Clariant LSM (Missouri) Inc. - Executive Summary |
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Clariant LSM (Missouri) Inc. (Clariant LSM) is a manufacturer of pharmaceutical chemicals. Our key products are materials used in the manufacture of ALEVE, naproxen sodium, and naproxen. REGULATED SUBSTANCES Bromine and methyl chloride are two of the primary chemicals used in the manufacture 2-bromo-6-methoxynaphthalene (BMN) and 1-bromopropionic acid (BPA), materials used in the manufacture of the pharmaceuticals naproxen and naproxen sodium. The RMP Threshold Quantities are 10,000 lbs. for both bromine and methyl chloride. STATIONARY SOURCE AND ACCIDENTAL RELEASE PREVENTION-METHYL CHLORIDE Methyl chloride is a material used in the BMN manufacturing process. Methyl chloride is unloaded from a tank truck to a 12,000 gallon carbon steel tank. It is stored under pressure as a liquid (pressurized gas). When used in the process, liquid methyl chloride is pumped from the storage tank through a flow meter to the processing tanks. The carbon steel storage tank contains up to 74,000 p ounds of methyl chloride. The average daily amount on site is approximately 40,000 to 50,000 pounds. The methyl chloride storage and handling system is closely monitored and protected: All safety parameters for the methyl chloride system, including tank and system integrity are monitored using control system software and displayed on computer terminals in site control rooms. Automatic shutdown controls are engaged in the event that process parameters go outside of predetermined setpoints. A sprinkler system is installed to ensure that the tank is properly protected from fire impingement. Methyl chloride sensors have been installed around the tank to detect potential methyl chloride leaks. If a sensor detects methyl chloride, it activates the emergency shutdown system which isolates the tank in a safe shutdown mode. During methyl chloride unloading, process parameters are constantly monitored by employees using control system software; the process parameters are displayed on c omputer terminals in site control rooms. Additionally, video cameras provide the ability to visually monitor the unloading process from the control room. STATIONARY SOURCE AND ACCIDENTAL RELEASE PREVENTION-BROMINE Bromine is used in the manufacture of both BPA and BMN. All of the liquid bromine on site is stored in an indoor containment room equipped with containment dike walls and process control systems to prevent upset conditions. Bromine is received on site via a tank truck. The tank truck is parked in an enclosed unloading bay where bromine is unloaded from the trailer to storage tanks. The average daily amount on site is approximately 157,500 pounds stored after a bromine truck is unloaded. The bromine unloading and storage rooms are equipped with bromine leak detectors which initiate an alarm in the event of a leak. Any leak or potential release of bromine is limited and quickly mitigated by management practices as well as several safety devices (interlocks) incorporated into the bromine storage and transfer system: All bromine in storage and loading is handled within a containment vault to contain any potential releases. Bromine is stored indoors, thus significantly reducing the potential for an off-site release. Room ventilation is exhausted through a scrubber to remove bromine from the discharged air. All unloading transfers from tank trucks to storage tanks are monitored by unloading crew members. Unloading crew members constantly oversee the bromine unloading procedure from the unloading room's control panel. Unloading process parameters are monitored using control software and displayed on computer terminals in site control rooms. Additionally, video cameras provide the ability to visually monitor the unloading bay during the process. Bromine transfers from storage tanks to the process vessels are also monitored by the control system and displayed on terminals in plant control rooms. WORST CASE RELEASE SCENARIO AND ALTERNATIVE RELEA SE SCENARIOS All hazard assessments were developed using the Cameo/Marplot/Aloha software package. Worst Case Release Scenario The worst case release scenario for the Clariant LSM facility was evaluated in accordance with the RMP regulations established by the EPA. The identified worst case scenario is the rupture or failure of the methyl chloride storage tank, allowing the entire contents of the tank to escape in 10 minutes. Worst case atmospheric conditions were assumed and no safety devices or facility response was allowed. The worst case release scenario results in off site methyl chloride concentrations at or above the EPA Level of Concern (LOC) concentration of 0.039% (390 parts per million). At the LOC concentration, individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects that could impair their abilities to take protective actions. See Section 2 of the RMP Submit report for detailed information on this release scenario. Alternative Release Scenarios In accordance with the RMP program, alternative release scenarios were evaluated for both methyl chloride and bromine. Alternative releases are intended to be more likely than the worst case scenarios. These scenarios assume average atmospheric conditions and allow for the reasonable application of safety systems and facility response. Each process is evaluated to consider what type of accidents or equipment failures might occur, and what off-site consequences might result. Methyl Chloride: The alternative release scenario for methyl chloride is a release through the emergency pressure relief system on the 12,000 gallon storage tank due to over-pressurization. The release was assumed to continue for 60 minutes. This alternative release scenario for methyl chloride results in off site methyl chloride concentrations at or above the EPA Level of Concern up to 0.14 miles from the storage tank. At the Level of Concern concent ration, 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 methyl chloride storage tank is equipped with automated safety controls that respond to and correct variances in pressure, temperature, or level that are beyond the setpoint limits for that particular variable. Additionally, there are four methyl chloride sensors installed at strategic locations on the tank to detect leaks. Once the sensor detects a leak, it activates the emergency shutdown system which isolates the tank and maintains the methyl chloride within safe operating parameters. Bromine: The alternative release scenario for bromine involves the release of bromine from one of the transfer lines that transports the bromine from the storage area to the manufacturing equipment. A failure of a flange or gasket in this piping could result in a release. Clariant LSM as sumes that the leak could continue unabated for 15 minutes, forming a pool inside a production building which gradually evaporates resulting in an off-site release. This alternative release scenario for bromine results in an off site bromine concentration at or above the EPA Level of Concern for up to 0.10 miles. At the Level of Concern concentration, individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects that could impair their abilities to take protective actions. All bromine transfer piping for the BMN and BPA manufacturing process are located indoors. Bromine lines are high integrity piping that is in compliance with Recognized and Generally Accepted Good Engineering Practices and are installed per Clariant LSM (Missouri) Inc.'s Pipe Specifications which conform to ASME Process Plant Piping Code (B31-3). In addition to installing high integrity lines for all bromine transfers, the flanged connections ar e all equipped with flange guards. The flange guards indicate any leakage at the flange by discoloring where bromine contacts the guard material. All bromine transfers are monitored by the operator in charge of that phase of the manufacturing process. If process conditions vary beyond the safe operating limits listed in the operations manual, the operator can stop the transfer remotely using the control system interface in a facility control room. Bromine transfer lines are all placed in contained or indoor locations, thus reducing the evaporation rate from potential spills or leaks, and, therefore, greatly reducing the potential for off-site exposure. PREVENTION PROGRAMS Clariant LSM (Missouri) Inc. has implemented the Responsible Care Process Safety Code, OSHA's Process Safety Management (PSM), and EPA's Risk Management Plan (RMP). Clariant LSM has developed prevention programs for all regulated chemicals. The success of these prevention programs is reflected in Clariant LSM's excellent safety performance. Clariant LSM's prevention programs are comprised of technology-, personnel-, and facilities-related elements. Technology-related elements include process hazards analysis (PHA), operating procedures and safe practices, and management of change (MOC). These elements provide guidance in managing all physical, procedural, and technical changes made on this site. A plant-wide database is used for tracking MOCs and PHAs. Facilities-related elements that significantly contribute to the success of the prevention program include the mechanical integrity program and the pre-startup safety reviews (PSSR). The mechanical integrity program is a comprehensive program that is responsible for equipment compliance with Good Engineering Practices (GEPs), proper equipment preventative maintenance, and equipment quality assurance. Personnel-related elements include formal training and incident investigation. Both of these programs utilized database systems to maintain and organize records so that site personnel are able to track plant performance in these areas. FIVE-YEAR ACCIDENT HISTORY In accordance with RMP reporting requirement. Clariant LSM is pleased to report that there have been zero accidental releases from Clariant LSM that have resulted in deaths, injuries, or significant property damage on site. There have also been no offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. EMERGENCY PREPAREDNESS Clariant LSM (Missouri) Inc. has established a complete emergency reponse plan to define the procedures and activities necessary to manage chemical incidents. All operators and maintenance mechanics complete a 40 hour certified hazardous material technician training course and conduct emergency response exercises approximately every 3 months. All shift supervisors complete certified emergency response incident command training. Clariant LSM works closely with the Springfield Fir e Department, Local Emergency Planning Committee and Emergency Management Office to assure these planning and response organizations are familiar with the Clariant LSM site. A joint emergency response exercise is conducted with the Springfield Fire Department once per year on each shift at the Clariant LSM facility to assure the fire department Hazardous Material Teams are familiar with the Clariant LSM site and can work effectively with the Clariant LSM HazMat teams. Clariant LSM maintains an account with the Community Alert Network (CAN) telephone notification service. In the event of an emergency at Clariant LSM, site personnel activate the CAN system which calls each telephone number of all facility neighbors who could potentially be affected. The telephone call provides a brief description of the emergency and instructions on precautions that should be taken. A follow up call can be given to sound the "all clear". PLANNED CHANGES TO IMPROVE SAFETY Clariant LSM believes conti nuous improvement of all environmental and safety systems is crucial to the ongoing success of the company. Several ongoing safety programs are in place to assure means of improving site safety performance are fully explored. All incidents and accidents are reported and investigated to assure causative factors are identified and corrected. The site Compliance Team conducts routine audits to verify safety management systems are functioning as designed. Plant safety committees meet each week to discuss safety and encourage employees to voice any suggestions they may have. These and other programs have resulted in numerous improvements to safety at Clariant LSM and will continue to do so. |