Owens Corning Newark plant - Executive Summary |
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EXECUTIVE SUMMARY 1.0 INTRODUCTION Owens Corning is committed to achieving environmental leadership within its industry and beyond. The Insulation Systems Business Unit (ISB), of which the Newark Insulation Plant is a key part, demonstrates this pursuit of excellence by proactively managing its operations to reduce environmental impacts while improving the quality of its products and the well-being of its employees and the community. ISB Environmental has implemented a programmatic approach to compliance with the EPA's Risk Management Program (RMP) Rule. All of the business unitms manufacturing facilities will address process safety and risk management issues for key materials utilized by the plants in manufacturing fiberglass insulation products. The program will fulfill the general duty clause requirement in the RMP rule. The following OSHA and EPA covered processes are specifically addressed in the RMP manual: One-15,000 gallon storage tank of formaldehyde solutio n (50%) One-15,000 gallon vertical storage tank and associated surge tank of aqueous ammonia (29.5%) and mix tanks in the Binder Room Two-33,000 gallon horizontal steel storage tanks of liquid propane and associated cylinder filling equipment Facilities, like Newark, with threshold quantities above the RMP triggers, have utilized a management manual system to comply with the requirements of RMP. This submittal only characterizes the subject processes, listed above, that require a RMP submittal and certification by June 21, 1999. 2.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Owens Corning is committed to developing and operating its manufacturing facilities in a manner protective of the environment and human health. This priority is expressed through continuing process improvement, risk reduction, and an emphasis on pollution prevention. In order to produce the quality products that Owens Corning is known for, the Newark facility uses a 50% formal dehyde solution as well as an aqueous ammonia solution in the manufacturing of fiberglass binder resin for use at the facility. The facility also uses propane as a form of motorized vehicle fuel for the plant forklifts and service equipment. Because these are toxic and flammable chemicals, numerous controls have been implemented to prevent an accidental release of these chemicals. In the event of a release, the Newark facility has an emergency response program that will be implemented. This program is made up of employee volunteers that have been properly trained in certain elements of emergency response, as well as communication with the appropriate responder organizations in the community. 3.0 DESCRIPTION OF THE FACILITY AND REGULATED PROCESSES The Newark plant, located at 400 Case Avenue in Newark, Ohio, is a manufacturer of wool glass fiber and fiberglass insulation products. Glass fiber manufacturing involves the high-temperature conversion of various materials into a homogeneous melt, followed by the fabrication of this melt into glass fibers. After the formation of the glass fibers, a thermosetting chemical binder solution is applied to the fibers. The glass fibers and binder solution are then collected on a conveyor belt where they are sent through a large curing oven and then through a cooling section. The result is a mat of fiberous insulation that is then cut into batts or rolls of the desired dimensions and then packaged. Newark Insulation plant has three covered processes which are subject to RMP. The formaldehyde solution utilized in a process to manufacture binder resin is a Program Level 3 process. While both the aqueous ammonia and liquid propane storage tank systems are classified as a Program Level 2. Both formaldehyde and ammonia are binder system ingredients used to manufacture wool fiberglass insulation at the plant. Propane is used solely as a motor vehicle fuel for plant forklifts and service equipment . 4.0 HAZARD ASSESSMENT RESULTS Owens Corning has determined the distance to the toxic or flammable endpoints for regulated substances present at the Newark facility. The following release scenarios have been considered: 29.5% Ammonia Aqueous ammonia is stored in a 15,000-gallon storage tank. The tank is located in a diked containment area with a surface area of 985 sq. ft. Trucks unload the material through a 2-inch hose. Worst-case release is an instantaneous release of the maximum inventory of the tank which forms a liquid pool in the dike. The release duration is assumed to be 60-minutes because the concentration of ammonia in solution after 10-minutes of evaporation is not significantly lower than the initial concentration. Distance to Endpoint - 0.65 miles (OCAG) The alternative release involves a failure of the unloading line during product delivery resulting in a release of 4,450 pounds over a 10-minute period. The liquid released from the li ne/hose break is not contained. Distance to Endpoint - 0.21 miles (ALOHA) 50% Formaldehyde Aqueous formaldehyde is stored in a 15,000-gallon storage tank. The tank is located in a diked containment area with a surface area of 985 sq. ft. Trucks unload the material through a 2-inch hose. Both the storage tank and truck are maintained at approximately 150* F. Worst-case release is an instantaneous release of the maximum inventory of the tank which forms a liquid pool in the dike. The release duration is assumed to be 60-minutes because the concentration of formaldehyde in solution after 10-minutes of evaporation is not significantly lower than the initial concentration. Distance to Endpoint - 0.40 miles (OCAG) The alternative release involves a failure of the unloading hose during product delivery resulting in a release of 4,450 pounds over a 10-minute period. The liquid released from the line/hose break is contained in the railcar/truck unloadin g area dike, which has a surface area of 500 sq. ft. Distance to Endpoint - 0.09 miles (ALOHA) Propane Propane is stored in two identical 33,000-gallon storage tanks. The maximum fill volume of each propane tank is 80% for a capacity of 26,400 gallons. At 4.24 lb/gal, each tank maximum inventory is 111,936 pounds. The tanks operate at ambient temperature and equilibrium pressure. Worst-case release is an instantaneous release of maximum inventory and formation of a vapor cloud, which explodes. Ten percent of the vapor participates in the explosion. Endpoint for a flammable is defined as the distance to a 1-psi overpressure. Distance to Endpoint - 0.39 miles (OCAG) Alternative case release is an instantaneous release of maximum inventory and formation of a vapor cloud, which explodes. Three percent of the vapor participates in the explosion. Endpoint for a flammable is defined as the distance to a 1-psi overpressure. Distance to Endpoint - 0.2 4 miles (OCAG) All of the release scenarios examined above could result in off-site impact. Both OCA guidance look-up table values and air dispersion modeling for the toxic compounds via ALOHA were examined and reported as indicated. 5.0 GENERAL ACCIDENTAL RELEASE PREVENTION/CHEMICAL- SPECIFIC PREVENTION STEPS Mitigation measures were considered in formulating the alternative scenarios since unloading incidents are the most commonly occurring incident type. The presence of an unloading pad containment dike for the ammonia process was considered as a passive mitigation measure, which would limit ammonia evaporation and thus reduce release rate. Accidental releases are mitigated by an aggressive spill reporting program and operator training in spill response. 6.0 FIVE-YEAR ACCIDENT HISTORY Historic incidents are typically small local spills during unloading activities within containment of less than 600-gallons of formaldehyde and 20-gallons of ammonia since 1994. Non e of these documented incidents resulted in an off-site or employee injury. No propane incidents were documented during the 5-year period. 7.0 EMERGENCY RESPONSE PROGRAM Newark maintains an up-to-date Emergency Response Plan (ERP) and conducts appropriate training and periodic drills to train on response procedures. The ERP resides in the plant public drive server (P: drive) and is available to all plant personnel. 8.0 PLANNED CHANGES TO IMPROVE SAFETY The following list of capital improvements represents an investment of approximately $400,000 that has been scheduled throughout 1999 by the Newark Plant in upgraded process safety controls and other equipment to mitigate and reduce the prospect of an accidental release. Automatic level monitoring with safety shutoff valves on appropriate Chemical Factory storage tanks. Installation of temperature indication for appropriate chemical storage tanks. Installation of a PLC based control system including Panelview o perator interface terminal to monitor as well as control for aspects of the chemical storage and Reactor batching process. Installation of acid quench system for runaway resin reactions. Installation of a non-contact means of measuring phenol rail car temperature. Upgrade of valves and gauges on Propane system. Removal of obsolete tank and pumping system in the propane system. Modification of propane venting and upgrade of unloading system. Implementation of Mechanical Integrity system for ammonia and formaldehyde storage and processing systems. Through continued review of the chemical processes surrounding resin manufacturing, binder mixing, and the propane system additional moneys are anticipated being committed in 2000 and beyond. This program, aimed primarily at release prevention and automation of certain manual processes, will further reduce likelihood of accidental chemical releases. |