Ciba Specialty Chemicals Corp. - McIntosh Plant - Executive Summary

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This Risk Management Plan (RMP) has been prepared by the Ciba Specialty Chemicals Corporation (Ciba), McIntosh site to satisfy the requirements of the Clean Air Act Amendments (CAAA) Section 112 (r) mandated by the U.S. Environmental Protection Agency (40 CFR-part 68). 
 
The Ciba McIntosh site is located on Ciba road in McIntosh, Washington County, Alabama.  The site occupies approximately 1,500 acres and has approximately 1,000 employees on site. Production at the McIntosh site began in 1952 with 32 employees manufacturing one product.  Currently, the site produces additives for plastics, paints, and oils,  optical brightners used in detergent, paper and textile industries, and chemicals used in household and farm products, such as herbicides, pesticides and insecticides.  In 2000 Ciba Specialty Chemicals sold its Performance Polymers division, which became Vantico.  Two of the site's manufacturing areas were included in the sale, and Ciba now shares its McIntosh site with Vantico. 
 
Wi 
th an injury rate 40 percent below the national average, the McIntosh site is a leader in safety.  In fact, employees at the site have worked one million safe hours (hours worked without an accident) 36 times since 1972.  The OSHA Star Designation program requires stringent inspections and an excellent safety and health program.  In 1989, the McIntosh site became the 64th industrial site out of five million in the U.S. to receive the coveted designation.  The site was re-certified as an OSHA Star site in 2000. 
 
The line of products at McIntosh may vary in response to market demand.  Overall, there are two operating divisions at the McIntosh site.  These two divisions are the Additives Division and the Consumer Care Division.  Below is a brief description of each production area at the site: 
 
The Additives Area 1 is designed to produce Irgafos (process stabilizers used primarily as blend components) and Irganox (antioxidants).  In this Area, raw materials and solvents are fed to reactor 
s.  The reaction mass undergoes additional processing steps such as stripping, crystallizing, centrifuging, blending, and drying.  The products are then either packaged dry or transferred to the granulations area.  Solvents used in the process are recovered and reused.  One RMP-regulated substance exceeding the threshold quantity was identified in Area 1: Phosphorous trichloride at a maximum quantity of 80,000 lbs. 
 
The Additives Area 7 is designed to produce Diazinon.  The process starts by burning hydrogen and chlorine to produce hydrochloric acid.  The gas is then cooled and fed continuously to both the oxypyrimidine process unit and an absorber, where 32% hydrochloric acid is made.  The oxypyrimidine is then reacted with raw materials to produce Diazinon.  Three RMP-regulated substances exceeding their threshold quantities were identified in Area 7: chlorine at a maximum quantity of 3,100 lbs., isobutyronitrile at a maximum quantity of 800,000 lbs., and a 28% ammonia solution at a  
maximum quantity of 170,000 lbs.  
 
The Additives Area 14 is designed to produce Thioherbicides.  The process involves reacting chlorotriazines with methyl mercaptan to make the final products.  Toluene is used in the process as a solvent to extract the product that is then fed through a two stage stripping operation to remove the solvent.  The molten product is then crystallized, milled and packaged.  The only RMP regulated substance exceeding its threshold quantity identified in Area 14: methyl mercaptan at a maximum quantity of 480,000 lbs. 
 
The Additives Area 17/18 is designed to produce various additives by diazotizing o-nitroaniline with sodium nitrite in an acidic medium.  The resulting diazonium salt is reacted with one of several substituted phenols.  The intermediate is then separated from the reaction mass and dissolved in a solvent before being reacted with hydrogen in the presence of a catalyst to form the corresponding additive product.  The catalyst is then removed from t 
he reaction mass and the solvents partially stripped off.  The product is finally purified, isolated and dried to the finished form for packaging.   No RMP regulated substances exceeding their threshold quantities were identified in Area 17/18. 
 
The Additives Area 20 is a multi-product batch processing unit that produces a variety of additives that are used in other finished products.  Some of the chemicals produced in Area 20 include light stabilizers, antioxidants, and oil additives.  No RMP regulated substances exceeding their threshold quantities were identified in Area 20. 
 
The Consumer Care Area 2 produces a variety of surfactants and oleophenols in addition to sodium iodide solution.  No RMP regulated substances exceeding their threshold quantities were identified in Area 2. 
 
The Consumer Care Area 8 produces fluorescent whitening agent (FWA) intermediates and paper dyes.  These are either further processed on site or sold.  The FWA intermediates and some of the paper dyes are p 
roduced from a para-nitro toluene base.  Many dyes are also formulated and/or repackaged, but not chemically produced in the Area.  Two RMP regulated substances exceeding their threshold quantities were identified in Area 8: Ammonia at a maximum quantity of 130,000 lbs. and Oleum, 65% at a maximum quantity of 920,000 lbs. 
 
The Consumer Care Area 10 primary task is to produce fluorescent whitening agents (FWA) that are used in various commercial products, such as paper, textiles, and detergents.  The process consists of reacting cyanuric chloride, diaminostilbene disulfonic acid, and various amines and/or glycols to form a number of final products.  Solvents used include water and methyl ethyl ketone.  The final products are sold in liquid, solid or slurry forms.  Various additives are used to enhance product performance.  No RMP regulated substances exceeding their threshold quantities were identified in Area 10. 
 
The Utilities Department controls all the boilers as well as the hydroge 
n storage and header system.  No RMP regulated substances exceeding their threshold quantities were identified in the utilities area. 
 
A waste management facility (Area 15) also exists on site which includes an incinerator for hazardous waste as well as aboveground wastewater treatment plant (WWTP) that treats sanitary and process wastewater generated at the plant.  No RMP regulated substances exceeding their threshold quantities were identified in Area 15. 
 
The first key element in the RMP regulations is that a facility must identify all processes that contain any RMP-regulated substances above their designated threshold quantities. 
 
The second key element in the RMP regulations, is to determine program levels for the RMP-regulated processes.  These levels range from a Program 1 that imposes minimal requirements on a process to a Program 2 or 3 which require a much greater level of effort.  The McIntosh site is subject to the OSHA Process Safety Management (PSM) standard, 29 CFR 1910. 
119.  The site?s processes are also included in the nine SIC codes specified by the RMP rule.  Therefore, the facility has designated all of its processes to be in the Program 3 level of the RMP. 
 
The third key element in the RMP regulations is that Program 3 facilities must conduct an offsite consequence analysis.  Ciba opted to use the EPA guidance manual mainly because it is more conservative than most commercial models. Ciba also used the toxic endpoint concentrations specified in the manual, which represent concentrations below those believed to cause serious health effects after thirty to sixty minutes of exposure. This data was then confirmed using the EPA provided software RMP*COMP.  
 
Using extremely conservative estimates of weather and release conditions, Ciba?s offsite consequence analysis indicated that a worst-case toxic release scenario could have an offsite impact.  This scenario was based on the failure of a railcar containing methyl mercaptan, which has a toxic end poi 
nt concentration of 0.049 mg/liter.  The toxic end points specified for the regulated toxic substances are intended to be protective of the general public.  These end points are concentrations below which it is believed nearly all individuals could be exposed for one-half to one hour without any serious health effects.  To prevent such a catastrophe from occurring, Area 14 has a permanently installed emergency storage vessel, which can accommodate the material in case of a vessel failure and a deluge system  to minimize a release. It is important to note that the McIntosh site has safely handled methyl mercaptan for 30 years. Training, procedures, safety systems, and preventive maintenance programs are all in place to ensure we will continue to handle this and all materials safely. 
 
Utilizing the same EPA guidance manual, an alternative release scenario for methyl mercaptan was also developed that could have an offsite impact.  This alternative release scenario was based on a worst cas 
e scenario occurring on the drop tank vessel within the process unit. The same measures in place for the larger storage tanks and rail car also apply to this tank. 
 
An alternative release scenario was also considered for each RMP-regulated toxic chemical on site.  The alternative release scenarios were based on process knowledge, accident history or the process hazard analysis conducted for the unit. 
 
The phosphorus trichloride alternative release scenario was based on the assumption of a transfer hose failure during an unloading operation in Area 1.  With a toxic endpoint of 0.028 mg/liter, the release scenario could have an offsite impact. Operators are always present during these unloading operations to insure the safety of the operation. The unloading operation is also monitored by a computer and by control room operator. Should a problem with the unloading occur, the tank trucks are equipped with an emergency cut off valve that can quickly be closed from the front of the truck.  A 
lso, the unloading area is surrounded by a concrete dike that is large enough to hold the contents of an entire truckload of material. This diked area is equipped with a foam spray system that can be used to provide a protective barrier to prevent vapors from a spill from being released to the air. Procedures, training, safety systems and preventive maintenance programs are all in place to prevent spills, but should a spill occur, this unit  is well prepared to effectively respond. 
 
The chlorine alternative release scenario was based on the assumption that a chlorine pipe leak occurs in Area 7.  With an endpoint of 0.0087 mg/liter, this scenario could have an offsite impact. Chlorine is produced at an adjacent facility and is transfered though a 1.5 inch diameter pipe to Area 7.  The pipeline is divided into four zones by automatic valves. These valves will automatically close if there is a sudden pressure drop on the line which may indicate a leak. The entire length of the line is vis 
ually inspected twice a day and is inspected for corrosion annually. The pipeline is made of a thick wall pipe (schedule 80) and all joints are welded, not flanged. Also, a direct telephone line is in place between the Area 7 control room and the adjacent facility control room.  
 
The isobutyronitrile alternative release scenario was based on the assumption that a transfer hose has failed in Area 7.  With a toxic endoint of 0.14 mg/liter, this scenario could also reach offsite. As with all of our hazardous materials, operators monitor every unloading operation.  Computer controls, procedures and preventive maintenance programs are in place to prevent spills, but should a spill occur, the storage area has concrete dike containment which is capable of holding the contents of the largest storage tank. Sprinkler systems and a water cannon are also in place for spill mitigation. 
 
The ammonia alternative release scenario was based on the assumption that a transfer hose fails during the unload 
ing of aqueous ammonia in Area 7.  With a toxic endpoint of 0.14 mg/liter, such a scenario could have an offsite impact. As with all of our other hazardous materials, measures are in place to prevent spills:  Computer controls and interlocks, training, procedures and preventive maintenance programs. If a spill should occur, the storage tank area is within a concrete dike large enough to contain the entire contents of the storage tank. Ammonia vapors from such a release can be effectivley controlled by the water spray and deluge systems in place. Water cannons are also strategically located throughout the areas. 
 
The oleum alternative release scenario was based on the assumption that a pipe begins to leak in Area 8.  This scenario could have an offsite impact.  Spill prevention measures in place for oleum include the use of a double walled storage tank, redundant level instrumentation, preventive maintenance programs, scrubber system, and computer controls and interlocks. If a spill sho 
uld occur, the storage area is located within a concrete dike to contain the spill, and a storage tank is always kept empty for emergency storage of oleum. A special neutralizing powder called Spill-X-A is also available to neutralize spills. 
 
Another key element of the RMP regulations is to develop and submit a five-year accident history involving RMP-regulated substances.  Over the past five years, the Ciba McIntosh site has had one accident involving RMP regulated substances.  
 
The accident occurred on February 1997 and involved a short span release of a methyl mercaptan, isopropanol and nitrogen mixture.  The release lasted less than a minute and resulted in 2 OSHA recordable injuries.  Since then, Ciba has revised its maintenance and training programs and revised the operating procedures to prevent such accidents from occurring. 
 
In order to deal with potential accidents and emergencies, Ciba has an Emergency Action and Response Plan in place.  In addition, there is a written cont 
ingency plan for the Area 15 treatment, storage and disposal (TSD) facility.  The contingency plan is part of the RCRA part B permit application.  The Ciba site also has its own fire department with its own fire fighters, hazmat team, emergency medical technicians and paramedics in addition to having a fully staffed health services facility with the most modern medical technology available. The Ciba hazmat team is utilized by the county for any hazmat incidents. Ciba's emergency response coordinator is also the chairman of the Local Emergency Planning Committee.  A community evacuation drill was conducted on February 19, 2000.  A tabletop emergency response exercise including the community was conducted on September 12, 2000, and a full scale emergency response drill with community participation was conducted on October 7, 2000.    In addition, this Ciba facility in coordination with other companies in the industrial park have provided local residents within a three mile radius a micro 
siren alert radio. This is an emergency alert system which will provide emergency information and instructions to the local community in an emergency situation.
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