Crompton & Knowles Colors Incorporated - Gibraltar - Executive Summary |
|
Accidental Release Prevention and Emergency Response Policies: At Crompton and Knowles Colors Incorporated, we are committed to operating and maintaining all of our processes, especially those utilizing 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. It is the policy of Crompton and Knowles Colors Incorporated to adhere to all applicable federal and state rules and regulations. Safety is a key factor considered in the manufacture of our products. The safety of our manufacturing processes depends upon the manner in which we handle potentially hazardous substances. The safety devices inherent in the design of these systems, the safe handling procedures that we use and the training of our employees are some of the ways we ensure safe operation of these systems. Our emerge ncy response plan includes procedures for the notification of the Berks County LEPC and notification of any potentially affected neighbors. Stationary Source and Regulated Substances: Crompton and Knowles Colors Incorporated is a leading manufacturer of colors for clothing, home furnishings, carpets, paper and leather. Our Gibraltar facility employs over 220 people in the production of these colors. We produce these colors using a variety of chemicals and batch processing operations. Manufacturing operations are located in one building structure that is located at the western end of our property. In some manufacturing processes, the following chemicals are used that the EPA has identified as having the potential to cause offsite effects in the event of a substantial accidental release: Phosgene: Phosgene is widely used in the manufacturing industry to make such materials as polyurethane foams, polycarbonate thermoplastics, plastic eyeglass lenses and organic dyestuffs to name just a few products. We receive phosgene by truck in 2,000 pound cylinders. These cylinders are used in a batch phosgenation process to make organic dyes for paper and textiles. Our facility can store a maximum of seven cylinders (14,000 pounds). Oleum 25%: Oleum, also referred to as fuming sulfuric acid, is a mixture of sulfur trioxide in sulfuric acid. Oleum is commonly used in the manufacturing industry to make such materials as rayon, cellophane, sugar, starch, sulfonated oils and organic dyestuffs to name just a few products. We receive oleum by tank truck in 40,000 pound quantities. The oleum is then stored in a 131,000 pound bulk storage tank which is typically maintained at 50% capacity. This tank then supplies batch sulfonation processes that make organic dyes for drugs, cosmetics, paper and textiles. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the publ ic, and the environment by our use of these chemicals. Key Offsite Consequence Analysis Scenarios: The RMP rule requires that we provide information about the worst-case release scenario and alternative case release scenario for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures available to limit the exposure distances for each scenario. The worst-case release scenario at our Gibraltar facility involves phosgene. The EPA specifies the worst-case release scenario as the loss of the largest storage container over a ten minute period. All active mitigation measures that were designed to prevent such a release are assumed to fail. Therefore, phosgene totaling 2,000 pounds would be released over a ten minute period. The estimated scenario footprint for this release would reach offsite endpoints and nearby public receptors. No passive or active mitigation measures such as enclosures , deluge systems or gas monitors were assumed to function for this scenario. The alternative case release scenario, as specified by the EPA, is one that is more realistic than the worst-case scenario but which also has the potential for off-site effects. The alternative case release scenario chosen for phosgene involves a shear in the teflon-lined steel hose that connects the phosgene cylinder to the process piping. This scenario would release 800 pounds of phosgene and would last for 60 minutes. Because the alternative case release scenario must have the potential for off-site effects, it was assumed, although highly unlikely, that the phosgene scrubber was not functioning. The estimated scenario footprint for this alternative release would reach offsite endpoints and nearby public receptors. Only the passive mitigation of the phosgene cylinder enclosure was considered for this scenario. The parameters for the worst-case release scenario and the alternative case release scenari o are determined by the EPA. The alternative case release scenario must have the potential for causing off-site effects. Due to the numerous active and passive mitigation measures installed on the phosgene process it was difficult to find an alternative case release scenario that would produce off-site effects. For this reason it should be noted that the scenario of the phosgene scrubber not functioning in the alternative case release scenario is highly unlikely. The scenario also assumes that the leak will last over 60 minutes which is also highly unlikely due to the phosgene monitors which constantly sample in and around the phosgene process. There are other numerous active and passive mitigation measures on the phosgene process that were assumed not to function to allow the alternative case release scenario to have off-site effects. These control measures include: *A phosgene scrubber that continuously neutralizes any fumes from the phosgene reactor vessel and the phosge ne feed line containment piping. *A phosgene monitor with twelve sampling points located around the phosgene system. Three monitoring locations are inside the phosgene cylinder enclosure. All points are continuously monitored for phosgene at the part per billion level. *An ammonia deluge system that will neutralize the phosgene. *A double-walled phosgene transfer line running from the phosgene cylinder to the reactor that is under constant suction to the phosgene scrubber. *A containment dike that will collect a liquid pool of phosgene. *Emergency shut-off valves at both ends of the phosgene transfer line that can be closed automatically to isolate a phosgene leak. *An on-site Hazmat team trained to respond to chemical incidents. *A valve bonnet that can be installed over the phosgene cylinder valve to seal a leak. The alternative case release scenario chosen is the result of a simultaneous failure of multiple control measures specifically designed to prevent such an event from oc curing. There is never an instance while operating the phosgene reactor when any passive or active mitigation measure is bypassed or ignored. 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: The Crompton and Knowles Colors Incorporated Gibraltar facility complies with EPA's Accidental Release Prevention Rule (40 CFR Part 68) and OSHA's Process Safety Management of Highly Hazardous Chemicals Rule (29 CFR 1910.119). Crompton and Knowles Colors Incorporated is also a member of the Chemical Manufacturers Association (CMA) and is committed to the fulfillment of CMA's Responsible Care Program. This program seeks continuous improvement in health, safety and environmental quality. We continuously maintain a number of programs to help prevent accidental releases and ensure safe operati on. The accidental release prevention programs in place at this facility include: *Process Safety Information. *Process Hazard Analysis. *Detailed operating procedures. *Training for operators and maintenance mechanics. *Mechanical Integrity Program. *Management of Change Policy. *Prestartup Reviews. *Compliance Audits. *Incident Investigation Policy. *Employee Participation Policy. *Hot Work Policy. *Contractor Policy. As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: *All active mitigation measures such as the phosgene detection monitor, phosgene scrubber and emergency shut-off valves must be operational before phosgene can be reacted. *Phosgene is only reacted by first shift operators. *Pressure tests are performed on the phosgene transfer line prior to every batch. *Only trained employees unload phosgene from the delivery truck. These individual elements of our prevention program work together to prevent accidental chemica l releases. Our company and our employees are committed to the standard that these management systems set for the way we do business. We have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. Five Year Accident History: There have been no reportable accidental chemical releases at the facility involving materials covered under the EPA's RMP rule during the past five years. Emergency Response Program: We maintain an emergency response plan, which meets all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting our employees, the public, and the environment during emergency situations. Our emergency response program is also coordinated with the community emergency response plan through the Berks County LEPC. We perform monthly tests of the Emergency Response Siren System. We have an on -site Hazmat team consisting of fourteen volunteers who receive extensive training and certification each year. Several members participate on the Berks County Hazmat team. Planned Changes to Improve Safety: The following is a list of programs that we will continue to implement at our facility to help prevent and/or better respond to accidental chemical releases: Continue to ensure compliance with the EPA's Accidental Release Prevention Rule (40 CFR Part 68). Continue to ensure compliance with OSHA's Process Safety Management of Highly Hazardous Chemicals Rule (29 CFR 1910.119). Continue to fulfill the requirements of the Chemical Manufacturers Association (CMA) Responsible Care Program. |