Clariant Corporation - Kalama Plant - Executive Summary |
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This is the executive summary for the Kalama plant RMP: At the Clariant Corporation Kalama Plant, we are committed to operating and maintaining our process 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. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: A description of our facility and use of substances regulated by EPA's RMP regulation A summary of results from our assessment of the potential offsite consequences from accidental chemical releases An overview of our accidental release prevention programs A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule An overview of our emergency response program An overview of recent improvements at the facility to h elp prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment Stationary Source and Regulated Substance: Our facility uses sulfur dioxide in the production of Sodium Hydrosulfite and Zinc Oxide for use in the paper and rubber industries. The EPA has identified sulfur dioxide as having the potential to cause adverse offsite consequences in the event of a substantial accidental release. Our storage tank holds 227 thousand pounds of sulfur dioxide at the site. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the potential hazards that are posed to our employees, the public, and the environment by our use of sulfur dioxide. Offsite Consequence Analysis Scenarios: EPA's RMP rule requires that we provide information about the worst-case release scenario (as defined by the EPA) and alternative release scenario for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario Sulfur Dioxide Our worst-case scenario is failure of the sulfur dioxide storage tank. The evaporating sulfur dioxide could potentially reach offsite endpoints and nearby public receptors. The site has implemented a process safety management system, including storage tank inspection and maintenance requirements, intended to prevent this type of incident from occurring. Alternative Release Scenario Sulfur Dioxide The RMP alternative release scenario involves the rupture of the sulfur dioxde unloading hose, resulting in the release of approximately 45 pounds of sulfur dioxide in less than a minute. The amount of sulfur dioxide that could be released is limited by an excess flow valve that would automatically close and stop the flow in the event of a hose failure. Per the EPA's off-site consequence a nalysis software, sulfur dioxide released in this scenario could impact public receptors within 0.2 mile of the facility. The public receptor that could be impacted by such a release is a park. However, the site has implemented a process safety management program that includes inspection and scheduled replacement of unloading hoses to prevent this type of scenario from occurring. 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. Chemical Release Prevention Program: At the Clariant Corporation's Kalama Plant we take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Management of change Pre-startup review Complia nce audits Incident investigation Employee participation Hot work permit Contractor safety As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: - SO2 transfer hose inspection and replacement program - SO2 monitoring systems that activate alarms in the event of an SO2 release - Video monitoring systems that allow us to monitor the SO2 handling and processing areas - Hazardous materials unloading permit procedure - SO2 storage tank inspection, certification and maintenance program These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to maintaining these management systems and recognize that this is 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 releases of sulfur diox ide in the past five years at our facility. In fact, none have occurred since the plant began operation in 1969. However, we have a system in place to investigate and keep records of significant incidents, including accidental chemical releases that might occur at our facility. If a significant release should occur, we will conduct a formal incident investigation to identify and correct the root cause(s) of the event. Emergency Response Planning: We maintain emergency response plans, which address 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 workers, the public, and the environment during emergency situations. Our plan also includes specific procedures for responding to a release of sulfur dioxide. Furthermore, we coordinate our plan with the Port of Kalama Emergency Preparedeness Committee Response Plan. Emergency response drills for SO2 and other site materials have also been conducted with the local emergency response organizations. Recent Changes to Improve Safety: The following is a list of improvements that have recently been made at the facility to help prevent accidental chemical releases: - The sulfur dioxide feed system has been revised to reduce the amount of material that is held in the processing area. - An SO2 monitoring system that sounds an alarm in the event of a release has been installed. - A video surveillance system that allows monitoring of the SO2 unloading and processing areas has been installed. - An enclosed SO2 level measuring system that is less vulnerable to leakage has been installed. In summary, Clariant is committed to the safe operation of our facility, and we take the actions necessary to ensure the safety of our employees, members of the community, and the environment. |