Morton International Advanced Materials - Executive Summary |
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28073 LDEQ Facility ID Number Accident Release Prevention Program and Emergency Response Policy It is the policy of Morton International, Inc. Weeks Island, LA facility management to implement the requirements of the Risk Management Program (RMP) herein described in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the potential of a release of a hazardous material to occur and if a release occurs, to minimize the impact to Morton employees, the public and the environment. This objective is met by continuing to utilize general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Morton's management is committed to providing the resources necessary to implement this policy. Facility Description Morton International, Inc. is located in Weeks Island, LA and operates primarily as a manufacturer of specialty chemicals. Two chemicals, MTS and H2Se, are utilized at the facility in sufficient quantities to be subject to the RMP requirements as detailed at 40 CFR Part 68. Another chemical, H2S which is regarded as being potentially harmful is also used at the facility. This compound, as well as those regulated by the RMP are handled and stored using the best management practices, including specially designed collectors, cylinders, or bulk tank. Consequence Analysis The Accidental Release Prevention Program requires facilities to evaluate the impact of a release of the regulated chemicals under well-defined conditions. Two types of releases must be considered; first, a "worst case" must be examined and secondly, a release that is more likely to occur. These incidents are known as the worst case and alternative release scenarios. The regulations require that the worst case consider the effects of the rupture of a v essel (or pipe) that contains the maximum amount of the chemical that is being examined. The chemical is then presumed to evaporate (if released as a liquid) and dissipate as it moves away from the release site. The regulation defines the conditions under which the evaporated material dissipates. Conservative assumptions are made regarding the temperature, wind speed and the tendency for "mixing" to occur in the atmosphere. The assumptions are used such that the predicted concentration of the chemical represents an over-estimate of what would actually occur. The alternative release scenario is one that is considered to be more likely to occur. The alternative release scenarios provided within this RMP have been developed by considering the following: previous incidents at the facility (e.g., hose leaks, seal failures, line ruptures) that have involved chemicals, items that have been identified through the "What If" process and those associated with the chemical industry in genera l. The RMP regulations provide the use of assumptions influencing dispersion that are more likely to occur during an alternative release scenario. The worst case consequence analysis that was performed for each compound indicated that there is a potential for concentrations to exceed the endpoints defined by the regulations in the event of an incident. For example, a catastrophic release of MTS from the storage tank (defined by the RMP regulations as the worst case) would impact the surrounding community. The alternative release scenarios that were developed for each chemical regulated under the RMP regulations indicated that the impact zone would be significantly reduced by comparison to that predicted for the worst case release of MTS. Given that the alternative release scenarios represent events more likely to occur, the reduced impact area is one measure of the effectiveness of Morton's prevention program and mechanisms used to mitigate the results of an incident. Further, it should be noted that the likelihood of any of these scenarios occurring is very small - again demonstrating the ability of Morton to handle chemicals in a safe manner. Five Year Accident History Morton has not had any release of H2Se or MTS from the Weeks Island, LA facility that has met the reporting criteria by causing injuries requiring medical treatment, significant property damage, affects the public or the environment. Emergency Response Program Morton has personnel trained in emergency response at the facility 24 hours per day, seven days per week. These personnel receive annual training on emergency procedures and response techniques (HAZWOPER). Planned Changes to Improve Safety Morton completes a thorough review of the potential impact of all chemicals that are considered for use at the facility. This includes compounds that are not specifically addressed under the RMP regulation. Further, Morton conducts reviews on a routine basis to ensure that each process that employs hazardous chemicals is thoroughly examined. The Weeks Island facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and the environment. These regulations include: * 40 CFR Part 68, Accidental Release Prevention * 40 CFR Part 112, Spill Prevention, Control and Countermeasure * 40 CFR Part 264, Hazardous Waste Contingency Plan * 29 CFR Part 119, Process Safety Management The key concepts in Morton's release prevention program are employee participation, appropriate design and maintenance of equipment, appropriate training of all employees, and ongoing communication and train with local responder. Employee participation in the release prevention program is encourage and supported by Morton management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for MTS and H2Se. Morton employees are also members of the facility emergency response team. Morton policy is to construct all new equipment, systems, and facilities in accordance with the most current building and safety codes. This ensures the appropriate safety and release prevention systems are included from the beginning of each project. Morton maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release. Morton is committed to providing comprehensive safety training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, Morton conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Memb ers of Morton's emergency response team receive annual training to ensure that response actions are promptly and safely completed. Annual training with local responders is part of this program. |