Engelhard Corporation - Executive Summary

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ACCIDENT RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
The Erie Site has a long and proud history of safe operations and commitment to our employees and the community.  Engelhard, as a responsible corporate citizen, is committed to respecting the environment in the conduct of its business and recognizes the need to preserve and protect our vital natural resources.  Environmental protection plays a key role in Engelhard's business objectives and is an integral component of all daily operations.  Our continued emphasis on operator safety is evidenced by the fact that we have a very low accident rate and have worked over three years and a total of over one million man-hours without a lost time injury.  We are routinely inspected by the Pennsylvania Department of Environmental Protection (PADEP) for our compliance with all applicable air, water, and  waste regulations.  There have been no incidents of non-compliance.  Similarly, we have a good record with the City of Erie Bureau of  
Sewers on our waste-water compliance.  The site also complies with the applicable Occupational Safety and Health Administration (OSHA) Process Safety Management Standards for the regulated processes.  The site is International Organization for Standardization (ISO) 9000 certified.  Most importantly, we have not had any accidental releases of a regulated hazardous substance in the past five years.     
 
The Engelhard Erie Site is an active part of the Erie County Emergency Management Agency's "Emergency Response Program" for the Erie, Pennsylvania  community.   Site personnel serve in the leadership of the Erie County Local Emergency Planning Commission (LEPC) and we routinely invite the Local Fire Department to our site to review our operations and to educate them on the chemicals we use.  We have trained forty site personnel to the Operations and Technician levels as Hazardous Waste Operations and Emergency Response (HAZWOPER) First Responders.  We have a strong internal safety awaren 
ess training program and detailed response plans to cover emergency situations.  We will work in cooperation with the appropriate emergency response services available in the community to meet any challenge.  The site has an approved detailed emergency plan on file with the Erie County LEPC and is in compliance with the EPA's Emergency Response Program requirements. 
 
STATIONARY RESPONSE AND REGULATED SUBSTANCE HANDLED 
 
The Engelhard Erie plant manufactures nickel, vanadium, copper, chrome and noble metal-based catalysts.  These catalysts are used in the food and petrochemical industries.  Anhydrous Hydrogen Chloride (AHCL), which is on the RMP regulated substance list, is used as a raw material in the manufacture of just two of our many different catalyst products.  These two products are members of a family of catalysts that are manufactured in a single facility covered by OSHA's Process Safety Management program.  The Erie Plant typically operates on a 24 hour per day - seven days pe 
r week schedule.  The various products that are manufactured at the site are campaigned and the two products made from AHCL are typical of our "job shop" production schedule.  Specifically, these two products are manufactured in campaigns and would only require the use of AHCL for about three months per year.  At the completion of the production campaign, the AHCL is returned to the vendor so as not to be stored unnecessarily on site.  Our employees receive a great deal of training in the safe handling of AHCL and we have numerous safety procedures and devices engineered into our process to insure that we can routinely handle AHCL in our process safely. 
 
The offsite consequence analysis includes consideration of two release scenarios for AHCL, the "worst case scenario" and an "alternate case scenario".  The "worst case scenario" is defined by EPA and states that "the owner or operator shall assume that the...maximum quantity in the largest vessel...is released as a gas over 10 minutes 
," due to an unspecified failure.  This is an extremely unlikely event.  The "worst case scenario" also requires that wind speed and other meteorological conditions be virtually optimized to allow the maximum dispersion of the chemical.  Another feature of the "worst case scenario" is the fact that we must assume that none of our administrative procedures or our engineered safety devices to safe guard the site and community are in use at the time of the release.  Once again it is extremely unlikely that events would ever turn out that way.  The "alternate case scenario" is defined as "more likely to occur than the worst case release scenario".  In this example, we have a realistic release profile, coupled with typical meteorological conditions and wind speed.  The assumption is that our administrative procedures and engineered controls are in place and we have as a result a much more realistic model of a likely outcome.  Even the "alternate case scenario" is an unlikely event, especial 
ly when we consider that we don't have AHCL on site for about nine months of the year and we have not had any accidental releases in the past five years.  
 
WORST AND ALTERNATE CASE SCENARIOS 
 
The atmospheric dispersion modeling, which has been performed to the requirements put forth by the EPA, is used to determine the potential distance the AHCL will travel before its concentration decreases to the "toxic endpoint".  This end point for AHCL specified in 40 CFR Part 68 Appendix A is 0.03mg/L of air (20 ppm).  The residential population within a circle with a radius corresponding to the toxic endpoint distance has to be defined, "to estimate the population potentially affected".   
 
The "worst case scenario" involves a failure of a tube in a tube trailer.  The tube contains 3,000 lbs. of AHCL, which is released as a gas over a 10-minute period.  EPA mandated meteorological conditions for the "worst case scenario were: Stability F, wind speed of 1.5 meters per second, highest daily temper 
ature of 98 degrees F (as supplied from 1995-1997 PADEP Erie COPAM Station data), and average humidity of 71% (three year average of 1996-1998 as supplied by the PADEP Erie COPAM Station).  Since the Erie facility is located in a city, the "worst case scenario" would encompass the residential population and environmental receptors.  Again, the possibility that this scenario would occur is extremely remote.   
 
The "alternate case scenario" involves a breech (20% rupture) in the 0.5 inch connecting line to the tube trailer.  The entire contents of three tubes are released based on the normal operation of the AHCL feed from the tube trailer.  The start of the release is conservatively set at 15 minutes prior to activation of the water deluge system, one of several of our engineered safety devices.  The release is assumed to last for an additional 203 minutes, after the water deluge system is activated.  During this time, the three tubes of AHCL would empty.  Meteorological conditions used 
for the "alternate case scenario" are ambient wind speed of 3 meters per second, temperature of 98 degrees F, atmospheric stability D and relative humidity of 71%.  The "alternate case scenario" is more plausible than the "worst case scenario" but is still a very unlikely event.  As modeled, it would affect a few offsite residents but would not encompass any environmental receptors. 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND PREVENTION STEPS 
 
The Engelhard Erie Site has had an active safety program and exemplary safety results, since operations were started in 1964.  Since April 1995, the OSHA Process Safety Management Program has covered the operating department that uses AHCL.  Each of the 14 management elements in the Program is followed.  Some of the highlights are: 
1. There is a written Employee Participation Plan, which is being implemented. 
2. A Process Hazard Analysis was conducted in early 1995.  Required Process Safety Information was available.  Major problem areas  
were corrected. 
3. Operating Procedures are up-to-date. 
4. Operators are trained and qualified. 
5. There is an active contractor qualification and selection program. 
6. Change is managed and pre start-up safety reviews are conducted. 
7. A preventive maintenance and inspection program covers critical equipment. 
8. Site work practices are covered by required permit systems. 
9. Incidents are investigated. 
10. Compliance audits were conducted in April of 1995 and July of 1997.  Major problem areas were corrected. 
 
FIVE YEAR ACCIDENT HISTORY 
 
There have been no accidental releases of AHCL within the past five years.  This is a very key point and one which gives credibility to our commitment to employee and community safety. 
 
EMERGENCY RESPONSE PROGRAM 
 
Engelhard Erie has a comprehensive Emergency Procedures Manual that includes:  
1. A description of the emergency organization. 
2. Evacuation alarms and evacuation routes. 
3. Procedures for communication and public notification 
4. Emergency me 
dical plans. 
5. Procedures for support services. 
6. Department shutdown plans. 
7. Procedures for handling spills. 
8. Emergency Response Team procedures and checklists. 
 
In addition, the site is covered by an Off-Site Plan that has been approved by the Erie County Local Emergency Planning Commission (LEPC).   
 
Engelhard Erie has emergency responders trained at the 24-hour technician level (OSHA HAZWOPER Standard).  These responders are trained to handle potential releases of AHCL.  Specific on-site response plans for handling releases of AHCL exist.  The Emergency Response Team is well equipped with conventional chemical sensing equipment, personal protective equipment, offensive and defensive strategy tools and equipment, and radio communication. Pre-determined response checklists are available for the Incident Commander, Operations Chief, Security Officer, Staging/Resources Chief, Safety Officer, and Environmental Officer.  Emergency decontamination and medical equipment and supplies  
are available.  The Engelhard Erie Emergency Response Team uses the Incident Command System.  This system includes provisions for interaction and support of off-site professional emergency responders. 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
As mentioned earlier, a process hazard analysis of the facility was conducted in early 1995.  As a result of that analysis, a number of improvements were made to the AHCL system.  Included were: 
1. Installation of a fixed water deluge system above the tube trailer piping header. 
2. Addition of critical AHCL equipment to the preventive maintenance system. 
3. Installation of bars and locks to prevent tube trailer from being moved while connected. 
4. Installation of several additional alarms and interlocks. 
5. Establishment of a procedure which requires tube trailer connection piping to be replaced when each new truck is piped in. 
 
Within the next six months the process hazard analysis will be revalidated, which will in all likelihood lead to additional im 
provements.  Also, within the next six months, a number of emergency drills are planned and an operator refresher training session is scheduled.  The possibility of installing a sensor system to provide early recognition of AHCL leaks is also being evaluated.
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