Cytec Kalamazoo, Michigan Plant - Executive Summary |
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DESCRIPTION OF THE CYTEC KALAMAZOO FACILITY (a) ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Cytec is a leader among chemical manufacturers in its safety, health and environmental programs. Our commitment to protect our employees and the communities that are home to our operations is an integral part of Cytec's way of doing business. Cytec has established safety, health, emergency response and environmental policies and standards to meet or exceed all regulatory requirements. As a member of the Chemical Manufacturers' Association (CMA), Cytec subscribes to the codes established for Responsible Care ?. (b) THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED Our facility has 3 processes that involve regulated substances. The Methylated Resins process makes products that are raw materials for the manufacture of coatings for the automotive and other industries; and, adhesives for rubber tire manufacturing. The regulated substance involved with this process is formaldehyde. The Polyamines process makes products that are used to manufacture water treatment chemicals for the paper, mining and food processing industry. The regulated substances involved with this process are epichlorohydrin and a flammable mixture of dimethylamine in water. The Quaternized PAM Emulsions process makes products that are used to separate sludge and solids from water in water recovery facilities before the water is returned to rivers and lakes. The regulated substances involved with this process are methyl chloride, formaldehyde, and a flammable mixture of dimethylamine in water. (c) WORST-CASE RELEASE SCENARIOS AND ALTERNATIVE RELEASE SCENARIOS The toxic worst-case scenario is the failure of a storage tank and the release of 220,000 pounds of methyl chloride. The effect of written operating procedures and a high level alarm that prevents the storage tank from being filled to more than 91% of its capacity was included in the evaluation of the possible con sequences. The evaporating methyl chloride could reach offsite endpoints and nearby public receptors. The flammables worst-case scenario is the failure of a storage tank and the release of 170,000 pounds of a flammable mixture (60% aqueous dimethylamine). The effect of written operating procedures and a high level alarm that prevents the storage tank from being filled to more than 93% of its capacity was included in the evaluation of the possible consequences. The overpressure from the ignition of the vapor could reach off-site endpoints and nearby public receptors. The alternative release scenario for epichlorohydrin is a leak in a transfer line during unloading and a release of 160,000 pounds of material. The mitigating effects of a dike and a sump were included in the evaluation of the possible consequences. The evaporating epichlorohydrin could reach offsite endpoints and nearby public receptors. The alternative release scenario for formaldehyde is a leak in a storage tank recirculating line and the release of 38,000 pounds of material. The mitigating effects of a dike and a sump were included in the evaluation of the possible consequences. The evaporating formaldehyde could reach offsite endpoints and nearby public receptors. The alternative release scenario for methyl chloride is a leak in a transfer pipe and the release of 15,000 pounds of material. The mitigating effect of an excess flow valve was included in the evaluation of the possible consequences. The evaporating methyl chloride could reach offsite endpoints and nearby public receptors. The alternative release scenario for the flammable mixture (60% aqueous dimethylamine) is a leak in the transfer pipe from the storage tank and the release of 46,000 pounds of material. The mitigating effects of operating procedures, a high level alarm and a high level switch that prevents filling the tank to more than 93% of its capacity were included in evaluating the possible consequences. The distance to endpoint from ignition of the vapor would not reach off-site. (d) THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Cytec's general accidental release prevention program includes: - EPA 40 CFR 68 - Risk Management Plans - OSHA 29 CFR 1910.119 - Process Safety Management of Highly Hazardous Chemicals - OSHA 29 CFR 1910.120 - Hazardous Waste Operations & Emergency Response - MI-OSHA Part 91, Process Safety Management of Highly Hazardous Chemicals - Other EPA, OSHA, DOT and State regulations - Generally recognized & accepted engineering codes and standards, and - Cytec Safety, Health, Environmental and Engineering standards The following engineering and administrative controls help prevent a release of methyl chloride: - the material is stored in an above ground tank - there is a dedicated railcar unloading platform that prevents contamination with other chemicals - the unloading operation is constantly manned and only done in daylight hours - the personnel performing the unloading are well trained and average over 15 years operations experience - there are numerous alarms and a sensor that prevents overfilling by shutting down the unloading system when a high level is reached - the indoor processing area has a gas detection system The following engineering and administrative controls help prevent a release of dimethylamine: - the material is stored in an above ground tank contained within a concrete dike - the material is always unloaded at the same railcar unloading platform - the railcar unloading platform is equipped with uniquely sized and fitted lines to prevent contamination with other chemicals - the unloading operation is constantly manned - the personnel performing the unloading are well trained and average nearly 18 years operations experience - the air space above the material in the storage tank is nitrogen purged - the storage tank vent is fitted with a flame arres tor - there are numerous alarms and a sensor that prevents overfilling by shutting down the unloading system when a high level is reached The following engineering and administrative controls help prevent a release of epichlorohydrin: - the material is stored in an above ground tank contained within a concrete dike - the material is always unloaded at the same railcar unloading platform - the railcar unloading platform is equipped with uniquely sized and fitted lines to prevent contamination with other chemicals - the unloading operation is constantly manned - the personnel performing the unloading are well trained and average nearly 18 years operations experience - the air space above the material in the storage tank is nitrogen purged - the storage tank vent is fitted with a flame arrestor - there are numerous alarms and a sensor that prevents overfilling by shutting down the unloading system when a high level is reached The following engineering and administrativ e controls help prevent a release of formaldehyde solution: - a substantial amount of formaldehyde used is generated and recycled within the process, which has less risk of release as compared to unloading - the material is stored in above ground tanks contained within a concrete dike - formaldehyde solution is unloaded from two railcar platforms: --- one is a dedicated platform that prevents contamination with other chemicals --- the other is equipped with uniquely sized and fitted lines to prevent contamination with other chemicals - the personnel performing the unloading are well trained and average over 11 years operations experience - there are numerous alarms and a sensor that prevents overfilling by shutting down the unloading system when a high level is reached (e) 5-YEAR ACCIDENT HISTORY There have been no incidents at the Kalamazoo Plant that meet the criteria for reporting in the five-year accident history. (f) EMERGENCY RESPONSE PROGRAM The Cytec Kalam azoo facility Emergency Response Plan incorporates OSHA's Incident Command System, as defined in 29 CFR 1910.120 (q). In the event of an emergency requiring assistance from outside agencies, our personnel will make the necessary notifications and will be able to interact effectively with outside emergency response personnel, since we are trained to operate under the same system. Working with Cytec Kalamazoo facility Emergency Preparedness Team leaders, the Kalamazoo Department of Public Safety (KDPS) and the Kalamazoo County Office of Emergency Management would make any decisions concerning how best to protect the neighboring community. In the event of a release of one of the four regulated substances, or other hazardous material, our facility Emergency Preparedness Team would use chemical-specific response plans and procedures to address the emergency at the earliest stage possible so as to prevent escalation of the incident. We regularly participate in the activities of the Kal amazoo County Local Emergency Planning Committee (LEPC) and Disaster Planning Committee. We work with the KDPS, which provides all fire-fighting services within the jurisdiction that includes this facility, to conduct facility tours for any personnel who may one day have to respond, required facility inspections, and training exercises. Contracted professional technicians test our fire protection system, which includes signals, alarms and sprinkler protection of all processing areas, on a monthly basis. Similarly, contract service technicians perform monthly inspections and service on our respiratory protection equipment, and annual inspections on all fire extinguishers. Facility personnel test our two fire pumps weekly, and safety showers and eyewash stations are checked monthly. Facility personnel who are members of the Emergency Preparedness Team are provided training on emergency response procedures and use of protective and response equipment, and participate in training ex ercises at least annually. Among these team members, we currently have 16 members trained to the HAZMAT Technician or Specialist levels. Emergency Preparedness Team members maintain the chemical protective clothing and response equipment. (g) PLANNED CHANGES TO IMPROVE SAFETY CYTEC Industries is constantly striving to upgrade its processes, control technology, employee training, inspection, repair and maintenance of process equipment in order to improve safety. |