Elementis Catalysts, Inc. - Executive Summary |
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The purpose of this document is to inform interested persons, including the public, that our facility is complying with the Environmental Protection Agency (EPA) Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act Section 112(r)(7). This regulation is published in Title 40 of the Code of Federal Regulations (CFR) Part 68. The Risk Management Program (RMP) regulation was developed in response to public concern regarding the consequences that a catastrophic chemical release may have on surrounding communities and the environment. The Clean Air Act required EPA to develop the RMP in an effort to help prevent accidental releases of regulated substances and to reduce the severity of a release should one occur. We have one regulated substance that is above the threshold quantities as specified in Section 68.130 of 40 CFR Part 68, and therefore must comply with the RMP program. This program provides our facility with an integrated approach to identif ying and managing the hazards posed by regulated substances. Under this program, our facility has assessed and continues to assess hazards to determine how accidental releases can impact the public health and environment. If after reading this program, you find that improvements can be made, please contact the safety and health manager, Robert Mikovitch. Because we are committed to the success of our written risk management program, we encourage all suggestions. We strive for a comprehensive, integrated prevention system, which obtains clear understanding, safe behavior, and involvement in the program from every level of our facility, as well as the general public. Elementis Catalysts Inc. practices total commitment to health, safety, and environmental performance as confirmed in our policy statement: "The health and safety of employees and the effect of our operational activities upon customers, the local community and the environment are of paramount importance to Elementis Catal ysts, Inc. We are committed to employ the highest standards of health, safety and environmental control. Our standards meet relevant statutory requirements and compare favorably with best practice in the chemical industry. They embrace the design, construction, operation and maintenance of all manufacturing equipment. The handling, processing, storage and transportation of raw materials and finished products are also subject to strict controls. Our commitment is to provide: * Plant and equipment which are safe to use; * A safe place of work; * Safe systems of work; * Appropriate information, instruction and training; * Appropriate safety equipment and occupational health facilities; * Waste minimization and acceptable disposal arrangements. Health, safety and environmental matters have greater priority than any other aspect of the Elementis Catalysts, Inc. operation. Responsibility for these issues is an integral part of the line management function although the role of every in dividual is also extremely important. By operating in a safe manner and adhering to established safe systems of work, the individual ensures the continued safety of himself and his colleagues." Our parent company, Elementis PLC reflects the corporate-wide dedication to health, safety, and the environment as well: "We are committed to managing all of our activities, throughout the world, so as to provide a high level of protection to the Environment and for the Health and Safety of our employees, customers and neighbours. We will comply with all the legal requirements and codes of practice in the countries where we operate, as a minimum, and we support the principles of the global chemical industry Responsible Care programme. Relevant information about the activities which affect Health, Safety and the Environment will be made available to employees, customers, the public, regulatory bodies and other interested parties in an understandable form. Appropriate policies and systems to manage Health, Safety and the Environment will be in operation in each of our businesses and will be formally reviewed on a regular basis. Achievement of goals and continuous improvement in Health, Safety and Environmental standards will be key measures of performance at all levels within the Group. All our employees will receive training to ensure their understanding of and competence in all relevant Health, Safety & Environmental matters and to gain their commitment to effective implementation of this policy." Elementis Catalysts, Inc. produces anhydrous aluminum chloride, a catalyst used in various chemical reactions at our customers' facilities. The only regulated substance, liquid chlorine, is supplied to the process from a 90-ton railcar. Thus, the maximum amount of chlorine in the process is 180,000 pounds. In accordance with the RMP regulation we have developed a worst-case scenario and an alternative release scenario to evaluate the offsite impact of significant accide ntal releases. These scenarios were evaluated using the RMP Offsite Consequence Analysis Guidance. Toxic endpoints were determined using RMP*Comp(tm) software provided by EPA, and offsite receptor reports were generated by Environmental Data Resources, Inc. EPA has defined a worst-case release as the release of the largest quantity of a regulated substance from a vessel that results in the greatest distance to a specified endpoint. It is simply assumed that the release takes place, without considering the possible cause or probability that such a release might occur. Based on this guidance, our worst-case scenario uses the following parameters: a) 180,000 lb. of chlorine released over a 10-minute period (18,000 lb./min) b) The toxic endpoint for chlorine is 0.0087 mg/L (ERPG-2 basis) c) 1.5 meters per second wind speed d) Atmospheric stability class F (stable) e) Ambient air temperature of 25xC f) 50% humidity g) Ground level release h) Urban topography i) No mitigation measures Using these conservative parameters, the estimated distance to the toxic endpoint is 14 miles. This would have a considerable offsite impact as indicated in Section 2 of the RMP. It must be stressed that a release of this magnitude is extremely unlikely. Furthermore, mitigation factors such as chlorine monitors, remote isolation valves, video surveillance, and excess flow valves were discounted for this scenario. Our alternative release scenario assumes a fracture in the 1" liquid chlorine transfer line. The basis for this simulation is a ten-minute release at a rate of 250 pounds per minute. Safety drills have proven that, with the advantage of chlorine monitors and remote valve closure systems, it would take considerably less than ten minutes to stop the release. Above a release rate of 250 pounds per minute, the excess flow valves on the railcars would immediately block the flow of chlorine. To summarize the parameters for the alternative release scenario, we have: a) 25 00 lb. of chlorine released over a 10-minute period (250 lb./min.) b) The toxic endpoint of chlorine is 0.0087 mg/L (ERPG-2 basis) c) 3.0 meters per second wind speed (based on EPA's model program guidance) d) Atmospheric Stability Class D (based on EPA's model program guidance) e) Ambient air temperature of 25xC f) 50% humidity g) Ground level release h) Urban topography i) No mitigation measures, other than those used to estimate release rate and duration as described above. The estimated distance to the toxic endpoint for the alternative release scenario is 0.3 miles. There are no public receptors or environmental receptors within this radius. As part of our attempt to prevent accidental releases, Elementis Catalysts, Inc. complies with the following rules and regulations: * Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 (40 CFR 355), formerly known as Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA Title III) * Occupational Safety and Health Standards 29 CFR Chapter XVII Part 1910 * Process Safety Management of Highly Hazardous Chemicals (OSHA PSM) 1910.119 As a chlorine consumer, our company has adopted the elements of responsible care developed by The Chlorine Institute. The Chlorine Institute is the safety, health and environmental stewardship center of the chlor-alkali chemicals industry. Its primary goals are the continuous improvement in the safety, human health and environmental protection performance of chlor-alkali producers, packagers, distributors and users. It sponsors and coordinates studies and research, and publishes a variety of chlorine-related technical pamphlets and drawings, and other safety-related information. By utilizing the resources of The Chlorine Institute, we have improved our process design, maintenance, and safety programs. Elementis Catalysts, Inc. has incorporated the latest technology for prevention and minimization of releases such as: * Chlorine monitors which send a udible and visual alarms throughout the plant when chlorine is detected. * Remote closure systems which, when activated, can automatically close railcar valves in the presence of a chlorine leak, power failure, compressed air failure, or nitrogen supply failure. * Video surveillance cameras for continuous monitoring of the railcar site * Excess flow valves which automatically stop chlorine flow should the flow exceed 250 pounds per minute Each new employee is trained on process and safety procedures before being placed on permanent shift work. Furthermore, every employee attends monthly training sessions covering the following topics: * Chlorine Safety * Chlorine C-Kit * On-Site Emergency Response Plan * Right to Know * Self-Contained Breathing Apparatus * Respiratory Protection * Personal Protective Equipment * Fire Safety * Lockout/Tagout * Forklift Training * Process Procedures As a result of this accidental release prevention program we have had no accidents or releases in the past five years. In fact there have been no such events in the history of the plant. Elementis Catalysts, Inc. has developed a Hazardous Materials Offsite Response plan, which is annually reviewed by the Local Emergency Planning Committee of Lehigh County. The plan is also filed with local fire companies, the Lehigh County HazMat Team, and the Pennsylvania Emergency Response Commission. The On-Site Emergency Response plan has been developed by Elementis Catalysts, Inc., in conjunction with CHLOREP, the Chlorine Emergency Plan program sponsored by the Chlorine Institute. CHLOREP is a network of about 250 teams which provide expertise and equipment to mitigate chlorine emergencies across North America. Annual reviews of the On-Site ERP and annual training sessions ensure that the plan is kept current and that the employees are adequately prepared in the event of an emergency. Periodic drills are conducted to assess the ability of operators to minimize any potential chlorine release s. Elementis Catalysts, in accordance with its safety policy, will systematically develop, test and implement new technology as it becomes available. Training programs will continue to evolve to mirror these technological developments. |