ESCO Company Limited Partnership - Executive Summary

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ESCO Company Limited Partnership is committed to the safe manufacture of fine chemicals.  The senior management at ESCO supports this commitment through our company Safety and Health policy.  This policy includes the following statements: 
"ESCO's primary business objective is to operate without incident.  The Management commitment exhibited at ESCO sets the tone for ESCO's safety attitude." 
"It is the policy of ESCO to provide for the continuous development, implementation, and maintenance of an ongoing program which assures safe and healthful working conditions, including the development of, and adherence to, safe work practices." 
At ESCO, protecting people and the environment is a part of everything we do and every decision we make.  Each employee has responsibility in ensuring that our products and operations meet applicable government or ESCO standards, whichever is more stringent. 
Our goal is to eliminate all injuries, prevent adverse environmental and health impacts, reduce  
wastes and emissions, and promote resource conservation. 
ESCO is a small chemical facility located in Muskegon, Michigan that produces colorformers.  ESCO operates in partnership with Mitsui Chemical Company and Yamamoto Chemical, Inc. in Japan.  ESCO is the nation's leader in the manufacture of colorformers.  Colorformers are "inks" that produce the image on carbonless paper forms.  The "ink" is released through pressure.  Our product has allowed the elimination of carbon paper, which previously was needed to produce multi-copy documents.  Colorformers are also used for heat sensitive applications, such as labels and fax paper; our products are used worldwide.  ESCO employs approximately 80 people. 
The EPA Risk Management chemicals used in the process are bromine and methyl chloride.  The bromine is stored in a 3,000 gallon glass-lined tank.  Administrative controls keep the maximum inventory of bromine to below 2,213 gallons.  The bromine tank is inside of a separate building and i 
s contained by a sealed concrete dike.  The methyl chloride is stored in a pressurized tank with a capacity of 7,500 gallons.  This tank is located outside in a tank farm.  Administrative controls keep the maximum inventory of methyl chloride to below 5,927 gallons. 
The EPA Risk Management worst case release at ESCO is the release of the methyl chloride from the storage tank.  This worst case creates the maximum off-site impact based on the EPA Off-site Consequence Analysis Guidance model.  The EPA model showed that the bromine release had less of an off-site impact. Administrative controls were used to minimize the inventory of methyl chloride and to minimize the off-site impact of a release.  The maximum storage capacity is 7,500 gallons and the maximum controlled inventory is 5,927 gallons.  The administrative controls include written procedures to not purchase and bring in any methyl chloride if the inventory would reach beyond the maximum level.  These inventory levels are checke 
d regularly to make sure that they are not exceeded.  The procedures also require that the methyl chloride inventory be kept to a minimum including an inventory reduction over shutdown periods. 
The methyl chloride storage tank has many safety features which make this worst case scenario unlikely.  The tank is built to withstand three times the operating pressure.  The tank is equipped with dual rupture discs and pressure relief valves to minimize the impact of a malfunction.  There are gas monitors in the diked area to monitor for any leaks, and there is a foam/water fire suppression system with a temperature detection system to help stop any fires. 
The alternative scenario for methyl chloride is the release from the storage tank through the rupture disc and pressure relief valve.  The tank is heated from a fire nearby, which causes the pressure to build in the storage tank above the rupture disc rated pressure.  The heat from the fire is maintained, so that the entire contents of th 
e tank are released through the rupture disc and pressure relief valve.  This scenario is more likely than the worst case scenario, but is still unlikely given the fire suppression system.  This scenario was chosen because it provides the greatest off-site impact in a more likely scenario.  This information helped us in planning for a methyl chloride release with the fire department.  The administrative controls to reduce the inventory as discussed in the worst case scenario were used to model this release.  The EPA Off-site Consequence Analysis Guidance was used to model this release.  The off-site impact in this scenario is much less than in the worst case scenario. 
The alternative release scenario for bromine is the failure of the glass-lined storage tank.  This failure allows the entire contents of the bromine tank to be released into the diked area which is inside of a building.  The amount of bromine in the tank is limited by the written operating procedures.  These procedures l 
imit the amount of bromine that can be stored on-site from a capacity of 3,000 gallons to 2,213 gallons.  The written procedures require the bromine on-site to be at minimum levels and includes the requirement to not purchase and bring in any bromine if the inventory level could go beyond the maximum level. The procedures also require that the bromine inventory be kept to a minimum including an inventory reduction over shutdown periods. 
The diked area limits the size of the pool formed to 150 square feet, which significantly reduces the release rate.  The building also reduces the release rate to the atmosphere by 10 percent.  The building is equipped with water spray nozzles that were assumed to be activated within 10 minutes of the release by employees.  Ten minutes was chosen to provide the greatest off-site impact from the release.  With monitors in the diked area, it is expected that the water nozzles would be activated by employees well within ten minutes time.  This information 
helped us in emergency planning for a bromine release with the fire department. The water from the nozzles would virtually eliminate the evaporative release of the bromine.  The monitoring system inside of the building would alert employees immediately of the release inside the diked area.  The monitor will detect a bromine release and activate an alarm in the control room to alert employees to activate the water spray nozzles.  The tank is inspected and tested yearly to detect any weaknesses in the tank.  The piping systems are double-walled to prevent releases from leaks.  The EPA Off-site Consequence Analysis Guide predicts a very minimal off-site impact from this release. 
ESCO is required to comply with the O.S.H.A. Process Safety Management standard.  Both the processes that use methyl chloride and bromine have been extensively reviewed for safety through the Process Hazard Analysis.  We work through a What-If/Checklist procedure in the Process Hazard Analysis meeting where team 
members bring up "what if" questions that we answer based on our safety systems and procedures.  This procedure helps to make sure that we are operating a safe system and that there are safeguards in place to protect employees and the environment.  ESCO has incorporated the requirements of Process Safety Management into the batch records to provide clear and safe batch instructions.  Each operator is trained in the operation of the equipment and the safety systems before they are allowed to operate the equipment.  ESCO employs a preventive maintenance system that helps make sure that equipment gets inspected and tested as necessary to ensure its integrity to handle the chemicals of the process.  Procedures are in place to make sure that contractors who work at our facility are trained and are made aware of the safety procedures required at this facility.  Any changes made to the process are carefully reviewed and documented to make sure that any safety concerns are addressed. 
The EPA 
requires that a five-year accident history be developed describing any releases of listed chemicals which resulted in deaths, injuries, significant property damage, off-site deaths or injuries, off-site evacuations or shelter-in-place procedures, or environmental damage.  In the past five years from 1994 to 1999, ESCO has had no accidental releases of methyl chloride or bromine. 
ESCO has used the EPA Risk Management release scenarios to improve our emergency response plan and to develop a stronger relationship with the fire department.  We have trained our supervisors to understand the potential scenarios of releases of bromine and methyl chloride.  We also have included the fire department battalion chiefs in this training, so that our supervisors and the battalion chiefs are familiar with each other and the actions each of them would take in an emergency. 
ESCO is committed to the principles of continuous improvement in the safety of our processes and in reducing risk to the commun 
ity.  We plan to conduct emergency drills that may include a mock release of methyl chloride or bromine to practice the emergency response procedures that have been planned.  We will review how the drill goes and improve the emergency response plan or our emergency response training as necessary.  The process hazard analysis team and the safety committee play key roles in identifying areas of improvement in the safety of our processes.  These groups will continue to meet to reassess safety equipment and procedures for improvement. 
If you have any questions, or would like more information, please contact Bruce Katje, the Regulatory Compliance Manager, at 231-727-6459.
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