APRC builds Asian response capacity

THE MORE THE MERRIER

EMERGENCY RESPONSE • OURAY ENVIRONMENTAL SERVICES IS LEADING A CONSORTIUM AIMING TO BRING FULL CHEMICAL RESPONSE CAPABILITIES TO THE WIDER ASIA-PACIFIC REGION

RESPONSIBLY MANAGED CHEMICAL companies do their best to ensure that their products do not have an adverse impact on people and the environment during transport. The most responsible among them aim to ensure that the same standards of environmental care are applied in all territories in which they operate. It cannot be denied, though, that ensuring a consistent level of preparedness and response capability in certain parts of the world is not so straightforward.

This was the position facing Chemours in its operations in the Asia-Pacific (APAC) region. In an attempt to change the picture, Chemours turned to US-based chemical emergency response provider OURAY Environmental Services. OURAY itself, having conducted services in the region, was aware that capabilities are lacking and that more are needed but Aaron Montgomery, president/CEO of Ouray, is not one to shirk a challenge. He and Chemours realised that if Chemours was having problems, then other OURAY clients – and, indeed, other chemicals companies – were likely to be also facing difficulties in sourcing chemical emergency response services in Asia, and the two parties decided to look at how such a service might be provided.

This has all taken place since October 2018 and by July this year OURAY was in a position to bring together a group of potential partners for a meeting in Singapore that sought to establish the extent of the need for a Level 3 response service in the broader APAC region. The consensus was that in many territories in the region there is a lack of chemical response equipment and expertise and that, even in those places where equipment and personnel are available, there is a lack of training and expertise.

As such, 14 chemical companies and three chemical logistics providers have already agreed to take part in a planned APAC Response Consortium to be operated by OURAY. Montgomery says he is aiming to have the service up and running across the region by the end of 2020 and is looking for more members for the consortium to help spread the costs.

GATHERING INTEREST In the absence of regulation, companies may decide to what extent they want to follow the standards they apply in North America or Europe in the rest of the world. It might be expected that their commitment to Responsible Care would follow them into new territories but that is not always the case. However, with increasing regulation and enforcement activities in developing nations in Asia, the need for a competent Level 3 chemical emergency response, transloading and remediation service has become more urgent.

Montgomery says that many chemical producers and logistics companies that operate throughout the APAC region have searched for a Level 3 response provider that can assist in addressing ever-increasing regulatory and penalty burdens and come up short: either there is no company that can provide a turnkey solution or, in many countries, there is no solution at all.

This was certainly the situation facing Chemours last year. After speaking with China’s National Registration Centre for

Chemicals (NRCC), the company approached OURAY to work on establishing functional emergency response services throughout the APAC region. It was decided that there would be a need for a series of ‘response pods’ strategically positioned across the area; these 20-foot containers would be fitted with all the necessary equipment to enable a prompt and effective response to chemical emergencies.

It was also realised very early on that this would be a costly exercise and, therefore, it would make sense for OURAY to seek participation from its other existing clients that had operations in the APAC region, in order to be able to spread the cost.

It did not take OURAY long to realise that Chemours was far from alone in being frustrated at the lack of response capability in the region and, after numerous calls and messages, it was decided that a group of ‘founding members’ would gather in Singapore in mid-July to thrash out the details of the service that was needed. Alongside Chemours there were representatives from DuPont, Eastman, Huntsman, Ineos, Lubrizol, Linde, Momentive and Dow; at least three more chemical manufacturers and three tank container operators have also expressed an interest.

DEVELOPING THE DETAILS That Singapore meeting provided the opportunity to establish where the response capability already exists and the equipment that is needed in the response pods. It was agreed that Taiwan, Australia and New Zealand are already covered by national response organisations but that pretty much everywhere else in the APAC region is lacking in the provision of equipment and/or expertise.

It was also determined that it would make sense to have two types of response pod available, staged at points around the region to allow their easy movement to deal with emergencies and to avoid the need for cross-border transport that could delay response action.

‘Type 1’ pods will contain all equipment required for a full-scale response to a consortium member’s Level 3 emergency response requirements, such as that needed to transfer or transload gases or liquids from tank containers, road tankers, intermediate bulk containers (IBCs) and drums. This unit will be a self-contained response unit that will allow all pumps and associated equipment to be run on an internal hydraulic power pack.

It is currently envisaged that these pods will be located in India (Mumbai), Thailand (Bangkok), western Malaysia, Singapore, Indonesia (Jakarta), Philippines (Manila), China (Shanghai), South Korea (Seoul), Japan (Nagoya) and Vietnam (Ho Chi Minh City).

‘Type 2’ pods will be stocked as secondary stores to supplement the equipment available elsewhere in the country in a Type 1 pod; these pods will contain a large variety of supplies to conduct liquid transfers, as well as absorbents, neutralisers and personal protective equipment (PPE), which will also be in the Type 1 pods, along with area control and lighting equipment. These units are intended for large-scale Level 3 response to chemical releases, transloads, transfers or other scenarios where gas and liquid transfer and handling equipment might be required. At present, it is expected that these will be needed in China (Beijing and Shenzhen) and India (Chennai and Ahmedabad).

LET’S TALK MONEY OURAY has worked out the cost of providing the necessary equipment, aided by the offer by DuPont and Chemours to make their existing stocks available to the consortium. It will also undertake the management of the network, re-supply pods as necessary and charge for projects on a ‘time and materials’ basis.

OURAY is leaving the window open for additional ‘founding members’ to come forward by the end of February 2020. After that, other interested parties may join the consortium but it is envisaged that they will pay more than the founding members, who have already invested the time and energy in developing the concept.

From the consortium’s inception, the idea has been about controlling liability and managing corporate risk while protecting the public and environment. In this regard, the consortium mirrors the way the oil and gas industry sought to form response consortia around the globe in the late 1980s to control their liability. However, the chemical industry places a wide range of commodities into the supply chain, which demands a correspondingly wide range of response expertise.

The next step is for OURAY to continue to promote the consortium through its own contacts, while the founding members are encouraged to engage with their contacts in the industry. As Montgomery says, “This will help collectively lessen the costs and also help to communicate that the industry as a whole must take collective action to mitigate current and future risks. We as an industry are collectively far stronger when unified as more consortium members are added.”

Those interested in finding out more about the consortium should approach Montgomery by email at amontgomery@ ourayservices.com or OURAY’s director of operations, Drew Higgins (dhiggins@ ourayservices.com). HCB

OURAY CEO AARON MONTGOMERY (BELOW): INDUSTRY

MUST TAKE COLLECTIVE ACTION TO MITIGATE CURRENT

AND FUTURE RISKS AND IS FAR STRONGER WHEN ACTING

AS A UNIFIED CONSORTIUM