Millennium Specialty Chemicals - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Millennium Specialty Chemicals Colonels Island facility, we are committed to operating and maintaining all of the processes (especially those using hazardous substances) in a safe and responsible manner. A combination of accidental release prevention programs and emergency response planning programs is used to ensure the safety of employees and the public as well as the protection of the environment. This document provides a brief overview of the comprehensive risk management activities that have been designed and implemented, including: l A description of the facility and use of substances regulated by EPA's RMP regulation l A summary of results from our assessment of the potential offsite consequences from accidental chemical releases l An overview of accidental release prevention programs l A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule l An overview of the emerg ency response program l 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 l The certifications that EPA's RMP rule requires us to provide l The detailed information (called data elements) about the risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES The Colonels Island facility produces aroma and flavor chemicals using a variety of chemicals and processing operations. The facility consists of 191 acres of which approximately 25 acres is developed as a chemical processing unit. The main processes are distillation and catalytic reactions. The chemicals in use that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release, are as follows: Toxics Ammonia, Anhydrous used in the process to control acidity and as a refrigerant. Maximum inventor y approximately 42,000 lbs. Flammables Hydrogen, Liquid and Gaseous used as a reagent in the process. Maximum Inventory approximately 10,000 lbs. Accidental release prevention programs and contingency planning efforts help us effectively manage the hazards that are posed to employees, the public, and the environment by the use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that MSC provide information about the worst-case release scenario(s) 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(s) - Regulated Toxic Chemicals Anhydrous Ammonia The worst case scenario used is as follows: a hole developes in the Anhydrous Ammonia Storage tank which results in the loss of the entire contents of the system within 10 minutes. According to EPA look-up tables, the res ulting vapor cloud could travel 5.6 miles before dissapating. MSC believes that this scenario is extremely unlikely to occur for the following reasons: 1. The plant is operated in compliance with OSHA's PSM standard 29CFR1910.119 and with the RMP rule. 2. The equipment is specifically designed to safely store and dispense ammonia to the process users. It is equipped with multiple redundant pressure relief devices as well as excess flow cutoff valves. 3. The plant has trained emergency responders onsite at all times to mitigate any accidental releases so that the chance of off site impact is minimal. Worst-case Release Scenario(s) - Regulated Flammable Chemicals Cryogenic Hydrogen Storage The worst case scenario used for hydrogen storage was a complete and sudden failure in the liquid side of the storage system which releases the entire content of the tank within 10 minutes. The hydrogen immediately boils and the gas cloud explodes. According to the EPA lookup tables, the off site co nsequences of this explosion would be felt 0.25 miles from the facility. This is enough to affect our immediate neighbors in the industrial developement but not any residential or commercial property. No major roadways would be affected either. MSC believes that the possibility of such a release is extremely remote for the following reasons: 1. The plant complies with OSHA PSM standard 29CFR1910.119 and this RMP rule. 2. The equipment and processes used are specifically designed and maintained for safe storage and handling of liquid hydrogen. The equipment is equipped with multiple and redundant safety reliefs and automatic shutdown systems. 3. The plant is staffed 24 hr/day 7 days/wk with trained operators and maintenance mechanics. The scenarios presented above are extremely unlikely to occur but are useful information to use to ensure that MSC's Emergency Response Plan and the community emergency response plan address all contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION P ROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The facility maintains several programs and practices designed to minimize the possibility of accidental releases and ensure safe operation. The accident prevention programs in place include: OSHA Process Safety Management per 29CFR1910.119 EPA Risk Management Plan per 40CFR Part 68 CMA Responsible Care (R) Process Safety Management Code Spill Prevention, Control and Countermeasures Plan. Inspections and Preventative Maintenance Incident Investigation FIVE YEAR ACCIDENT HISTORY There have been no reportable releases of toxic or flammable substances covered by the RMP rule since the plant was started in 1981. EMERGENCY RESPONSE PROGRAM The facility maintains an integrated contingency plan, which consolidates all of the various federal, state and local regulatory requirements for emergency response planning. The program provides the essential planning and training for effectively protecting the employees, the public and the envi ronment during emergency conditions. The plan is available to the Local Emergency Planning Council and to Responders for coordination with the community plan. PLANNED CHANGES TO IMPROVE SAFETY The facility has a systematic program for reviewing process hazards and as improvements are identified as worthwhile, they will be implemented. This year the facility is scheduled to add to its fire fighting capabilities with additional foam generating monitors and a foam cart. CERTIFICATION The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Signature: Title: Date: RMP ELEMENTS Section 1. Registration Section 2. Toxic Worst Case Section 3. Toxic Alternate Release Section 4. Flammable Worst Case Section 5. Flammable Alternate Case Section 6. Five Year Accident History Section 7 Prevention Program Level 3 Section 9. Emergency Response Plan |