Ciba Specialty Chemicals, Corp. - Executive Summary |
|
The Ciba Specialty Chemicals (Ciba) Old Bridge, NJ facility is located on Old Waterworks Road, near the Old Bridge/Sayreville border, between Bordentown Avenue and Route 9. At the facility, Ciba manufactures specialty organic chemicals used to produce water treatment chemicals. At Old Bridge and at all of its facilities around the world, Ciba is committed to the safety of its employees and neighbors, to protecting the environment, and to building positive relationships in the community. Ciba employees work closely with the local community, emergency responders, and local emergency planning commissions to ensure the safety and health of our neighbors. Ciba believes that the more the community understands about our business and the way we manage our facilities, the more they will be reassured that we are responsible members of the community. Ciba takes very seriously the safe and proper handling of the products and raw materials, and the safe operation of its facilities. The compa ny supports the community?s right-to-know, and programs that provide meaningful information to the public about environment, health and safety issues. Leadership from Ciba's senior management is evident in policy, participation, communications and resource commitments dedicated to achieving continuous improvements in environmental, health and safety performance, which is a major corporate goal. Toward this end, Ciba is also committed to the American Chemistry Council's Responsible Care Program, which is the foundation of the company?s environmental health and safety program. Risk Management Planning (RMP) requirements provide another important framework for ensuring safe chemical manufacturing operations. The first key element in the RMP regulations requres that a facility must identify all processes that contain RMP-regulated substances above designated threshold quantities. The second key element in the regulations involves determining program levels for RMP-regulated processe s, depending upon the actual risks posed. The third key element involves conducting off-site consequence analyses. Ciba has opted to use the EPA Guidance Manual for this purpose because it is more conservative than most commercial models. Ciba also used the topic endpoint concentrations specified in the manual, which represent concentrations below those believed to cause serious health effects after 30 or 60 minutes of exposure. Use of such criteria provides further evidence of Ciba's commitment to going beyond what is required in order to facilitate, monitor and measure the effectiveness of its efforts in support of safe operations. At the Ciba Old Bridge site, the commitment to a safe work place has resulted in no lost work-days in almost one year. The RMP Plan developed for the site reflects Ciba's commitment to the safety of its employees and the community. Ciba continually works to enhance the program through on-going process safety reviews and improvements that go beyon d the requirements of RMP. A $1 million dollar state-of-the-art fire protection system including a new underground ring main, pump house, and foam systems has recently been installed, along with a new emergency pressure release system which ensures no significant discharges to the atmosphere even in the most unlikely event of loss of reactor control. The only RMP regulated chemical used at the site is allyl alcohol. The maximum quantity of allyl alcohol at the facility is 70,000 pounds. Using conservative estimates of weather and release conditions, Ciba's off-site consequence analysis for allyl alcohol indicated that a worst case release scenario for allyl alcohol could have an off-site impact. The worst case scenario for allyl alcohol would involve the release of the material from a storage tank into a diked area, and the evaporation of the resulting liquid pool. Using EPA's OCA Guidance Manual, the release would have an off-site endpoint that could potentially reach nearby r esidential receptors. However, such effects would be mitigated by the presence of the allyl alcohol storage tank in a diked area, which would effectively reduce the release rate to 15 lbs./minute. Through process hazard analyses, the alternatative scenario was also developed for allyl alcohol. The alternative scenario involves the failure of a transfer hose during the unloading of a tanker of allyl alcohol to the allyl alcohol storage tank. Conservative assumptions dictate that such a release could last 15 minutes, until the operator making the transfer shuts the pump off to stop the flow. The release could have an off-site endpoint, but would not reach nearby residential, public, or environmental receptors. This scenario was also developed based on the EPA OCA Guidance Manual. Another key element of the RMP regulations involves developing and submitting a five-year accident history involving RMP-regulated substances. The Old Bridge site's five-year RMP chemical accident his tory indicates no releases to the environment or any major process incidents. To continue such performance, the Ciba Old Bridge plant conducts an accidental release prevention program that includes quarterly emission monitoring of all flanges, valves, pumps, etc., with immediate repair of any leaks, as well as ultrasonic thickness testing of all vessels and transfer lines utilized for regulated chemicals. Procedurally, transfers of RMP-regulated chemicals to storage vessels is made during daylight hours under taped video surveillance to maximize our ability to detect and effectively respond to any problem. A computerized program is also utilized to insure that preventive maintenance is performed on all critical equipment according to a pre-determined schedule which is based on good manufacturing practices. The Ciba Old Bridge plant is actively involved in the community beyond its gates. The site is an active member of the Old Bridge Local Emergency Planning Committee, and a s such has reviewed its RMP program with LEPC officials. Means of alerting the surrounding community in the unlikely event of a release are being finalized with the LEPC. Plans include utilizing the Old Bridge warning sirens located through-out the township, or route alerting using official vehicles. In addition, the plant conducts emergency drills in conjunction with the Cheesequake Fire Department, and makes sure that local fire officials are familiar with the lay-out and emergency response equipment available at the site. |