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Croda, Inc. - Atlas Point

Parent Companies:
EPA Facility ID:
100000109606
Other ID:
19720CMRCSCHE
Facility DUNS:
0

Location:

Address:
315 Cherry Lane
New Castle, DE 19720
County:
NEW CASTLE
Lat / Long:
39.692, -75.542 (Get map)
Method:
Interpolation - Map
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
100

Owner/Operator:

Name:
Croda, Inc.
Phone:
(302) 429-5599
Address:
315 Cherry Lane
New Castle, DE 19720
Foreign Address:

Person responsible for RMP implementation:

Name:
Chris Barnett
Title:
Site Director

Emergency contact:

Name:
Derrick Schweitzer
Title:
SHE Manager
Phone:
(302) 429-5201
24-hour phone:
(302) 429-5315
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
New Castle LEPC
Full-Time Equivalent Employees:
193
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
AQM-003/00426
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 12, 2014
Inspecting Agency:
OSHA
Using Predictive Filing:
No

Processes:

Storage in Railcars
RMP ID:
1000084834
CBI claimed:
No
Program Level:
3
NAICS:
Surface Active Agent Manufacturing (325613)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
1,433,200
No
Propylene oxide [Oxirane, methyl-]
75-56-9
303,800
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Ethylene Oxide System
RMP ID:
1000084835
CBI claimed:
No
Program Level:
3
NAICS:
Surface Active Agent Manufacturing (325613)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
500,000
No
Public OCA Chemical
0
No
Propylene Oxide System
RMP ID:
1000084836
CBI claimed:
No
Program Level:
3
NAICS:
Surface Active Agent Manufacturing (325613)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propylene oxide [Oxirane, methyl-]
75-56-9
277,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Feb. 7, 2018
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000067618

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ethylene Oxide System)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
1420.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Drains
  • Sumps
not considered:
  • Enclosures
  • Berms

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ethylene Oxide System)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Drains
  • Sumps
not considered:
  • Enclosures
  • Berms
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
  • Excess flow valve
  • Scrubbers
  • Emergency shutdown
not considered:
  • Water curtain
  • Neutralization
  • Flares
Public OCA Chemical (in Propylene Oxide System)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Drains
  • Sumps
not considered:
  • Enclosures
  • Berms
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
  • Excess flow valve
  • Scrubbers
  • Emergency shutdown
not considered:
  • Water curtain
  • Neutralization
  • Flares

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Storage in Railcars, Surface Active Agent Manufacturing (325613)
Prevention Program ID:
1000071614
Safety Review Date
June 21, 2016, since latest RMP submission
PHA Update Date
Oct. 11, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Runaway reaction
  • Overpressurization
Process Controls
  • Relief Valves
  • Manual Shutoffs
  • Alarms
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
Dec. 28, 2017, since latest RMP submission
Training Review Date
May 21, 2014, since latest RMP submission
Maintenance Review Date
Dec. 11, 2017, since latest RMP submission
Maintenance Inspection Date
March 24, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 7, 2016
Management of Change Review Date
Nov. 18, 2016
Pre-startup Review Date
Nov. 5, 2014
Compliance Audit Date
June 21, 2016
Compliance Audit Change Completion Date
Nov. 30, 2018
Incident Investigation Date
Dec. 5, 2015
Incident Invest. Change Completion Date
April 25, 2016
Participation Plan Review Date
Feb. 19, 2016
Hot Work Review Date
Oct. 3, 2016
Contractor Safety Review Date
March 28, 2012, since latest RMP submission
Contractor Safety Eval. Date
Sept. 16, 2016, since latest RMP submission
Ethylene Oxide System, Surface Active Agent Manufacturing (325613)
Prevention Program ID:
1000071612
Safety Review Date
June 21, 2016, since latest RMP submission
PHA Update Date
April 21, 2017, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 28, 2017, since latest RMP submission
Training Review Date
June 10, 2014, since latest RMP submission
Maintenance Review Date
Dec. 11, 2017, since latest RMP submission
Maintenance Inspection Date
Sept. 15, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 8, 2016
Management of Change Review Date
Nov. 18, 2016
Pre-startup Review Date
Sept. 24, 2016
Compliance Audit Date
June 21, 2016
Compliance Audit Change Completion Date
Nov. 30, 2018
Incident Investigation Date
June 4, 2014
Incident Invest. Change Completion Date
Sept. 9, 2014
Participation Plan Review Date
Feb. 19, 2016
Hot Work Review Date
Oct. 3, 2016
Contractor Safety Review Date
March 28, 2012, since latest RMP submission
Contractor Safety Eval. Date
Sept. 16, 2016, since latest RMP submission
Propylene Oxide System, Surface Active Agent Manufacturing (325613)
Prevention Program ID:
1000071613
Safety Review Date
June 21, 2016, since latest RMP submission
PHA Update Date
April 21, 2017, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 28, 2017, since latest RMP submission
Training Review Date
June 10, 2014, since latest RMP submission
Maintenance Review Date
Dec. 11, 2017, since latest RMP submission
Maintenance Inspection Date
Sept. 15, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 8, 2016
Management of Change Review Date
Nov. 18, 2016
Pre-startup Review Date
March 28, 2015
Compliance Audit Date
June 21, 2016
Compliance Audit Change Completion Date
Nov. 30, 2018
Incident Investigation Date
June 4, 2014
Incident Invest. Change Completion Date
Sept. 9, 2014
Participation Plan Review Date
Feb. 9, 2016
Hot Work Review Date
Oct. 3, 2016
Contractor Safety Review Date
March 28, 2012, since latest RMP submission
Contractor Safety Eval. Date
Sept. 16, 2016, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Aug. 25, 2016
Local Response Agency:
Local Response Agency Phone:
(302) 654-2817
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Croda

Atlas Point Site



Risk Management Program

2014 Update



1. Accidental Release Prevention and Emergency Response Policies

The Croda Atlas Point site uses ethylene oxide and propylene oxide as raw materials in the manufacture of various surface active agents (surfactants). Surfactants are used in household, personal care and industrial applications. It is Croda's policy to comply with all applicable state and federal regulations. Croda is in compliance with the Environmental Protection Agency (EPA) Risk Management Program, 40 CFR Part 68. The 5-year RMP submission is being made in accordance with the requirements specified in 40 CFR 68-190(b)(1).



The Croda Atlas Point site conducts hazard analysis reviews prior to the design, construction and operation of any process unit. Records are kept of each hazard review and the actions implemented as an outcome of the review are documented. Detailed information relating to Croda's accidental release prevention program is provided in the Accidental Release Prevention Program section.



The Croda site maintains an Integrated Contingency Plan (ICP) that describes the emergency response program. It is Croda's policy to respond in an efficient and effective manner to any emergency that occurs at the Croda Atlas Point site. Croda personnel regularly prepare for emergencies by conducting emergency drills that have included the local fire department. A group of Croda employees have been trained to act as emergency responders, incident commanders and duty managers. Croda emergency personnel can be reached 24 hours a day in the event of an emergency.



Croda has made safety performance a priority at the Atlas Point facility. We have partnered with OSHA in the Voluntary Protection Program (VPP) a voluntary program for worksites that show excellence in occupational safety and health. This shows Croda's commitment to effective employee protection beyond the requirements of OSHA standards. As a VPP STAR Worksite, Cr
oda has developed and implemented systems to effectively identify, evaluate, prevent, and control occupational hazards to prevent employee injuries and illnesses.



The Croda Atlas Point site also has a Community Advisory Council, which meets quarterly to foster communication with our neighbors and answer questions of concern. Participants include the Delaware State Police, the Delaware Bridge and River Authority, a local school district, local businesses and government agencies, as well as local community organizations.



2. Regulated Substances Handled



The Croda Atlas Point site stores ethylene oxide and propylene oxide in quantities that exceed threshold quantities of 10,000 pounds, as defined in 40 CFR 68.115. Both ethylene oxide and propylene oxide are listed as toxic substances under 40 CFR 68.130. The Croda site does not store any additional substances in quantities greater than those specified under 40 CFR 68.130. Both substances are used on-site in chemical reactions to make surfactants, which are sold as ingredients for a variety of consumer and industrial products.



The worst case release scenario determined by Croda involves the on-site storage of ethylene oxide in an aboveground tank. The alternative release scenarios reviewed by Croda include the transfer and unloading of ethylene oxide and propylene oxide from a railcar to the on-site aboveground tanks. The largest quantities of ethylene oxide and propylene oxide that are stored at the Croda site are in the respective storage tanks. Written procedures limit the quantity stored in the on-site tanks and both storage tanks are located outside in open areas to allow ample ventilation. The tanks are located in diked areas which would contain potential spills and slow the release into the air. An emergency spill retention area, or spill sump, is located south of the tanks and was designed to capture releases from a full railcar and both the ethylene oxide and propylene oxide storage tanks s
imultaneously.



The Croda Atlas Point site has chosen to utilize EPA's Offsite Consequence Analysis Guidance and the RMP*Comp program for obtaining the worst case release scenario. Due to the complex nature of the properties of ethylene oxide and propylene oxide when stored as liquids, Croda utilized the National Atmospheric Organization's ALOHA model for the alternative release scenarios for ethylene oxide and propylene oxide because it better represents substances liquefied under pressure.



Croda obtained public and environmental receptor data through MARPLOT, a desktop mapping program sponsored by the EPA, US Bureau of Census, US Geological Society, Nuclear Regulatory Commission, Department of Transportation and Federal Emergency Management Agency.



3. Accidental Release Prevention Program and Chemical-Specific Prevention Steps



The Croda accidental release prevention program includes the components of EPA's RMP Prevention Program 3 specified in 40 CFR 68.65 to 68.87. The components include process safety information, process hazard analysis, operating procedures, training, mechanical integrity, management of change, pre-startup safety review, compliance audits, incident investigation, employee participation, hot work permits, and contractor work.



Some of the safety features in use, categoried as passive or active mitigation systems include the following.



- A network of 50 combustible gas sensors located strategically to detect leaks or loss of containment. Leak detection by the sensors will automatically trigger a staged response, starting with an alarm and progressing to water deluge, depending on the extent of the leak.



- Ethylene oxide gas sensors worn by personnel in the process area. These sensors alarm if ppm levels of ethylene oxide are detected, allowing personnel to respond prior to exposure to harmful concentrations. They also provide an early warning if there are leaks.



- A remote emergency retention area or spill sump is located
south of the storage tank area. The spill sump was designed to contain releases from a railcar and both the ethylene oxide and propylene oxide storage tanks. The capacity of the spill sump is 18,750 cubic feet. The spill sump confines the chemical and is equipped with a water spray system to dilute and contain the spill, thereby reducing the amount released to the atmosphere.



- A diked area surrounds the storage tank area and is approximately 65 feet long by 24 feet wide. The diked area captures spills and directs the liquid to the spill sump. The remote location collects leaks of flammable liquid away from process equipment to prevent the spread of fire.



- A water deluge system is installed to quench fires and absorb leaks of ethylene oxide or propylene oxide. It is designed based upon the National Fire Protection (NFPA) standards.



- A Programmable Logic Controller (PLC) is installed to improve system monitoring and control. This system monitors key parameters such as temperature and pressure and will automatically set the system to a safe state should an upset occur. A redundant interlock system, independent of the PLC, is in place to monitor and set to a safe state if critical conditions are encountered and the PLC does not respond.



- Alarms are wired and controlled through the PLC and sound an audible alarm as well as a visual flag. Alarms are early warning systems which send an alert of potential leaks.



- Emergency backup power for storage tank area lighting and control components.



- A packed column scrubber is installed to capture emissions vented during ethylene oxide and propylene oxide unloading operations. The scrubber was designed to remove emissions at a much higher than normal concentration and rate to insure that a potential upset condition would be controlled.



- A dispersion stack for the relief valve outlet was included to control and disperse emissions during an emergency release. The stack insures that the concentrat
ions at the ground level would be less than OSHA's Immediately Dangerous to Life and Health (IDLH) levels. The modeling used to design the stack included scenarios provided by DNREC and incorporated worst case scenario features.



In addition, Croda performs a Leak Detection and Repair (LDAR)inspection twice annually, which will detect small leaks and repair them before they become a hazard.



4. Five Year Accident History



In the last five years the Croda Atlas Point facility has had no accidental releases from the ethylene oxide or propylene oxide processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.



5. Emergency Response Program



The Croda accidental release prevention program includes the components of EPA's RMP Emergency Response section, specified in 40 CFR 68.90 to 68.95.

Croda maintains an Integrated Contingency Plan (ICP) that describes the site's emergency response program. The local community emergency response organization, Hollaway Terrace Fire Department, has received a copy of the ICP and has included it in the community emergency response plan. The ICP includes the following elements:



- Procedures for informing the public and local emergency response agencies about accidental releases.

- Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures.

- Procedures and measures for emergency response after an accidental release of a regulated substance. This includes a public address system throughout the worksite used to give verbal instructions in the case of an emergency.



In addition, the site's emergency response program, as included in the ICP, includes procedures for the use of the site's emergency response equipment and for its inspection, testing and maintenance. The emergency response plan includes procedures to review and update the I
CP to reflect changes at the ethylene oxide and propylene oxide storage tanks. Croda trains all employees in the applicable procedures and informs them of changes at the ethylene oxide and propylene oxide storage tanks.



6. Recent Changes to Improve Safety



Through the Process Hazard Review that is performed every five years, the safety of the systems is continuously improved. As recommended in the most recent Process Hazard Review, new equipment was purchased and installed to close railcar valves from a remote location. In the case of a hose failure (the Alternative Release Scenario) this new equipment allows the flow from the railcar to be stopped without approaching the railcar, thereby avoiding personnel exposure to the leak. As new opportunities to improve safety are identified they will be evaluated and implemented as appropriate.