Ringwood Facility - Executive Summary |
|
Executive Summary of the Risk Management Program Plan and Emergency Response Policy It is the policy of the Morton International, Inc. (Morton) Ringwood, Illinois facility management to implement the requirements of this Risk Management Program (RMP) 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 risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to Morton employees, the public and the environment. This objective will be accomplished by utilizing 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 Ringwood, Illin ois and operates primarily as a manufacturer of specialty chemicals. Seven chemicals, acrylonitrile, ammonia, methyl chloride, vinyl acetate, vinylidene chloride, toluene di-iscoyanate, and methyl thiocyanate, are utilized at the facility in sufficient quantities to be subject to the requirements of 40 CFR Part 68, RMP. Consequence Analysis The Risk Management 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 vessel (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 si te. 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 used are 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, safety valve releases) that have involved chemicals, items that have been identified through the HAZOP process and those associated with the chemical industry in general. The RMP regulations provide for the use of assumptions influencing dispersion that are more likely to occur during an alternative release scenario. The worst case consequence analysis that was perf ormed 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 methyl chloride 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 methyl chloride. 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. Fi ve Year Accident History Morton has not had any release of acrylonitrile, ammonia, methyl chloride, vinyl acetate, vinylidene chloride, toluene di-isocyanate, or methyl thiocyanate from the Ringwood, Illinois facility that has had major offsite impacts, such as serious injury, evacuation, contamination of soil, ground water, or drinking water; or vegetation or crop damage. Emergency Response Program Morton has personnel trained in emergency response at the facility 24 hours per day, seven days per week. These personnel receive ongoing training on emergency procedures and response techniques. The local responders have been provided with the Ringwood Facility emergency response plans and RMP plan. Continuous Safety Improvement The Ringwood 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 to 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 RMP plan are employee participation, appropriate design and maintenance of equipment, appropriate training of all employees, and ongoing communication and training with local responders. Employee participation in the release prevention program is encouraged and supported by Morton management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the acrylonitrile, ammonia, methyl chloride, vinyl acetate, vinylidene chloride, toluene di-iscoyanate, and methyl thiocyanate. 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 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. Additionally, Morton conducts audits on a routine basis to ensure that each process that employs hazardous chemicals is thoroughly examined. Morton is committed to providing appropriate 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 employe es each month. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of Morton's emergency response team receive monthly on-site and yearly off-site training to ensure that response actions are promptly and safely completed. Cooperative training with local responders is a part of this program. |