals we handle. In the event that an emergency does occur, our employees have received extensive safety, health, and environmental training and they continue to train on a monthly basis. Our employees are committed to working safely with all the chemicals we handle as evidenced by their working over 4 years without a lost workday injury. Our emergency response team is made up of plant employees. Our employees are trained as emergency responders and have both hazardous materials response and fire-fighting training. Our employees who participate in the emergency response have received special training on the four RMP covered substances. Our emergency response plan includes procedures for notification of the local fire/police authorities who are responsible for notification of the local community if necessary. If an accidental chemical release did occur that impacted the local community, local citizens would receive information/directions from the Mt. Pleasant City and Maury County emergency response agencies as to the steps you should take to protect yourself. (g) Planned Changes to Improve Safety Over the past 10 years, Zeneca has put over $50 million of capital investment into the Mt. Pleasant Site. A significant portion of this investment has involved upgrading the existin g manufacturing facilities and improving process safety. Our annual capital budget continues to include millions of dollars of capital investment. Improvements that have recently been completed or are currently underway include the following: * Replacement of the PCl3 storage tank * Installation of a containment sump system and building around the bromine railcar * Relocation of the phosphorus trichloride railcar and installation of a containment sump system around the railcar * Mechanical integrity program including inspection/testing of mechanical equipment and instrument/controls for the covered RMP and PSM substances * Extensive painting program in 1999 for the manufacturing area involving the four RMP covered substances |