Morton International, Inc. Cincinnati (Reading),OH - Executive Summary |
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Accident Release Program and Emergency Response Policy It is the policy of the Morton International, Inc. Cincinnati, Ohio facility management to implement the requirements of the Risk Management Program (RMP) herein 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, and if a release occurs, to minimize the impact to Morton employees, the community and the environment. This objective is met by continuing to utilize general good operating procedures, providing appropriate training to all employees, and communicating and coordinating response activities with the local emergency response providers. Morton has taken a number of steps to minimize the quantity of hazardous compounds that are stored on-site. For example, the facility has reduced the inventory of propane to a level that is below the RMP thr eshold. The RMP regulated materials have been handled safely for over twenty years at this site. Facility Description Morton International's Cincinnati, Ohio, facility operates primarily as a manufacturer of specialty chemicals. Four chemicals - ammonia (in aqueous solution), chlorine, ethylenediamine and methyl chloride - are utilized at the facility in sufficient quantities to be subject to the RMP requirements in detailed at 40 CFR Part 68. All chemicals used at the facility, including those regulated by the RMP, are handled and stored using best management practices. 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: a "worst case scenario" must be examined as well as an "alternative case scenario". By EPA regulations the "worst case scenario" is defined as the catastrophic rupture of the vessel (or pipe) th at causes the maximum quantity of the regulated chemical to be released. The EPA specifies that all of the regulated chemical is released. In addition, the "worst case scenario" requires us to assume all process controls, safety devices, monitoring and detection systems fail to operate as designed. Further, worst case scenarios do not consider possible causes or likelihood of the event. The EPA also defines the conditions under which the evaporated material dissipates including conservative assumptions regarding the temperature, wind speed and the tendency for "mixing" to occur in the atmosphere. These EPA assumptions are such that the predicted concentration of the chemical represents an over-estimate of what would actually occur. By EPA regulations the "alternative release scenario" is an emergency planning release scenario that must lead to an off-site impact based on a facility's use of the regulated chemical. The emergency planning scenario takes into account the facility's safety systems and response plans to minimize the release. 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 consequences analysis indicated that using the EPA guidelines there could be off-site impact in the event of an incident. For example, a catastrophic release of chlorine from the rail car (defined by the RMP regulations as the worst case) would impact the surrounding community. The alternative release scenarios that were developed for each chemical indicated that the impact zone would be significantly reduced by compari son to that predicted for the worst case scenario. The likelihood of either of these scenarios occurring is very small demonstrating Morton's ability to handle chemicals in a safe manner. In fact, the reduced impact areas of the alternative scenarios compared to the worst case scenario is one measure of the effectiveness of Morton's prevention and safety programs. Five Year Accident History Morton has not had any release of ammonia solution, chlorine, ethylenediamine, or methyl chloride from the Cincinnati, Ohio facility that has caused serious injury, significant property damage, affects to the community or the environment. Emergency Response Program Morton's Cincinnati, Ohio facility is staffed with employees trained in emergency response 24 hours per day. These employees receive annual training on emergency procedures and response techniques. The local emergency responders in the community utilize lap-top computers containing CAMEO and ALOHA for determining the likely exten t of impact from a release. Hence, the facility chose to use these programs, in conjunction with guidance developed by the U.S. EPA, to determine the extent of the area predicted to be impacted under the various scenarios described above. Planned Changes to Improve Safety Morton completes a thorough review of the potential impact of all chemicals considered for use at the facility prior to their use. This includes compounds that are not specifically addressed under the RMP regulation. Morton has reviewed the chemicals currently used on site as part of the compliance program involving the Clean Water Act, the Clean Air Act, RCRA, Spill Prevention and Contingency Planning and Accidental Release prevention. Further, Morton conducts Process Safety Management reviews at least every three years to ensure that each process that employs hazardous chemicals is thoroughly examined. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Cincinnati 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 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 encouraged and supported by Morton management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia solu tion, chlorine, ethylenediamine, and the methyl chloride. 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 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 employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of Morton's emergency response team receive quarterly training to ensure that response actions are promptly and safely completed. Annual training with local responders is a part of this program. |