Clariant Corporation - Coventry - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Clariant Corporation, we are dedicated to protecting the health and safety of our employees and neighbors, as well as the environment at our site and in our community. We are committed to operating and maintaining all of our processes 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 the Environmental Protection Agency's Risk Management Program (RMP) regulation * A summary of results from our assessment of the potential off-site 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 planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment STATIONARY SOURCE AND REGULATED SUBSTANCES Clariant is a specialty chemical company based in Switzerland with 130 manufacturing plants worldwide. We are established as one of the world's leading producers of dyes, dye intermediates, pigments, and specialty chemicals. The Coventry Site is one of Clariant's primary manufacturing plants. Clariant's assets at the Coventry Site include production buildings, site infrastructure including a boiler house and a wastewater treatment plant, laboratories, warehouses, and an administration building. Coventry Site employees include approximately 300 Clariant employees and 20 contract maintenance and sec urity personnel. The Coventry Site produces pigments, pigment and dye intermediates, and specialty chemicals using a variety of chemicals and processing operations. Our pigment products are used in the coloration of house paint; automotive and industrial coatings; plastics for packaging; automotive components; household items; films and fibers; printing inks for magazines, packaging, advertising fliers and newspapers; toner for copiers; and crayons, pens and artist's colors. In our processes, we use the following two chemicals that the Environmental Protection Agency has identified as having the potential to cause significant off-site consequences in the event of a substantial accidental release: Toxic Chemical Maximum Inventory Use Bromine 104,000 lbs. Manufacture of pigment intermediates Sulfur Trioxide (SO3) 128,000 lbs. Manufacture of pigment intermediates Our accidental release prevention programs and our continge ncy planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's Risk Management rule requires that we provide information about the worst-case release and alternative release scenarios 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 - Regulated Toxic Chemicals Sulfur Trioxide (SO3) - Failure of the transfer line from the storage building to the production building resulting in a liquid spill of sulfur trioxide to the roadway between the tank farm and the production building. Amount released is total content of the transfer line. No mitigation is employed. The release would have off-site consequences. Alternative Release Scenarios - Regulated Toxic Chemica ls Bromine - Failure of hose used to unload bromine from the tank truck to the storage tank. Quantity spilled is maximum volume of unloading hose and associated piping. Passive mitigation is employed, as the spill drains into the unloading sump. No active mitigation is considered. The release would have off-site consequences. Sulfur Trioxide (SO3) - Failure of hose used to unload sulfur trioxide from the tank truck to the storage tank. Quantity spilled is maximum volume of unloading hose and associated piping. Passive mitigation is employed, as the spill drains into the unloading sump. No active mitigation is considered. The release would have off-site consequences. 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. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The Coventry Site complies with all EPA and OSHA accident prev ention requirements at 40 CFR Part 68 and 29 CFR 1910. We maintain a number of programs to help prevent accidental releases and ensure safe operation. 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 * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors These individual elements work together to ensure that sufficient layers of protection exist through technology, facilities, and personnel to prevent escalation from a single failure to a catastrophic event. As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Both the Bromine and Sulfur Trioxide storage tanks are located in dikes designed to contain a tank release and both tanks are located inside buildi ngs. As a result of these two passive mitigation measures, the amount of vapor released to the atmosphere in the event of a "worst-case type" release is reduced by over 99.5%. Unloading of bromine and sulfur trioxide occur in truck bays with sumps to contain a release. The truck bays are also equipped with either a foam system or a dry spray system to cover a release and thus minimize vaporization of the spilled material. Sensors are used in the processing areas to detect small leaks of bromine and sulfur trioxide. The sensors are connected to audible alarms that alert personnel so that the small leaks can be repaired before a release with off-site consequence occurs. Process control systems with interlock, alarms, and automatic shutoffs are used in both the bromine and sulfur trioxide processing areas. Manual shutoffs are also available in the processing areas as well as both storage buildings and truck unloading bays. Bromine and sulfur trioxide processing and storage vessel s are equipped with safety and relief valves to prevent over pressurization. FIVE-YEAR ACCIDENT HISTORY The Coventry Site keeps records for all significant accidental chemical releases that occur at our facility. We have not had a release involving materials covered under EPA's RMP rule that resulted in on-site injury or off-site impact during the past five years. We have a comprehensive incident investigation program. For all incidents and near miss incidents, we conduct formal incident investigations to identify and correct the root causes of the events. The employee success sharing annual bonus is currently based in part on the identification and correction of root causes of incidents. EMERGENCY RESPONSE PROGRAM The Coventry Site maintains an integrated contingency plan, which consolidates 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 w orkers, the public, and the environment during emergency situations. We coordinate our plan with the community emergency response plan. Additionally, the Coventry Site hosts an annual community drill with local community responders. We have a 24-hour Emergency Response Team (ERT) with nearly 40 members trained in emergency response, incipient stage fire fighting, and hazardous materials requirements. Several ERT members are certified Emergency Medical Technicians. Training requirements are rigorous and all members must pass a physical exam. The site has an extensive fire fighting system with monitor nozzles, hoses, foam generating capability, and sprinkler systems. We also maintain an emergency response vehicle equipped with air monitoring equipment, radio and cellular phone systems, and emergency response and decontamination materials. The Coventry Site has an established partnership with the Local Emergency Planning Committee and the local fire departments. An automated tel ephone Community Alert Network (CAN) and neighbor hotline are used to notify neighbors of a site emergency and actions to be taken. OUR GOAL: CONTINUOUS IMPROVEMENT At Clariant, we are committed to continuous improvement of Environment, Safety, and Health performance. Through our Process Safety Management program, we review hazards associated with our processes and implement actions to reduce the hazards according to risk assessment/risk management principles. |